THE MODERN SLAVERY ACT 2015

What is it ?

The UK Parliament implemented The Modern Slavery Act 2015 to confront human trafficking and modern slavery. Using both existing legislation and new measures, the Act specifically targets organisations and their supply chains.

Who does the Modern Slavery Act apply to?

Government guidance states that

“Every organisation carrying on a business in the UK with a total annual turnover of £36m or more will be required to produce a slavery and human trafficking statement for each financial year of the organisation.”

Any organisation in any part of a group structure will be required to comply with the provision and produce a statement if they:

  • are a body corporate or a partnership (described as an “organisation” in this document), wherever incorporated;

  • carry on a business, or part of a business, in the UK;

  • supply goods or services; and

  • have an annual turnover of £36m or more.

Total turnover is calculated as:

  • the turnover of that organisation; and

  • the turnover of any of its subsidiary undertakings (including those operating wholly outside the UK).

“Turnover” means the amount derived from the provision of goods and services falling within the ordinary activities of the commercial organisation or subsidiary undertaking, after deduction of:

  • trade discounts;

  • value added tax; and

  • any other taxes based on the amounts so derived.

What is included in a modern slavery statement?

There is no fixed structure and content, however a typical modern slavery statement will include a number of elements. It represents the organisation’s report to the outside world of the steps being taken to ensure that slavery does not exist in the business or it’s supply chain.

As a guide the following sections might be found in a high quality modern slavery statement:

  1. An introduction to the organisation confirming it’s commitment to the eradication of slavery and trafficking in all forms.

  2. Overview of the organisation, it’s structure and supply chains.

  3. Modern slavery governance. A specific section of the statement detailing the structure and management roles and responsibilities within the organisation in relation to modern slavery.

  4. A link to relevant organisation policies.

  5. Supply chain due diligence. An explanation of the due diligence that is carried out on suppliers.

  6. A summary of the approach taken to training and raising awareness of the issue of slavery and trafficking amongst staff of the organisation.

  7. Key performance indicators that are used within the organisation to monitor progress in relation to modern slavery management.

  8. An action plan of initiatives that are in place and or are planned for the next year.

THE MODERN SLAVERY ACT – WHO NEEDS TO COMPLY ?

The Modern Slavery Act and Who Needs To Comply ?

The Modern Slavery Act 2015 states that:

“Every organisation carrying on a business in the UK with a total annual turnover of £36m or more will be required to produce a slavery and human trafficking statement for each financial year of the organisation.”

This would seem a very straightforward requirement. Unfortunately, as at October 2019, it is estimated that as many as 25% of organisations required to comply have yet to do so. This is 4 years after the Act was introduced.

However, there is good news. In the last 4 years, many of the UKs leading firms are ‘stepping up’ and looking to drive improvements in their supply chains. Firm’s like Marks & Spencer, Tesco, and other major retailers, as well as firms across all UK business sectors.

3 REASONS AN SME SHOULD COMPLY WHEN THEY AREN’T REQUIRED TO?

  • Because it is the right thing to do! Business owners or directors surely do not wish to take advantage of people trafficked for work. Shouldn't they also insure that their own workforce or that of their suppliers are not living in conditions of slavery.

  • If that’s not a good enough reason in itself, complying with the Modern Slavery Act enables you to stay ahead of competitors. This may allow you to win a place on the supplier roster for the biggest tier 1 UK firms. Many SME businesses will already be finding that their larger customers are looking for evidence that slavery or human trafficking are not a risk in their supply chain.

  • Thirdly, do you employ anyone under the age of 35? If so, the chances are they are expecting you to demonstrate good social and environmental values.

    https://www.wespire.com/10-things-millennials-look-for-in-an-employer/

PRACTICAL STEPS TO HELP AN SME BUSINESS COMPLY WITH THE MODERN SLAVERY ACT 2015

  • Appoint a senior member of the business to lead the firm’s understanding of the issues. They will need to own the actions and understand the basic requirements of The Modern Slavery Act.

  • Secondly, carry out an assessment of your business. Use the findings to create action plans and move the business forward. Try using the Bizblocs cloud based anti-slavery software to start your journey and plan the way ahead.

  • Train your people in how to “spot the signs” of slavery in the workplace. A number of organisations including Unseen (the anti slavery charity) and Stronger2Gether (specialist training and consultancy firm) have a range of solutions to train your key personnel.

  • Draft a Modern Slavery Policy for your firm to set out how you will manage your business. This will ensure there is no opportunity for human trafficking or forced labour in your business or your supply chain.

  • Begin to fully question your supply chain. Incorporate a modern slavery questionnaire in your procurement and supplier management processes. Commit to the production of a modern slavery statement on an annual basis. Submit the statement to TISC so that you appear on the national register of firms complying with the Act.

SAVE THE MODERN SLAVERY HELPLINE

Save the Modern Slavery Helpline

Without urgent funding, the UK Modern Slavery Helpline will close on 30 November. Because of this thousands of victims across the UK will lose their only chance of freedom. For more info or to give now, go to https://buff.ly/2ZZ8n6a #DontLetHerGoUnseen #ModernSlavery @MSHelpline.

IN CRISIS

Since 2016, over 15,000 potential victims of modern slavery – including many British nationals – have been identified across the UK through the Modern Slavery Helpline. And the number of calls is increasing. July 2019 was our busiest month ever.

At the same time, key income has been slow to secure, leaving us with a major funding crisis.

We need to raise £800,000 to not only save the Helpline today but to also sustain it in the long term. Without immediate donations the Helpline will close on the 30th November 2019.

This is not a marketing ploy, it is reality. And men, women and children across the UK will remain enslaved and unseen.

SUPPORTING UNSEEN UK AND DUCHENNE UK

Clarke Wilmott and Bizblocs supporting Unseen and Duchenne UK

Partners from Bizblocs joined a 14-strong Clarke Willmott team to raise over £20,000, taking on a 100-mile challenge stretching from North Devon to the Clifton Suspension Bridge

They completed a gruelling three-day trek over the April 2019 bank holiday weekend, to raise over £20,000 for anti-slavery charity Unseen UK and muscular dystrophy charity Duchenne UK, which holds a particularly strong place in the hearts of many colleagues.

Martin Palmer, Director of our Business Development & Marketing team, organised SWAY100. He said: “It is fantastic that we have managed to smash our target of £20,000 which means an incredible £10,000 each for Duchenne UK, our new office charity and Unseen UK our outgoing office charity.

“The weather was mostly kind to us and we took in some incredible views of Bristol, Bath, Somerset and Devon.

“The team have come back with many aches, pains and injuries but it was so worth it for the funds and awareness raised.

“Any pain experienced over the 100 miles was nothing compared to the challenges faced by victims of slavery or in deed the Smedley family and those facing a Duchenne diagnosis.”

DMD occurs in childhood and almost always affects boys who tend to be diagnosed before the age of five. There are around 2,500 patients in the UK and an estimated 300,000 sufferers worldwide. Duchenne UK relies solely on charitable donations for their work in finding new treatments and a cure.

Unseen UK works to support the victims of slavery, trafficking and exploitation and effect change across local authorities, government, businesses and law enforcement.