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Modern Slavery: if your turnover is above £36m you need to read this.

The Prime Minister has announced that a section of the Modern Slavery Act that addresses the prevention of slavery & human trafficking in supply chains will come into force next month (October 2015).

The act states that businesses who have a turnover above £36 million must declare what steps they are taking to tackle modern slavery within their business and their supply chain (by publishing an annual statement).  Alternatively they must declare that no steps to confirm the existence of slavery or trafficking have been taken.  It seems unlikely that many businesses will choose option 2 given the reputational risks!

The statement must be published on the business’s website, be approved by the board of directors, and signed by a director.  The act also applies to LLPs and partnerships.

If your company is affected you could start thinking about:

  • Drafting your annual statement for publication
  • Assessing the information you have about your existing supply chain and consider whether you need more details
  • Draft and introduce a slavery & human trafficking policy
  • Incorporate anti-slavery and trafficking obligations into procurement and sub-contracting arrangements

Although there are no financial penalties for commercial organisations who do not publish a statement, the duties imposed are enforceable by the Secretary of State bringing civil proceedings in the High Court for an injunction.  Perhaps more of a concern for most will be the reputational risks in not being seen to have dealt with these issues seriously.

For assistance producing an annual statement or to discuss any of the issues in this area please contact Nic Elliott on 0115 9100 253 or send him an email.

Posted on September 3, 2015

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