Slaving Away – New Reporting rules on supply chain labour practices The Issue
Employment E-alert October 2015
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The Modern Slavery Act 2015 requires large businesses operating in the UK (with a £36 million + turnover worldwide) to publish annually on their website a Board-approved statement of steps taken to ensure slavery and human trafficking do not exist in their business or supply chains (inside or outside the UK). For these purposes:
Carolyn Brown
“Slavery” is holding people in slavery or servitude or requiring them to perform forced or compulsory labour.
Partner, Head of Employment T: +44 (0)20 3755 5390 E: carolyn.brown@howardkennedy.com
“Human trafficking” means facilitating workers’ travel with a view to exploiting them. “Exploitation” covers sexual offences, removal of organs as well as working under threats, force or deception. There will be interim rules for large businesses whose financial year ends soon. Promised Government Guidance is still to come when an update will follow.
The Consequences It is likely these Board statements will need to specify: business and supply chain relationships relevant policies, including supplier due diligence and auditing processes training provided to those in supply chain management key risks related to slavery and human trafficking and how those are evaluated and managed key performance indicators enabling assessment of the effectiveness of the business’ anti-slavery activities.
Guidance Large businesses and those who supply to them should now:
Assess their suppliers and supply chains for risk Introduce an Anti-slavery policy, which should: identify high risk business and supply chain areas (e.g. types of supplier heavily reliant on migrant labour) guide procurement and supplier liaison staff on identifying ‘red flags’ provide mechanisms for reporting concerns which ensure prompt remedial action. Train staff on the operation of the Anti-slavery policy Review procurement arrangements and supplier contracts for inclusion of appropriate business safeguards such as: supplier information provision and monitoring use of anti-slavery compliant policies and practices contract termination rights when anti-slavery compliance issues arise.
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