Modern Slavery: internal and supply chain labour practice
March 2016 Contact the author:
The issue The Modern Slavery Act 2015 applies to UK operated businesses with a £36m+ turnover. For financial years ending on 31 March 2016 and later, such businesses must publish an annual Board-approved statement of steps taken to ensure slavery and human trafficking do not exist in their business or their supply chains (inside or outside the UK).
Key terms
Carolyn Brown Partner, Head of Employment
“Slavery” is holding people in slavery or servitude or requiring them to perform forced or T: +44 (0)20 3755 5390 E: carolyn.brown@howardkennedy.com compulsory labour “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.
The consequences Businesses must set out the steps taken in this respect in that financial year, or specify that no such steps have been taken. Government guidance states that these Board statements may also 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 including how those are evaluated and managed Relevant key performance indicators to enable readers to assess the effectiveness of the business’ anti-slavery activities. While detailed statements are encouraged, legal compliance does not mandate them.
Guidance Businesses should now:
Assess their suppliers and supply chains for risk Introduce an anti-slavery policy, this policy should: identify high risk business and supply chain areas (e.g. types of suppliers heavily reliant on migrant labour) give guidance to the staff involved in procurement and supplier liaison on identifying ‘red flags’ provide a mechanism for reporting concerns which ensures speedy action train staff on this policy Review procurement arrangements and supplier contracts to ensure that they include appropriate business safeguards including requirements for information and use of compliant policy material as well as contract termination rights if compliance issues arise.
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