The UK government has launched a Modern Slavery Statement Registry in order for organisations to publish the positive steps taken to address the risk of modern slavery in their supply chains. Including the statement in the official Registry is currently voluntary, though “strongly encouraged”, but will become mandatory in due course. It is therefore essential that businesses that are caught by the regulations are prepared.
Under the UK Modern Slavery Act 2015, organisations must publish an annual Modern Slavery Statement on their website if they meet the following criteria:
• They are a ‘body corporate’ or a partnership, wherever incorporated or formed;
• They carry on a business, or part of a business, in the UK;
• They supply goods or services; and
• They have an annual turnover of £36 million or more (note that total turnover means the turnover of the organisation and any of its subsidiary undertakings, including those operating wholly outside the UK).
The statement must be reviewed and updated annually and signed off by the board of directors. A link must also be published on the organisation’s website. A group of companies can choose to issue one statement for the whole group.
The statement must cover:
1. Organisation structure and supply chains;
2. Policies in place relating to slavery and human trafficking;
3. Due diligence processes;
4. Risk assessment and management;
5. Key performance indicators to measure the effectiveness of action being take;
6. Training on modern slavery and trafficking;
Organisations do not have to guarantee that their supply chains are slavery free, but they do have to describe the steps taken during the previous financial year to deal with the risks of modern slavery in the business and supply chain. Where the organisation has not taken any steps to deal with modern slavery risks, a statement must still be published setting this out. This is of course not recommended though and businesses should be looking to address the risks of modern slavery.
Once the Modern Slavery Statement is signed off, companies are now also encouraged to publish the document in the UK’s registry. The hope is that the new registry will enhance transparency in relation to the topic of modern slavery and encourage organisations to ensure they are carefully considering it, and indeed tackling it, at all stages of their business. Leading by example, the UK government has even published their own statement on the registry.
If you would like further advice regarding the above, or support in drafting a suitable Modern Slavery Statement, please get in touch.
Madeleine Rhodes email: mrhodes@redfernlegal.com
