What does the Modern Slavery Act 2015 mean for my business?

Most business leaders would have seen the headlines when the Modern Slavery Act 2015 came into force and thought that as a good employer the Act isn’t relevant. However we are nearly a year on from the first prosecution under the Act, and the requirement to report under the Act is now upon us.
It is worth properly considering whether this legislation could impact your business.

In January 2016, Leeds Crown Court convicted Mohammed Rafiq, owner of Kozee Sleep, of conspiracy to traffic under the Modern Slavery Act 2015. KozeeSleep is a UK-based company and a supplier to UK retailers, yet the case showed us how unethical employers and working practices both at home and overseas can creep into our supply chain. It is this supply chain that is at the heart of the requirement to report.

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. Businesses with a year-end of 31 March 2016 will be the first businesses required to publish a statement for their 2015-16 financial year.

Each organisation must make a statement setting out the steps they took during the financial year to ensure that slavery and human trafficking was not occurring in their supply chains and in their own organisation. This means that organisations must be able to demonstrate they have taken reasonable steps to ensure their supply chain is slavery / trafficking free as opposed to guaranteeing this is the case. The statement should be approved by the Board and signed by a Director or Partner.

The purpose of the legislation is to use reporting requirements to drive more ethical business and create a level playing field for businesses by creating a shared obligation to be transparent. The statement must be published on an organisation’s website with a link in a prominent place on the homepage. In support of complying with the legislation, organisations should look at their policies and procedures and decide if any training is necessary.

One final thought: although the reporting requirement is only for organisations with a turnover of £35m, they will have to report on their supply chain which means smaller businesses need to be ready to answer questions and be ready for audits from their customers. The Modern Slavery Act really could end up affecting every business, however large or small.

Please contact us on [email protected] if you need any advice on this area.