The Modern Slavery Act came into force in October 2015 and requires all commercial organisations with a minimum global turnover of £36million, that supply goods and services and conduct business in the UK, to publish a slavery and human trafficking statement each financial year. This statement must be approved by the board, signed by a director and published on the organisation’s website with a link from the homepage.
The information that should be within the statement includes:
- information about the organisation’s structure, its business and supply chains;
- its policies relating to modern slavery;
- its due diligence processes in relation to slavery and trafficking in its business and supply chains;
- the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps taken to assess and manage that risk;
- its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate; and
- the training about slavery and human trafficking available to its staff.
Where an organisation fails to produce a statement, the Secretary of State may seek to enforce the duty by applying to the High Court for an injunction. Failure by the organisation to comply with the injunction would amount to a contempt of court order and is punishable by way of an unlimited fine. It should also be noted that criminal liability could be attached to the director who signed off the statement.