The Modern Slavery Act 2015 s.54 requires certain commercial organisations to publish an Annual Slavery and Human Trafficking Statement.
The organisations this applies to are those:
- with a total annual turnover threshold of £36 million or more,
- which are carrying on business, or part of a business, in the UK
- which supply goods or services.
Turnover is determined on a global scale and it includes subsidiaries. Both UK and non-UK incorporated commercial organisations may be caught, as well as partnerships.
The Statement must…
- This published statement needs to detail the steps it has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains or any part of its business or a statement that it has taken no such steps.
- This statement must be approved by the Board or equivalent management body and signed by a Director or equivalent. The statement is to be published on their website with a link to the document in a prominent place on the homepage. If the organisation doesn’t have a website, it must provide a copy of the statement within 30 days of receiving a written request.
The exact content of the statement has not been dictated by the Act but the core elements may include:
- details of the training about modern slavery available to its staff
- their policies relating to human trafficking and modern slavery. This should include the due diligence and auditing processes implemented in its business and supply chains
- an outline of the organisation’s business, structure and supply chains
- the parts of its business and supply chains where there are risks related to slavery and human trafficking, including the steps taken to assess and manage those risks
- relevant performance indicators to gauge the organisation’s effectiveness in ensuring that modern slavery is not taking place in its business or supply chains.
If you fall within the definition of the Act we can help.
The Anti-Slavery and Human Trafficking Statement template on our Online HR Toolkit has been designed to help you in complying with the provisions. It sets out your commitment to combating modern slavery and that you expect the same from your contractors, suppliers and business partners. It gives your employees, contractors and other business partners’ guidance on modern slavery and the measures you’re taking to tackle it in your business and supply chains. It also sets out who will be responsible on a day-to-day basis for monitoring and implementing the policy, the systems in place to encourage early reporting of suspected modern slavery, training on the policy for staff, communication of the policy to suppliers and contractors and the sanctions for breach of the policy.
Need some advice?
If you would like to discuss your HR strategy and how you can comply with the Act, please give us a call to discuss. We have the expertise you need to help guide you through this requirement. We’re a friendly bunch and provide outsourced HR support and advice that has a really positive impact on your business. Let us make a difference by calling us on 01473 360160 or book a free hour HR consultation here >>
The template available on our Online HR Toolkit sits alongside over 1000 templates, policies and documents for almost any HR related situation. You simply access the Toolkit via a monthly subscription. To see how the HR Toolkit can fit in to your business, whether as your virtual HR manager or as a bolster to your current HR team, book a free demo. There is no obligation, it only takes 30 minutes and you speak to a person.
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