Section 54 of the Modern Slavery Act (MSA) requires certain businesses to publish an annual statement explaining what steps they are taking to ensure there is no modern slavery within their own business and their supply chains. During consultation on this measure, businesses repeatedly called for effective and practical guidance on what a modern slavery statement should look like. That long awaited guidance was published today. Below, we look through the typos and duplications contained in the guidance to report on the good bits and the bad, and consider what businesses should be doing now.

For background on the reporting requirement in the MSA, please see our blog posts of 22 July and 29 July, and listen to our podcast.
Continue Reading Government publishes guidance on the reporting obligation in the Modern Slavery Act

This morning the Prime Minister made an important announcement regarding the new reporting requirement in the Modern Slavery Act. David Cameron confirmed that businesses with a turnover of £36 million or more will be caught by the Act and will therefore be required to produce an annual slavery and human trafficking statement from October 2015.

The Modern Slavery Act was passed in March 2015. When section 54 of the Act comes into force, large businesses will be required to report annually on their efforts to ensure the business and its supply chains are free of slavery and human trafficking. Below, we consider what businesses need to do to comply.

The obligation

Section 54 of the Act requires businesses over a certain size to publish an annual slavery and human trafficking statement. The statement must confirm either:

  1. the steps the organisation has taken to ensure that slavery and human trafficking are not taking place in any of its supply chains or in any part of its own business; or
  2. that no such steps have been taken.

A link to the statement must be published in a prominent position on the business’ website homepage and the statement must be approved and signed by a director. So, although businesses could opt to take no action as a result of the Act and simply produce a statement under option (b), the Government hopes that public pressure and scrutiny from shareholders and the media, together with the risk of reputational damage, will encourage businesses to take real steps to investigate their supply chains and publish details of their efforts. Experience in California, with similar legislation, suggests businesses will not go for option (b).

Continue Reading The Modern Slavery Act: What You Need To Know