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UK government recently issued its response to its consultation on anti-slavery supply-chain compliance, which can be found here.
Earlier this the year the UK introduced the Modern Slavery Act 2015 (“the Act”) to combat modern slavery and human trafficking. The Act includes transparency compliance requirements on businesses and their supply chains.
Essentially, businesses carrying out any part of their business in the UK above a certain turnover will have to publish an annual “slavery and human trafficking statement” that discloses the steps taken to ensure that the business and its
supply-chains are slavery-free; alternatively the business may provide a statement that no such steps have been undertaken.
The statement must be published on the businesses’ website with a link to the statement in a prominent place on the homepage – if there is no website a copy of the statement must be provided to anyone within 30 days of their making a written
request for it.
The statement must be meaningful and the Act sets out what the statement may include, as follows:
The government will issue statutory guidance on the content of the “slavery and human trafficking statement”.
Compliance enforcement for failing to comply would likely take the form of a High Court injunction requiring compliance – there are no financial or criminal enforcement sanctions, at least not for the moment.
The consultation concerned:
Whatever the pros and cons of the threshold figure it is now set and the next steps are for the figure to be legislatively incorporated into the Act so that it can apply from this October. Likewise, the statutory guidance is expected to be issued around
the same time which it is hoped will be sufficiently detailed and meaningful.
The government also recently issued an evaluation report of its modern slavery marketing campaign (“Slavery is closer than you think”) which was aimed at educating the public and victims about slavery in the UK and to encourage people to report
their concerns. The report felt that the campaign played a significant and positive role in contributing to the government’s objective of ending slavery in the UK. The report can be found here.
The following should be considered as business compliance priorities:
We are advising businesses on how they can best comply with this new compliance challenge so please also don’t hesitate to contact us if you need help. We also took part in the UK government’s consultation exercise on the compliance obligations
and made a short film at the time of the consultation which can be found here, and, we have previously written about this issue here and here.
Cordery is also jointly hosting a workshop with Mazars on 22 September 2015 to help determine how businesses can meet the Act’s compliance obligations and add value to their supply chains. More details on this can be found here.
Jonathan Armstrong & André Bywater are lawyers with Cordery in London where their focus is on compliance issues.
0330 161 1234