The Modern Slavery Act 2015: UK government's response to the compliance consultation

The Modern Slavery Act 2015: UK government's response to the compliance consultation

Handcuffs demonstrating slavery and the lawThe 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.

Compliance obligations

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 organisation’s structure, its business and its supply chains;
  • The organisation’s policies in relation to slavery and human trafficking;
  • The organisation’s due diligence processes in relation to slavery and human trafficking in its business and supply chains;
  • The part of the organisation’s business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps the organisation has taken to assess and manage that risk;
  • The organisation’s effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as the organisation considers appropriate; and,
  • The training about slavery and human trafficking available to the organisation&r

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About the author:

Jonathan is an experienced lawyer with a concentration on technology and compliance. His practice includes advising multinational companies on matters involving risk, compliance and technology across Europe. He has handled legal matters in more than 60 countries involving emerging technology, corporate governance, ethics code implementation, reputation, internal investigations, marketing, branding and global privacy policies. Jonathan has counselled a range of clients on breach prevention, mitigation and response. He has also been particularly active in advising multi-national corporations on their response to the UK Bribery Act 2010 and its inter-relationship with the U.S. Foreign Corrupt Practices Act (FCPA).

Jonathan is one of three co-authors of the LexisNexis definitive work on technology law, “Managing Risk: Technology & Communications”. He is a frequent broadcaster for the BBC and other channels and appeared on BBC News 24 as the studio guest on the Walport Review.

In addition to being a lawyer, Jonathan is a Fellow of The Chartered Institute of Marketing. He has spoken at conferences in the U.S., Canada, China, Brazil, Singapore, Vietnam, the Middle East and across Europe. Jonathan qualified as a lawyer in the UK in 1991 and has focused on technology, risk and governance matters for more than 20 years. In April 2017 Thomson Reuters listed Jonathan as the 6th most influential figure in risk, compliance and fintech in the UK. Jonathan was ranked as the 14th most influential figure in data security worldwide by Onalytica in their 2016 Data Security Top 100 Influencers and Brands Survey.

Jonathan is a Solicitor of the Senior Courts of England & Wales. In addition Jonathan is admitted as a Solicitor (non-practising) in Ireland.