Modern slavery risk management guide

The following Risk & Compliance practice note provides comprehensive and up to date legal information covering:

  • Modern slavery risk management guide
  • Why you need to manage this risk
  • Top five priorities
  • 1. Know your business
  • Know your business—mini action list
  • 2. Know your supply chain
  • Know your supply chain—mini action list
  • 3. Assess your modern slavery risk
  • Risk assessment—mini action list
  • 4. Work out a plan of action
  • More...

Modern slavery risk management guide

Why you need to manage this risk

The Modern Slavery Act 2015 (MSA 2015) has pushed issues of modern slavery and human trafficking up the corporate agenda. Section 54 requires large commercial organisations (with a total turnover of £36m or more) to produce and publish an annual slavery and human trafficking statement. The statement must set out the steps the organisation has taken to ensure there is no modern slavery in its own business and its supply chain.

Failure to comply could lead the Secretary of State to seek an injunction through the High Court (or, in Scotland, civil proceedings for specific performance) requiring the organisation to comply. If the organisation fails to comply with the injunction, it will be in contempt of court, which is punishable by an unlimited fine. More importantly, failure to publish a statement may also damage the reputation of the business and cause problems for commercial tenders. It will often be for consumers, investors and Non-Governmental Organisations to engage and/or apply pressure where they believe a business has not taken sufficient steps.

Even if your organisation is not required to publish a transparency statement under MSA 2015, s 54, your clients or customers may seek assurances from you in respect of modern slavery issues as part of their own supply chain due diligence.

Top five priorities

The table below identifies

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