The Modern Slavery Act 2015 and multinational organisations
Produced in partnership with Brett Hartley of Morgan Stanley
The Modern Slavery Act 2015 and multinational organisations

The following Risk & Compliance guidance note Produced in partnership with Brett Hartley of Morgan Stanley provides comprehensive and up to date legal information covering:

  • The Modern Slavery Act 2015 and multinational organisations
  • Key concepts and their application to multinationals
  • Who must publish a slavery and human trafficking statement?
  • Form and content of statements
  • Due diligence and risk assessment
  • Responding to risks of modern slavery
  • Responding to actual or suspected modern slavery
  • Measuring progress and Key Performance Indicators
  • Overlap with other initiatives
  • Possible changes to slavery and human trafficking statements

Section 54 of the Modern Slavery Act 2015 (MSA 2015) places obligations on 'commercial organisations' that:

  1. supply goods or services

  2. carry on business wholly or in part in the UK, and

  3. have a global turnover of £36m or more

MSA 2015, s 54 requires these organisations to publish an annual 'slavery and human trafficking statement' on their website, outlining the steps taken (if any) during each financial year to ensure slavery and human trafficking is not taking place in any part of their business or global supply chains (disclosure obligation). In the unlikely scenario that a qualifying organisation doesn't have a website, it must provide a copy of its statement within 30 days to anyone who makes a written request for one.

A slavery and human trafficking statement should be underpinned by actions that are defensible and proportionate to the assessed risks of modern slavery (ie slavery, servitude, forced and compulsory labour and human trafficking; see Practice Note: Slavery and human trafficking statement—What is slavery? for further information) faced by the disclosing organisation in the UK and abroad.

This Practice Note explains how MSA 2015 applies to multinational organisations and group companies and considers a number of key issues they may face in complying with the letter and spirit of the disclosure obligation, eg due diligence, risk assessment, and responding to the risk of