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PRECEDENTS
As an organisation we maintain clear policies and procedures aimed at preventing exploitation and human trafficking and protecting our workforce and reputation. These are available [insert details, eg on our intranet]. This awareness tool identifies typical warning signs that indicate someone might be a victim of slavery or human trafficking. If you suspect someone is being controlled or forced by someone else to work or provide services, please report it. This could be a colleague, someone in our supply chain or someone unrelated to our [firm OR organisation]. If a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated, then please report it. There is no typical victim and some victims do not understand they have been exploited and are entitled to help
CHECKLISTS
STOP PRESS: On 24 March 2025, the government published a fully revised and updated verson of its statutory guidance on the transparency in supply chains provisions in section 54 of the Modern Slavery Act 2015. This document is being reviewed in the light of the new guidance. Section 54 of the Modern Slavery Act 2015 (MSA 2015) requires a commercial organisation with an annual turnover exceeding £36m operating in the UK to produce an annual transparency statement setting out the steps taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains or any part of its business. This could include information about its structure, policies, due diligence, assessment and management of risk, training and effectiveness in ensuring its supply chain is free from modern slavery and human trafficking. Our Flowchart: Does section 54 of the Modern Slavery Act 2015 apply to my business? can help you determine whether MSA 2015, s 54 applies to your business. This Checklist is designed to help you consider what policies,
PRACTICE NOTES
This Practice Note is intended for commercial organisations within the UK. It should be read in conjunction with Practice Note: How to manage modern slavery and human trafficking risk. Why you need to manage this risk Modern slavery results in enormous suffering. All businesses are encouraged to take action to ensure they are not complicit in modern slavery, whether knowingly or unwittingly. As well as being ethically and morally important, MSA 2015, s 54 requires large commercial organisations (with a total turnover of £36m or more) to produce and publish an annual modern slavery and human trafficking statement. Failure to comply with MSA 2015 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. Failure to publish a statement may also damage the reputation of the business and cause problems for commercial tenders. Proposed
PRECEDENTS
1 Definitions Modern Slavery Policy • means the Employer's anti-slavery and human trafficking policy as set out in Schedule [insert] as updated by the Employer and notified to the Contractor from time to time; 2 Modern slavery 2.1 The Contractor undertakes, warrants and represents that: 2.1.1 neither the Contractor nor any of its officers, employees, agents or sub-contractors: (a) has committed an offence under the Modern Slavery Act 2015 (an MSA Offence); or (b) has been notified that it is subject to an investigation relating to an alleged MSA Offence or prosecution under the Modern Slavery Act 2015; or (c) is aware of any circumstances within its supply chain that could give rise to an investigation relating to an alleged MSA Offence or prosecution under the Modern Slavery Act 2015; 2.1.2 it shall comply with the Modern Slavery Act 2015 and the Modern Slavery Policy; 2.1.3 [its responses to the Employer's modern slavery and human trafficking due diligence questionnaire are complete and accurate; and] 2.1.4 it shall notify the Employer immediately in writing if it becomes aware or has reason to believe that it, or any of its officers, employees, agents or sub-contractors have
PRECEDENTS
1 Modern slavery 1.1 For the purposes of this clause 1: 1.1.1 Modern Slavery Policy • means the Customer’s anti-slavery and human trafficking policy as set out in Schedule [insert] as updated by the Customer and notified to the Supplier from time to time; 1.1.2 MSA Offence • means an offence under the Modern Slavery Act 2015; 1.1.3 Supplier Associated Person • means all or any of the Supplier’s officers, employees, agents, subcontractors, and subsidiaries. 1.2 The Supplier shall comply with the Modern Slavery Act 2015 and ensure that all Supplier Associated Persons so comply. 1.3 The Supplier warrants and represents that it has not, and[ to the best of its knowledge, information and belief,] no Supplier Associated Person has: 1.3.1 committed an MSA Offence; 1.3.2 been notified that it, or any Supplier Associated Person, is subject to an investigation relating to an alleged MSA Offence or prosecution under the Modern Slavery Act 2015[; OR ; or] 1.3.3 become aware of any circumstances within its supply chain that could give rise to an investigation relating to an alleged MSA Offence or prosecution under the Modern Slavery Act 2015[; or OR .] 1.3.4 [provided any incomplete or inaccurate responses to the Customer’s modern slavery
PRACTICE NOTES
Section 54(5) of the Modern Slavery Act (MSA 2015) identifies six categories of information that may be included in an organisation’s slavery and human trafficking transparency in supply chains (TISC) statement. One of these categories is information on the organisation’s effectiveness in ensuring slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate. Statutory guidance on the TISC provisions in MSA 2015, s 54 indicates two main ways in which key performance indicators (KPIs) are relevant: • your TISC statement could include evidence to show you have considered whether your business-related KPIs might cause, contribute or result in modern slavery in your operations and supply chains • you can set outcome focused KPIs to measure your progress towards achieving your business goals in relation to identifying, preventing, mitigating and responding more effectively to modern slavery risks year on year This Practice Note focuses on KPIs used to measure the progress and effectiveness of an organisation’s anti-slavery actions, with illustrative examples of
PRECEDENTS
1 Initial KPIs Objective Action step Indicator Increase understanding of modern slavery risk within our supply chain. Identify suitable training workshops for suppliers with all [Tier 1 and 2] suppliers required by [date] to either:—certify they have attended a training session, or—provide evidence of equivalent alternative training attendedUndertake feedback sessions with workers as part of in-person supplier audits. The % of Tier 1 and 2 suppliers who have been trained/audited/assessed.The % of suppliers who have a modern slavery policy.Number of feedback sessions held with workers to hear their feedback and concerns. Ensure high-risk suppliers have robust plans in place to respond to an identified incident of modern slavery or human trafficking. Together with [insert, eg name of local NGO] develop a response plan and model scenario/testing exercise with all high-risk suppliers required to have undertaken the testing exercise by [date]. Number of response plan scenario modelling/testing exercises delivered. Ensure all new suppliers are aware of, and satisfy, [insert organisation name]’s minimum labour standards. Develop a code of conduct on labour practices by [date].Notify all new suppliers of organisational code of conduct on labour practices and
PRECEDENTS
Agriculture Objective Action step Indicator Ensure the organisation only sources its UK contract farm labour from reputable agencies. Undertake review of all agency relationships in the UK by [insert date] to ensure that those supplying labour hold a current gangmaster’s licence. [100]% of labour suppliers hold a current gangmaster’s licence. Ensure all farms in our supply chain meet minimum labour standards and all labourers have a right to work in the UK. Undertake spot checks of [x number or %] of supplier farms in the UK by [insert date] to confirm labour conditions are consistent with [insert relevant benchmark] and that all labourers have a right to work in the UK. Number of sites audited, the degree of access given (including to worker records in relation to rights to work), and the number and seriousness of breaches identified against [insert relevant benchmark]. Ensure our suppliers are openly
PRECEDENTS
Supplier to complete and return to [insert details], together with supporting documentation, policies and procedures where referred to. General Company name [Insert] Vendor/Reference number [Insert] Your name [Insert] Your job title [Insert] Phone number [Insert] Email address [Insert] Site/location Geographical location of your main employment site(s) [Insert] Management structure description [Insert] Staff Total number [Insert] Gender split [Insert] Age range [Insert] Nationalities (including approximate %) [Insert] Languages spoken [Insert] Is accommodation
NEWS
Law360: A legal battle between rival developers of coronavirus (COVID-19) jabs over the technology underlying the vaccine could set the tone for future litigation, as intellectual property lawyers expect a pledge made by Moderna at the height of the pandemic to dominate proceedings.
NEWS
Law360, London: The Court of Appeal ruled on 1 August 2025 that remaining protections underpinning Moderna's mRNA vaccine technology are valid, dismissing Pfizer and BioNTech's application to set aside patent claims left untouched by the High Court.
NEWS
Law360: Moderna has successfully defended a key patent underpinning its coronavirus (COVID-19) vaccine, after rivals Pfizer and BioNTech attempted to convince the European Patent Office (EPO) that the IP protections should be nixed.