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Modern Slavery Act 2015 made law today: What it means for companies and their supply chains

26/3/2015

 
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On Thursday March 26th, the Modern Slavery Bill received Royal Assent in parliament to become the Modern Slavery Act 2015. 

The Modern Slavery Act consolidates the current legislation relating to trafficking and slavery. 

It contains a specific supply chains clause requiring businesses over a yet to be determined size threshold to report annually on the action they have taken to ensure there is no modern slavery in their business or supply chain.

The government said it was fitting for the Bill to be passed on the United Nations day of remembrance for victims of slavery. 

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The Supply Chains requirement applies to:

  • Companies or partnerships that;
  • Sell goods or services and are;
  • UK based or;
  • Based outside of the UK, but have a part of their operations in the UK.

A
 slavery and human trafficking statement must be approved by the board of directors (or equivalent management body) and signed by a director (or equivalent) - as the government has said, “This will ensure that those at the top level take this issue seriously and understand the implications of taking little or no action.”

The government is currently consulting on the threshold for disclosure - only companies over a certain revenue threshold will need to report, and guidance for exactly what should go into an annual Modern Slavery statement. Likely requirements include:

  1. A brief description of an organisation's business model and supply chain relationships; 
  2. A business’ policies relating to modern slavery, including due diligence and auditing processes;  
  3. Training available and provided to those in supply chain management and the rest of the organisation;  
  4. The principal risks related to slavery and human trafficking including, how the organisation evaluates and manages those risks in their organisation and their supply chain; and 
  5. Relevant key performance indicators

To give time for the consultation to complete (it closes on May 7, 2015), the supply chains clause is not due to commence until October 2015.

To learn more about the Modern Slavery Act 2015, the consultation, and the requirements for companies, download our quick reference guide.

Please get in touch with any questions on how the act might affect your business, or sign-up to our newsletter above.


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