7 essentials of a Modern Slavery Statement

The Modern Slavery Act 2015 requires UK businesses to do their part to stop modern slavery.

The legislation applies primarily to large businesses (with an annual turnover of over £36 million) who must publish an annual statement detailing the steps they have taken to ensure that modern slavery and human trafficking are not present in their operations or supply chains. The House of Lords Modern Slavery Act 2015 Committee has suggested that the category of businesses obliged to produce a statement are widened.

Top tips for your Modern Slavery Statement

1. Organisational structure
   You must detail your operations and supply chains, describing how they function and where potential vulnerabilities might exist.
2. Staff handbook and internal policies
   The statement should highlight the internal policies you have put in place to prevent and address modern slavery and human trafficking, such as supplier codes of conduct, ethical trading policies, and whistleblowing mechanisms.
3. Training and education for all
   All employees must know what your policies and procedures are to address modern slavery and trafficking: As an employer, you will need to describe the training provided to staff.
4. Due diligence
   What processes do you have in place to vet suppliers and job applicants?
5. Risk assessment and management
   You will need to assess where risks of modern slavery are highest, both in your direct operations and supply chains.
6. Key performance indicators
   How will you measure your success and the effectiveness of the procedures you have put in place?
7. Transparency
   Your company’s Modern Slavery statement must be approved at the highest levels of the organisation (such as the board of directors) and made publicly available on your business’s website. The House of Lords Modern Slavery Act 2015 Committee has proposed the introduction of financial penalties for non-compliance with the requirement to publish a statement.

Currently the Secretary of State can enforce the duty to prepare a slavery and human trafficking statement in civil proceedings by way of an injunction. If the organisation fails to comply with the injunction, it will be in contempt of a court order and will be liable to an unlimited fine. Obviously, a failure to produce and publish a statement could lead to reputational damage. A good example of a brand impacted by modern slavery issues is the recent case of a branch of McDonald’s in Cambridgeshire, which was found to have employed 16 victims of modern slavery.