From October 2015 any commercial organisation in any sector, which supplies goods or services, and carries on a business or part of a business in the UK, and has a global turnover above £36 million, must under Section 54 of the Modern Slavery Act (MSA) produce and publish a slavery and human trafficking statement for each financial year of the organisation, which sets out the steps they have taken to ensure there is no slavery or human trafficking in their business or supply chains.
The MSA, specifically states that the statement must include ‘the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business’. When the MSA refers to ensuring that slavery and human trafficking is not taking part in any part of its supply chain, this does not mean that the organisation in question must guarantee that the entire supply chain is slavery free. Instead, it means an organisation must set out the steps it has taken in relation to any part of the supply chain.
Whilst the MSA does not prescribe what content should form part of the slavery and human trafficking statement, the Home Office issued some guidance on the content, which shall include:
- The organisation's structure, its business and its supply chains.
- Its due diligence processes in relation to modern slavery and human trafficking.
- The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps taken to manage that risk.
- Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate.
- The training about slavery and human trafficking available to its staff.
The Government encourages all businesses to develop an appropriate and effective response to modern slavery. Businesses may choose to take further action over and above what is prescribed by the MSA but this will be a decision for individual businesses themselves.
Please note: Organisations that have taken no steps during the financial year to ensure that their business and supply chains are free of slavery and human trafficking must be transparent about what is happening within their business, and in order to comply with Section 54 of the MSA they must still publish a statement stating that no actions have been taken to prevent slavery and human trafficking. However, since the slavery and human trafficking statement is a public-facing document, a statement that an organisation has taken no steps to prevent slavery and human trafficking may damage the reputation of the business.
If a business fails to comply with Section 54 of the MSA by not producing and publishing a slavery and human trafficking statement for a particular financial year, or by not setting out the steps taken by the organisation in the relevant financial year, not only this may damage the reputation of the business, the Secretary of State may also seek an injunction through the High Court (or, in Scotland civil proceedings for specific performance of a statutory duty under section 45 of the Court of Session Act 1988) requiring the organisation to comply. If the organisation fails to comply with the injunction, they will be in contempt of a court order, which is punishable by an unlimited fine.
This fully comprehensive Anti-Slavery and Human Trafficking Policy is designed to assist organisations comply with the Modern Slavery Act 2015. This Policy not only contains a statement from senior management for the purposes of Section 54 of the MSA, it also gives workers, contractors and other business partners guidance on slavery and human trafficking and the measures taken by the organisation to tackle slavery and human trafficking in its business and its supply chains.
This Anti-Slavery and Human Trafficking Policy template is in Microsoft Word format, written in plain English, easy to use and edit.
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