Modern Slavery: Where should businesses be now?
With the introduction of the Modern Slavery Act 2015 requiring large commercial organisations to prepare a slavery and human trafficking statement for financial years ending on or after 31 March 2016, what is your business doing to show that it is tackling the problem of human trafficking and slavery?
How are SME’s affected?
The requirement to provide the slavery and human trafficking statement applies to commercial organisations with a total turnover of £36 million or more. However, SME’s are becoming increasingly required to show what steps they are also taking, either because they form part of a bigger company’s supply chain, because they are growing and will meet the £36 million turnover threshold at some point, or because consumers are becoming increasingly aware of the issue and want to see an ethical approach.
The requirements of the modern slavery statement are not prescriptive in what steps a business should take to ensure that their business or supply chain are slavery free, only that a statement must be published.
Below shows examples of steps businesses may take.
Consider your supplier agreements
Section 54 of the Modern Slavery Act 2015 requires qualifying businesses to show the efforts they are making to ensure human trafficking is not taking place in their supply chains or a statement to say that no steps have been taken. Since the implementation of this legislation, some businesses have chosen to include new contractual requirements in supplier contracts asking them to confirm commitments to tackling this issue. Businesses should therefore be looking to have their agreements with third parties reviewed.
Identify the issue
The first step to show you are tackling this issue of human trafficking and slavery is to acknowledge that modern slavery is an issue and transparently show what steps your company is going to take to address the issue. Consider therefore what information you may wish to give on your website and what information is provided to staff.
Consider what values your business has
Consider whether your business’ values make it clear what your business’ attitude is to modern slavery. Are you clear what your business’ values are and are they embedded and reflected in your business culture?
Assess the steps taken
Consider how you will identify and monitor any risks. The requirement to produce a statement each year clearly shows that a monitoring process should be undertaken and changes made where required.
Furthermore, how will you show progress within your business and judge the effectiveness of your steps? It is important to be able to evaluate the steps you are taking against a set of criteria or goals.
Consider programmes and staff training
It is important that the issue of modern slavery is not addressed solely by management. Do you therefore have a programme in place to provide staff training? Are staff clear on how risks may be identified and what warning signs may be? Furthermore, do your staff know where to go to find information on this matter?
How we can help
Brachers are able to advise on issues connected with the Modern Slavery Act and provide guidance on modern slavery statements. For further information please speak to Sarah Wimsett or another member of the Employment team.