Issues of modern slavery and human trafficking are global issues and there is increasing awareness among business that they have a responsibility in combating them and other human rights abuses. Globally, an increasing number of countries have implemented modern slavery legislation requiring specific compliance.
Modern slavery compliance is intended to increase transparency on global business supply chains to ensure modern slavery abuses and human trafficking are not taking place in those supply chains. For businesses, this can mean exhaustive analysis of their business structure, the business structure of their suppliers and their own procurement practices.
The UK was one of the first countries to implement modern slavery compliance legislation. This was through the Section 54 of the Modern Slavery Act 2015, also known as a Transparency in Supply Chains provision. S.54 requires commercial entities with a turnover of £36 million or more to publish annual Statements on their actions to identify, prevent and mitigate modern slavery in their supply chains. The statement is to set out the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in their supply chains or any parts of their own business (s.54(4)).
There are only two mandatory requirements that entities need to fulfil when completing and publishing their modern slavery Statements. Firstly, the entities are required to publish their Statements on their website if they have one, and on an off chance that they do not have a website, they must make it available upon request (as per s.54(7) and (8)).
Secondly, Statements must be approved at the highest level of governance and signed by a senior member of the organisation (as per s.54(6)).
Section 54 also contains suggested topics as to the information that may be included in the Statements to set out the full picture of the organisations approach to ensuring that modern slavery and human trafficking are not present in its business and supply chains. As per s.54(5), these may be:
a) the organisation’s structure, its business and its supply chains;
b) its policies in relation to slavery and human trafficking;
c) its due diligence processes in relation to slavery and human trafficking in its business and supply chains;
d) the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk;
e) 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;
f) the training about slavery and human trafficking available to its staff.
The publication of modern slavery compliance statements is intended to be an exercise in self-assessment and an investigation into the entity’s business principles and supply chains. The first steps that need to be undertaken in order to successful draft a modern slavery statement, is mapping those supply chains and identifying high risk areas within. Southwell & Partners can advise on implementing human rights compliant policies, conducting due diligence and audits to ensure businesses comply with international regulations. Please contact us for further information on how we can assist your business.