Does the Modern Slavery Act affect you?


Is your group global turnover more than £36 million per annum?  If so, you need to display a slavery and human trafficking statement on your website.

The Modern Slavery Act 2015 requires organisations supplying goods or services in the UK, with a global group annual turnover of £36 million or more, to complete a slavery and human trafficking statement. Starting with the financial year ending on, or after, 31 March 2016, organisations must display this statement on their website for each financial year, or provide a prominent link to that statement.

If an organisation is caught by the Modern Slavery Act, its board is required to set out the steps the business 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.  This requirement does not mean that the organisation must guarantee that the entire supply chain is slavery free, but it should set out in the statement all the actions taken by the organisation and its suppliers to ensure its supply chain and its business is free from slavery.  There is no prescribed content for this statement, but the guidance recommends the statement should be:

  • written in simple language to ensure that it is easily accessible to everyone;
  • succinct but cover all the relevant points and link to relevant publications, documents or policies; and
  • in English, but may be provided in other languages that are relevant to the supply chain. It suggests that specifying the actions by specific country will help readers understand the context of the steps taken.

The statement must be approved by the board and signed by a director, and include either a statement:

  • of 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; or
  • that the organisation has taken no such steps.

For a confidential discussion about slavery and human trafficking, contact Natalie Bowman at Artington Legal in Surrey, on 020 3740 2360 or email natalie.bowman@artington.com.

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