Modern Slavery Act 2015
Tuesday, 13 October 2015

The UK’s Modern Slavery Act 2015 was enacted on the 26th March, 2015. Whilst it applies to individuals and corporate entities alike, Section 54 of it introduces an imminent obligation on companies...

The UK’s Modern Slavery Act 2015 was enacted on the 26th March, 2015. Whilst it applies to individuals and corporate entities alike, Section 54 of it introduces an imminent obligation on companies.

It is entitled ‘Transparency in supply chains’. Clause 1 of this Section sets out how this transparency should be demonstrated:

"A commercial organisation within subsection (2) must prepare a slavery and human trafficking statement for each financial year of the organisation."

Following a period of consultation, the UK legislators have identified five general areas of activity that should be included in a slavery and human trafficking statement. They are:

a) A brief description of an organisation's business model and supply chain relationships;

b) A business’s policies relating to modern slavery, including due diligence and auditing processes implemented;

c) Training available and provided to those in

  • 1) supply chain management and
  • 2) the rest of the organisation;

d) The principal risks related to slavery and human trafficking including, how the organisation evaluates and manages those risks in their organisation and their supply chain;

e) Relevant key performance indicators (Key performance indicators are measures that will assist the reader of a slavery and human trafficking statement to assess the effectiveness of the activities described in the statement. As the statements will be produced annually, performance indicators are likely to be useful in demonstrating progress from one year to the next. The choice of which measures to use will depend on the individual circumstances of the business).

All commercial organisations carrying on business in the UK with a total turnover of £36m or more will be required to complete a slavery and trafficking statement for each financial year of the organisation.

The Modern Slavery Act 2015 is bringing to the fore the need for companies to understand and take responsibility for behaviours taking place within their supply chains.

Here is a list that we at Stop Slavery Today have put together outlining 10 steps that companies should take to get a handle on modern slavery and human trafficking:

1. Consider how a response to the MSA will fit within existing strategic objectives within the company,  which may include adopting an approach to embed the UN Guiding Principles on Business and Human Rights

2. Develop or update existing  policies to address human rights issues, including slavery, forced and bonded labour, and human trafficking

3. Identify relevant KPIs to monitor performance and help to ensure continuous improvement, for example:

  • number of known incidents of slavery and human trafficking linked to the company either by its operations, business relationships or supply chain,
  • percentage and number of suppliers engaged on the issue of human trafficking and slavery
  • percentage and number of suppliers signed up to specific requirements included, for instance, in a code of conduct or contract
  • percentage and number of staff trained on the issue of human trafficking and slavery

4. Work with relevant personnel to map the supply chain and determine where suppliers operate

5. Identify the main areas of risk relating to slavery and human trafficking: which of those countries and sectors pose a higher risk?

6. Ensure that all employees are made aware of the policy, the business risks associated with the incidence of human trafficking and slavery in operations and the supply chain, and the heightened risk of human trafficking and slavery occurring when working through agents and other third parties

7. Develop or update any existing checklists, pre-qualification questionnaires, and purchasing policies to require the procurement or purchasing department to engage with suppliers on slavery and human trafficking issues, for example, ensuring certain labour standards and good practices are being met, particularly in regions where there is a heightened risk or legal systems lack enforcement

8. Develop or update supplier codes of conduct, tender requirements and supplier contracts to account for the issue of slavery and human trafficking, including, for example, requirements on meeting minimum labour standards in their supply chain

9. Develop or update due diligence procedures to incorporate the risk of slavery and human trafficking, to be engaged in any merger or acquisition or partnership or joint venture process

10. Make training on slavery and human trafficking available to staff

View our archive

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UK Anti-Slavery Day & Wales Anti-Slavery Conference 2016    27 October 16
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Modern Slavery Forum    15 February 16
How to Avoid Forced Labour in your Supply Chain    08 February 16
Tackling Modern Slavery in the Hotel Sector in Wales    26 January 16
Transparency in Supply Chains – A Practical Guide    17 November 15
Home Office Notification of Modern Slavery Cases    11 November 15
Independent Anti-Slavery Commissioner – Strategic Plan 2015-17    30 October 15
Steps Companies Should Take    13 October 15
Modern Slavery Act 2015    12 October 15
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Typology Of Forced Labour    03 October 15
The Requirement for Transparency in Supply Chains    01 October 15
The 2015 International Association of Women Police conference    04 September 15
Diverse Cymru - Radio Cardiff interview    27 August 15
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Wales Anti-Slavery Conference 2015    20 July 15
Welsh Assembly Government Anti-Slavery Conference    17 June 15
7 days and 7 faces of Modern Slavery and Human Trafficking    12 June 15
Tackling Hidden Labour Exploitation - Stronger Together Exeter Event    28 April 15
Human Trafficking Event    22 April 15
The Modern Slavery Bill is now law    22 April 15