Modern Slavery Act - Have you been unintentionally caught?

With effect from March 2016, certain employers are required to prepare and publish an anti-slavery and human trafficking statement. We were advised by all the legal advisers we subscribe to that it was good news for smaller employers as they would completely escape this new piece of regulation (companies have to have turnover of £36 million or over to be affected). The advice we received was that those under this threshold could completely ignore the requirement to publish a statement.

Unfortunately, as some of our clients have found out, that is not actually the case. Some of our clients are in the supply chains of those larger organisations and are being asked to provide exactly the same information as those who have a turnover of £36 million or above. This is actually quite a big job for a small company, so we have produced some guidance to help with the bare bones of a statement. Further information is, as always, available from the friendly HR team here should you require assistance with producing this statement.

It is likely for most organisations that they will be required to provide such a statement in tendering processes. These reports are a data collection exercise for the large company in order for them to put together their own report. There are three key elements that you will need to produce information on to comply with such a request:

  1. Information about your organisation's own structure and that of your supply chain
  2. A description of the due diligence processes your business carries out on its supply chains
  3. Details of any part of the business or the supply chain where there might be a risk of human trafficking or modern slavery.

We can provide more detailed information for you as to what content should be included under each heading. Although there is some information available for free on the Internet, don’t be fooled into thinking that poaching someone else’s statement will be sufficient. You may find you have committed to something that is not realistic for a smaller organisation.

The three areas of biggest difficulty for smaller businesses are going to be:

  • The requirement to produce relevant policies, e.g. an anti-slavery policy or a recruitment policy or a whistleblowing policy. These are policies that many smaller businesses just don’t have. Again we can help with these if they are required.
  • The requirement to regularly train procurement and buying teams on what to look out for within the supply chain and action to take if they suspect modern slavery is taking place.
  • Key performance indicators to evidence that modern slavery is not taking place within the business or the supply chain.

We can organise and arrange some training for your key managers if you would find it helpful. Contact us on 0115 984 3119 for more information if you require any assistance.

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