Modern slavery: updated supply chain guidance
The Home Office has updated its practical guide to transparency in supply chains. The guide aims to help commercial organisations (a company or a partnership carrying on business in the UK for the supply of goods or services) required to produce a slavery and human trafficking statement (a statement) under section 54 of the Modern Slavery Act 2015.
An organisation's statement must set out the steps it has taken in its previous financial year to ensure that slavery and human trafficking is not taking place in its business and supply chains.
The key changes to the guide include:
- Smaller organisations whose turnover falls below £36 million are encouraged to publish a statement “voluntarily”. This supplements the pre-existing recommendation that organisations whose turnover dips below £36 million continue to publish a statement, even though not legally required to do so.
- The suggested content of a statement is more strictly prescribed. Previously the guide contained six illustrative examples of the kinds of information an organisation could include in a statement. Now the guide clarifies that the government expects organisations to cover all six of these items, as well as all other steps the organisation has taken in the relevant financial year.
- The guide now includes an extensive definition of "child labour" and notes that an organisation’s slavery and human trafficking due diligence should form part of its wider human rights due diligence process, where possible.
- The statement should be signed by a director who sits on the organisation's board and dated with the date of the board approval. (For a limited liability partnership, the statement needs to be approved by its members and signed by a designated member.)
- Organisations should keep their historic statements from previous financial years on their website so that the public can compare statements and monitor progress.
- The guide notes that investors, the media and the public will expect to see “year-on-year” improvements in how commercial organisations are tackling slavery and human trafficking.
The Financial Times has noted that company statements are "lacklustre" and there have been calls for harsher requirements for those who were not compliant.
- Review your Modern Slavery Act statement and amend if necessary to comply with the revised guidance.
- Ensure that historic statements are kept on the website. Your reputation and brand may suffer if you are seen not to be in compliance with the Modern Slavery Act.