Modern Slavery Statement Registry: what do you need to do?
On 11 March 2021 the UK Government launched the Modern Slavery Statement Registry ("the Registry").
The Registry, an online central bank of organisations' modern slavery statements operated by the Home Office, has been introduced in order to strengthen the reporting requirements under s.54 of the Modern Slavery Act 2015 ("the Act"). The purpose of the Registry is to provide consumers and investors with easier access to the statements so they are able to compare and analyse statements and with a wider view to promoting transparency.
Who is required to publish a statement?
A commercial organisation which is a body corporate or partnership, carries on a business in the UK, supplies goods or services and has an annual turnover of £36m+ is required to publish a modern slavery statement.
What do you need to do?
Over the past few weeks the Home Office has been sending letters directly to organisations which its records indicate are legally required to publish a modern slavery statement under the Act, encouraging, not insisting on, submission of their statements to the Registry. From a best practice approach, upon receipt of this letter companies should register on the Registry and upload their most recently published modern slavery statement. If your company receives this letter from the Home Office and is not required to publish a statement under the Act, the Home Office requests that you notify the Registry that you are exempt by opting-out.
Publishing on the Registry is currently voluntary, although the Government has announced that it intends to legislate to make this a mandatory reporting requirement. We anticipate however that many companies will opt to publish on the Registry from a transparency viewpoint and to demonstrate the active steps they are taking to identify and eradicate modern slavery risks in their businesses and supply chains.
If you require any further assistance or information please get in touch with your usual Trowers contact, or with Ayda Habboush and Amy Sandel in our Corporate Team.
The Government's announcement on the Registry can be accessed here.
Updated Government guidance on modern slavery statements can be accessed here.