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The Modern Slavery Act came into force in October 2015 to consolidate the Government’s approach to human trafficking and slavery. The Act will take effect this financial year and provides law enforcement agencies with the tools and powers to fight modern slavery and trafficking with criminal penalties including life prison terms, confiscation of assets and enhanced protection to victims with identification and repatriation.
Importantly for business, the Act introduces a reporting duty on companies and a requirement to carry out due diligence of their own business and also of their supply chain to ensure that trafficking or slavery is not taking place.
The Act initially applies to companies who are either carrying on a business in the UK or which are incorporated in the UK with a turnover of over £36 million. Those companies will be required to publish an annual statement, setting out what steps they have taken during the financial year to ensure that slavery and trafficking is not taking place.
Companies will need to develop anti-slavery and human trafficking policies as well as developing processes for the investigation of suppliers, sub-contractors etc.
Whilst the reporting duty sits with the larger organisation, if your business supplies services or you are part of a supply chain to a company with a turnover of over £36m then you can expect to be asked to produce evidence of your anti-slavery/human trafficking policies. There will be an inevitable trickle-down effect to much smaller organisations who will need to have policies in place to demonstrate their commitment to anti-slavery and trafficking. Companies who are unable to provide such evidence, could expect to be required to or be removed from supply chains.