Who does the modern slavery act apply to?

A commercial organisation that supplies goods and or services and has a turnover of £36 million or more.

What duty does the Act impose?

A commercial organisation must prepare a slavery and human tracking statement for each financial year.

What must the statement include?

A statement of steps taken during the financial year to ensure that slavery and human tracking is not taking place in any of its supply chains and in any part of its business. If no steps have been taken, then the organisation must make that statement.

Any other requirements?

The statement must be approved by the board.

Does the statement have to be published?

If the organisation has a website, the statement must be published there and there must be a link from the homepage.

What if the organisation does not have a website?

The organisation must provide a copy of the statement within 30 days to anyone who makes a written request.

What else may go into the statement?

Information about :

  • Business structure and supply chains.
  • Policies on slavery and human tracking.
  • It’s due diligence process in relation to slavery and human tracking.
  • Any parts of the business where there is a risk of slavery and human tracking.
  • Steps were taken to assess and manage the risk.
  • The performance of the business in ensuring that slavery and human tracking is not taking place in its business or supply chains as measured against KPIs.
  • The training about slavery and human tracking available to statutory duty.

What should the business be doing?

  • Await the guidance from HMG.
  • Consider which function owns the responsibility.
  • Draft a policy on the requirement.
  • Consider what KPIs to put in place.
  • Consider who to train in your organisation.
  • Assess current risks.

Can PJH Law help with training?

PJH Law is developing an e-learning package. Please contact enquiries@pjhlaw.co.uk for further details.