Help notes: ANTI-MODERN SLAVERY
Can your organisation demonstrate how it meets UK regulatory requirements around Modern Slavery?
This question is about organisations ensuring that slavery and human trafficking is not taking place in their business or supply chains. Many larger organisations are obliged by law to take measures around combatting modern slavery, including by publishing an annual statement.
Modern slavery refers to slavery, servitude and forced or compulsory labour, and can include debt bondage, human trafficking and forced or early marriage. Over 12,000 people were referred to the UK authorities in 2021 as victims of modern slavery, but the real number of people is estimated to be more than 130,000 people and is estimated to cost the UK £33 billion per year. (www.antislavery.org)
What is a ‘Yes’ for me?
Answering ‘yes’ to this question means that you have followed the regulatory requirements (see below). These include publishing an annual statement approved at board level, updating it and publishing it on your UK website.
NB Smaller organisations can consider modern slavery as part of their wider Supply Chains checks and engagement (see Supply Chains question)
Does this question apply to me? Is this a regulatory requirement?
This question is for larger organisations which have to meet the regulatory requirements on Modern Slavery, under section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015. These are large organisations, broadly any UK ‘body corporate’ or partnership supplying goods or services with annual turnover above £36 million.
Government advice: Publish an annual modern slavery statement – GOV.UK
A commercial organisation is required to publish an annual statement if it:
- supplies goods or services
- has an annual turnover of £36 million or more
- is a ‘body corporate’ or a partnership, wherever incorporated or formed, and
- carries on a business, or part of a business, in the UK
This can include charities and public sector organisations as well as private companies.
Organisations are responsible for determining whether the legislation applies to them. You may wish to seek legal advice to decide if your organisation needs to produce an annual statement.
Modern slavery itself is covered under the Modern Slavery Act 2015, which includes offences around Slavery, Servitude and Forced or Compulsory Labour, and Human Trafficking (arranging or facilitating the travel of another person with a view to them being exploited).
Regulatory requirements and Modern Slavery statements
For those who need to comply, the regulatory requirements include:
- Publishing an annual statement setting out the steps they take to prevent modern slavery in their business and their supply chains
- Publishing the statement on their UK website
- Updating the statement every year
- Having statement approved by board of directors and signed off by a Director
It is also recommended to add the statement to a government registry.
Organisations are not expected to guarantee that all their supply chains are ‘slavery free’. However, statements must describe the steps the organisation has taken during the financial year to deal with modern slavery risks in your supply chains and your own business.
If your organisation has taken no steps to deal with modern slavery risks, you must still publish a statement setting this out.
The Modern Slavery Act recommends that you cover the following 6 areas in your statement:
- Policies in relation to slavery and human trafficking
- Organisation structure and supply chains
- Due diligence processes
- Risk assessment and management
- Key performance indicators to measure effectiveness of steps being taken
- Training on modern slavery and trafficking
For examples of other organisations’ modern slavery statements, see the government registry. Search the registry> Use search filters> select a relevant sector
See government guidance for more details on publishing a modern slavery statement.
More information about Modern Slavery