Modern slavery is an umbrella term for all forms of slavery, servitude, forced or compulsory labour and human trafficking. The Modern Slavery Act 2015 (the Act) combats modern slavery in the UK and consolidates previous offences relating to trafficking and slavery.
Commercial organisations which meet certain criteria (eg an annual turnover of at least £36 million) must publish an annual statement setting out the steps they take to prevent modern slavery in their business and their supply chains. Smaller organisations can choose to make a voluntary statement to show the steps it takes to prevent modern slavery in their business and supply chains.
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What is modern slavery?
What is a modern slavery statement?
A modern slavery statement (MSS) details what steps a business has taken to ensure that its business and supply chains are slavery-free during a given financial year. Businesses should publish their MSS as soon as possible after their financial year ends and, in any event, within six months of the end of the financial year.
A business is required to publish an annual MSS if the business:
carries on a business, or part of a business, in the UK
supplies goods or services, and
has an annual turnover of at least £36 million (this includes the individual business' turnover and the turnover of any of its subsidiaries)
While smaller businesses (ie those with a turnover below £36 million) are not required to publish an annual statement, they can publish a voluntary MSS. Smaller businesses may, for example, be asked by those they are supplying goods or services to if they have a statement or policy setting out their approach to tackling modern slavery. This is particularly important if they are bidding for contracts with larger organisations that are above the annual turnover threshold of £36 million.
An example of a business that wishes to publish an MSS could be a charity engaged in collecting old clothing for recycling and may clarify to the public its position and commitment to good working practices.
Businesses are responsible for determining whether they need to comply with the Act and publish an MSS. If you are unsure if the Act applies to you, Ask a lawyer.
For more information, see the government’s guidance.
Information on supply chains
Under the Act, businesses are required to provide information on their supply chains. This seeks to address the role of a business in preventing modern slavery from occurring in their supply chains.
All businesses, regardless of the size, should be open and transparent about their policies and procedures regarding modern slavery and human trafficking and demonstrate their measures are consistent and proportionate, taking into account the organisation’s size, structure, location of activities and supply chains, and nature of business.
To evaluate their supply chains, businesses need to:
research and identify risks where they have operations or supply chain(s)
prioritise those risks
assess the level of importance
ensure that appropriate remedies are in place
For more information, read the government’s guidance.
How to evaluate the risks your business may face
Your organisation should consider the products and services that are used, including the people (ie suppliers) who provide them. To help you carry out effective risk assessments and appropriately review possible risks, you should also identify and set out relevant information from internal and external sources (such as existing company policies, eg whistleblowing policies or a staff code of conduct).
Particular risks to consider when assessing and managing risks include:
country risks – particularly for businesses with global supply chains in countries where protection against breaches of human rights are limited, especially with regards to the rights of foreign contract workers (eg to retain their ID and papers)
sector risks – there are different risks and levels of risk in different sectors (eg a recruitment business that recruits staff in the agriculture or manufacturing sectors operate in a high-risk environment, while a recruitment business that recruits office workers and administrative staff operates in a low-risk environment)
financial transaction risks – particularly for banks or financial institutions which may be involved in facilitating financing from or supporting cases of modern slavery in operations, supply chains or through money laundering
business partnership risks – different business partnerships and supplier relationships will carry different levels of risks (eg long-term business partnerships may involve less risk than new partnerships as organisations may have a greater understanding of each others’ operations and policies)
product or raw material risk - different risks and levels of risk are associated with certain products and raw materials, with some being more susceptible to slavery and human trafficking (eg cocoa and cotton)
What are the due diligence requirements?
Businesses must set out the due diligence processes employed in monitoring and reducing the risk of slavery and human trafficking occurring in their supply chains.
Your business’ due diligence procedures will depend on the relationships with your supply chains. Depending on the complexity of the relationship, you may find it helpful to investigate working conditions with support from independent experts.
Due diligence processes should be:
proportionate to the identified modern slavery risk, the severity of the risk and level of influence the business has
informed by any broader risk assessments that have been conducted
Information that should be considered as part of your due diligence includes:
actions to understand the operations of the business
details of the risk management processes
any impact assessments
action plans to address actual or potential instances of modern slavery and the priority of those
grievance mechanisms in place to address modern slavery within the business
actions within the organisation addressing human rights and zero tolerance of modern slavery
Due diligence guidance is available on the government website.
Do I need to provide training to my employees?
Businesses are not required to provide training on modern slavery to staff, but, in doing so, you are demonstrating that you are committed to tackling slavery and human trafficking in your business and supply chains.
Training can be targeted at different groups of staff, including leadership, or different businesses within a supply chain. The training can further be tailored to the different groups of staff and can range from detailed training courses to broader awareness-raising programmes.
In deciding what training (if any) is appropriate, businesses should consider and evaluate the business size, business type and perceived level of risks.
The Home Offices provides training materials and information that you can consider using.
How should I publish the statement?
Your MSS must be published on your business’ website with a link in a visible place on the website homepage, or a drop-down menu. This is done to maintain transparency with website visitors (eg consumers or clients).
The link to the MSS should be clearly marked - it is typically sufficient to link to a ‘Modern Slavery Act Transparency Statement’.
Where your business has more than one relevant website, you should link to or place a copy of the statement on each website.
If you do not have a website, then you must send a copy of the statement to anyone who requests one in writing. The copy must be provided within 30 days of receiving the request.
Does an MSS need to be approved?
Modern slavery statements require approval by the board of directors (or equivalent management body). If you are a company, the board of directors need to provide this approval. If you are an LLP or partnership, the partnership members need to provide approval.
The MSS must clearly state that it has been approved by the board of directors (for companies), the members (for LLPs) or partners (for general partnership). It must also include the date on which approval was given.
The MSS must also be signed off by either a director (for companies), a designated member (for LLPs) or a general partner (for general partnerships). If the organisation is any other kind of partnership, a partner must sign it.
While the MSS does not need to include a physical signature, it should still clearly state that it has been signed. The MSS should also include the signing party’s name and job title, and the date of signature.
Do I have to register my statement?
The government launched the modern slavery statement registry in 2021. While it is not currently mandatory for businesses to register their statements, they are strongly encouraged to submit their most recently published MSS to demonstrate the steps they have taken to prevent modern slavery. This can be done online.
In future, all organisations required to produce an MSS will need to submit their most recent statement to the modern slavery statement registry.
What is the requirement if I am an overseas business operating in the UK?
This will generally depend on the business itself. If the business has a demonstrable business presence in the UK and meets the required criteria, then an annual MSS will need to be published in accordance with the UK government guidelines.
Businesses may need to publish a statement if their UK presence:
is registered at UK Companies House
has offices in the UK
provides service or support functions in the UK
receives income in the UK
has other visible UK business presence, such as a website
There are a number of proposed changes and extensions of the existing requirements for modern slavery statements to encourage greater transparency. While these proposed changes have not yet come into force, they are expected to do so in the future, with the government providing more information in due course.
The proposed changes include, but are not limited to:
Mandatory reporting areas
Currently, an MSS may include detail on:
organisational structure and supply chains
policies on modern slavery and human trafficking
due diligence in relation to slavery and human trafficking
risk assessment and management
the actions that the organisation has taken to prevent slavery and human trafficking in its business or supply chains, measured against key performance indicators, if appropriate
staff training on slavery and human trafficking
Under the government’s reform, it would become mandatory to report on these areas. Businesses should therefore ensure that their MSS reflects the proposed changes.
Single reporting deadline
Under the proposed changes, businesses will have a single reporting deadline. All businesses would be reporting on the same 12-month period, between 1 April and 31 March, and would be publishing their statements by 30 September each year.
Currently, businesses can produce a group statement where more than one entity in the company group meets the reporting requirements, and it is not necessary for businesses to identify the different entities covered by the group statement.
Under the proposed changes, group statements will need to identify each entity covered by the statement. Businesses that form part of a larger group may need to carry out further analysis to ensure they identify all group entities required to make a statement.
- Make your Modern slavery statement
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- Answer a few questions. We'll take care of the rest