Section 54 of the Modern Slavery Act 2015 (likely to come into effect in October 2015) will require both corporate bodies and partnerships, with turnover of £36 million or more per annum and which carry on a business or part of a business in the UK, to publically state each year the actions taken to ensure their supply chain is slavery free.
The statement will include either (i) the steps the organisation has taken during the year to ensure the supply chain remains slavery free, or (ii) that it has taken no steps. If the organisation has a website, the statement must be published on that website. Otherwise if the organisation does not have a website, it will be required to provide a copy of the slavery and human trafficking statement to anyone who makes a written request for one within 30 days of receiving the request.
Although heavily debated, the turnover threshold of £36 million is taken from the threshold set out in the Companies Act 2006 for determining the size of a large company.
This is in addition to existing requirements for quoted companies to disclose in their strategic reports information necessary for the understanding of the development, performance and position of a company’s business. (As per Section 414 Companies Act 2006).
As part of their CSR reporting some organisations may already have opted to voluntarily disclose in accordance with the UN Guiding Principles Reporting Framework.
The Home Office has published its consultation responses and next steps on the above Act in the context of supply chains.
Beverley Flynn