22rd October 2015


 Issue No.  2015/18



Human Trafficking and Modern Slavery

The Modern Slavery Act 2015 (“the Act”) comes into force this month bringing together legislation relating to trafficking and slavery. It is described as being amongst the toughest in the world. 

How Does it Affect Employers? 

If you have a turnover of £36m or more and carry on a business or part of a business in any part of the United Kingdom, the Act requires you to publish a Slavery and Human Trafficking Statement. 

This must set out the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains and in any part of its own business.  If no such steps have been taken the statement must say exactly that -  that the organisation has taken no such steps.

 “Slavery” is not defined within the Act but it does refer to the offences of “Slavery, servitude and forced or compulsory labour”.  “Human Trafficking” concerns the arrangement or facilitation of the travel of another person with a view to exploiting them.  

An organisation’s slavery and human trafficking statement may include information about:

  • the organisation's structure, its business and supply chains
  • policies relating to slavery and human trafficking
  • due diligence processes in relation to slavery and human trafficking in its business and supply chains
  • the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place and the steps taken to assess and manage that risk
  • the effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against performance indicators
  • training about slavery and human trafficking available to its staff

If the organisation is a body corporate (e.g. limited company / limited liability partnership / association / charity) the slavery and human trafficking statement must be approved by the board of directors or equivalent management (e.g. Partners / Trustees) and signed accordingly. If it is not a body corporate, the statement should be signed by a Partner or owner of the organisation.

If the organisation has a website, it must publish the slavery and human trafficking statement on that website, and include a link to the slavery and human trafficking statement in a prominent place on that website’s homepage.  If the organisation does not have a website, it must provide a copy of the slavery and human trafficking statement to anyone who makes a written request for one within 30 days.

What is the penalty for failing to comply?

There is no financial penalty for failing to publish a Statement. However, the Government can apply to the High Court for an injunction to force an organisation to comply. Given that such enforcement action would bring adverse publicity (e.g. potential reputational damage) this is a strong incentive for compliance.

What does this mean?

If you are an affected organisation:

  • Audit your business and supply chains.
  • Review existing policies and seek to address the issue of slavery and trafficking with your supply chains.
  • Ensure tender documentation and supplier ‘codes of conduct’ set out minimum working conditions that must be provided to its staff and those whose services it uses.
  • Implement whistle blowing mechanisms if staff have concerns over slavery and trafficking.
  • Train staff to ensure they understand the obligations and requirements of the Act.
  • Produce a Statement (as indicated above) and have it approved by the Board of Directors /  Members and put a link to it on the organisation’s website home page.





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