How to Prepare a Modern Slavery Statement

Wednesday 1 May 2019

In 2016 the International Labour Organization published statistics showing that at any given time, 24.9m people are in forced labour.

Modern Slavery

Current UK legislation requires transparency among businesses and organisations in respect of their policies concerning the prevention of modern slavery. Modern slavery encompasses:

• Slavery, servitude and forced/compulsory labour
• Human trafficking

What do businesses need to do to be compliant with UK legislation?

Under the Modern Slavery Act 2015 any business or organisation in the UK which is caught by the compliance criteria described below has a duty to prepare a Statement detailing the steps (or lack thereof) that the organisation has taken to ensure that slavery and/or human trafficking isn’t present in their supply chains and/or their own business.

A Statement must be prepared at the end of each financial year and signed off by a senior officer of the business or organisation. The Statement must be published on the homepage of the organisation’s website (if it has one) or some other prominent place.

The duty doesn’t require an organisation to take steps, nor are they required to ensure, that their supply chains are free from slavery. However, those organisations which fail to do so run the risk of damaging their reputations in the eyes of their customers.

Who has to comply?

An organisation will be required to produce and publish a Modern Slavery Statement if it:

• Is a commercial entity (i.e. a company or a partnership)
• Conducts business, or part of its business, in the UK
• Is a provider of goods and/or services
• Has a turnover of £36m or greater

If an organisation’s turnover falls below £36m after the duty has previously been triggered, guidance from the Government recommends that the organisation should, in the interest of transparency, still produce a Statement.

Producing a Statement

The Act doesn’t prescribe the form which a Statement needs to take, nor is there any content which is specifically required.

The only requirement is that organisations must detail all of the steps (or lack thereof) which they have taken, although the Home Office has published a practical guide to achieving transparency in supply chains which you can access here.

Our Five Top Tips

We recommend that organisations should consider the following when preparing a Statement:

1. Use plain, simple English to ensure that the Statement is easily accessible and understood
2. Keep the Statement concise
3. Cover only the relevant points
4. Where appropriate, provide links to publications, policies, or documents
5. Ensure the Statement is accurate and refer to steps which have been taken or have begun

For more information on Modern Slavery Statements please contact a member of our Employment Law team today.