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Employers will soon be required to publish a modern slavery statement setting out how they protect against slavery in their supply chains. Jonathan Exten-Wright looks at how employers should respond to the new reporting requirement.
The Modern Slavery Act 2015 consolidates current offences relating to trafficking and slavery. It also criminalises aiding, abetting or procuring forced labour or human trafficking, or being an accessory to such offences.
Modern slavery resources
Visit our Modern slavery topic page for more details on reporting requirements and what should be included in the statements.
For UK nationals, the trafficking provisions have extraterritorial application - this means an offence is committed regardless of where in the world the arranging or facilitating of trafficking takes place.
And from October 2015, all businesses operating in the UK with a turnover of £36 million or more will need to make a slavery and human trafficking statement every financial year.
This must include "a statement of 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" or that they "have taken no such steps".
The turnover threshold is lower than previously expected, bringing more organisations within the scope of the reporting requirement.
This requirement is part of a continuing trend compelling businesses to address adverse human rights impacts of not only their own activities, but those of their entire value chain.
In this context, suppliers represent a particular challenge for companies. Adverse human rights impacts can occur at any level of a supply chain – from direct suppliers, all the way through multiple layers of sub-suppliers and sub-contractors, to those at the end of the chain that provide raw material inputs.
The requirements of the Modern Slavery Act mean that this is no longer about corporate social responsibility or brand protection; transparency through all those layers will now be a legal requirement.
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