Large employers with a financial year running from April to March should be gearing up to publish their second annual modern slavery statement by the end of September 2017.
Drafting your modern slavery statement
Commercial organisations with an annual turnover of at least £36 million are required to publish a modern slavery statement for each financial year.
The statement must set out the steps taken during the financial year to ensure that slavery and human trafficking is not taking place in supply chains, or in any part of a company’s own business.
There is no strict timetable within the Modern Slavery Act 2015 for relevant organisations to publish their modern slavery statement.
The Government’s guidance on complying with modern slavery laws states only that publication should be “as soon as reasonably practicable after the end of each financial year”.
However, the Government’s guidance encourages publication within six months of the end of the financial year.
This means that companies with a financial year running from April to March are expected to publish their latest modern slavery statement by 30 September 2017.
This will be the second annual modern slavery statement for many large employers, following their first statements in 2016.
However, new research from the Chartered Institute of Procurement & Supply (CIPS) suggests that many large organisations are lagging behind in meeting their obligations under the Modern Slavery Act.
According to the CIPS survey, one-third (34%) of organisations legally required to complete a modern slavery statement have failed to do so.
Where should modern slavery statements be published?
The statement must be published prominently on the company’s website, or be available within 30 days of a written request for it to be produced. The statement must be signed by a director.
The CIPS report highlights that a lack of impetus within organisations to produce a modern slavery statement has resulted in a large proportion of businesses having few or no policies in place to tackle the issue.
The CIPS says that only 45% of organisations have provided any training to their staff to help them spot modern slavery, while just 42% have mapped their supply chains to understand their risks.
Meanwhile, new research has suggested that even organisations that are tackling the problem of modern slavery within their overseas supply chains still have a “blind spot” for forced labour within their own UK workforces.
The report from the University of Sheffield and University of Bath, which focuses on the UK’s construction and food industries, blames UK organisations’ widespread use of outsourcing, subcontracting and informal hiring of temporary staff.
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The National Crime Agency has recently said that modern slavery and human trafficking in the UK is far more prevalent than previously thought, and that it is dealing with cases affecting “every large town and city in the country”.
