Modern slavery statements: September deadline looms

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The end of September is a key cut-off point for large employers required to publish their first modern slavery statement.

The Modern Slavery Act 2015 requires commercial organisations with an annual turnover of at least £36 million to publish a modern slavery statement for each financial year ending on or after 31 March 2016.

The Act states that the employer’s slavery and human trafficking statement might include information on:

  • its structure, business and supply chains;
  • its policies in relation to slavery and human trafficking;
  • its 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 that it has taken to assess and manage that risk;
  • its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate; and
  • the training about slavery and human trafficking available to its staff.

There is no strict timetable within the legislation for relevant organisations to publish their modern slavery statement.

Government’s guidance on timing of publication

“We expect organisations to publish their statements as soon as reasonably practicable after the end of each financial year in which they are producing the statement.

Organisations may well choose to publish the statement alongside any other annual or non-financial reports they are required to produce. In practice, we would encourage organisations to report within six months of the organisation’s financial year end.”

The Government’s guidance on complying with modern slavery laws simply says that it “expects organisations to publish their statements as soon as reasonably practicable after the end of each financial year”.

However, the guidance goes on to “encourage” publication within six months of the end of the financial year.

For organisations with a financial year running from April to March, this means that they are expected to publish their modern slavery statement by 30 September 2016.

Stephen Simpson, principal employment law editor at XpertHR, commented: “The Modern Slavery Act stops short of having strict deadlines on when statements have to be published, with the Government preferring a light-touch approach.

“However, organisations with an April to March financial year that have still not thought about their anti-slavery statement should use the end of September as an indicator that they should now be thinking seriously about what it should contain.”

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.

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