Large employers with a January to December financial year are expected to publish their first slavery and human trafficking statements by the end of June.
Slavery and human trafficking statements
The Modern Slavery Act 2015 obliges commercial organisations with an annual turnover of at least £36 million to publish slavery and human trafficking statements for each financial year ending on or after 31 March 2016.
The statement might include information on companies’ supply chains; anti-slavery initiatives; what due diligence of suppliers is carried out; key performance indicators; and what training and awareness-raising programmes are taking place.
There is no strict timetable within the legislation for organisations to publish their slavery and human trafficking statement, but Government guidance on complying with anti-slavery rules states that it “expects organisations to publish their statements as soon as reasonably practicable after the end of each financial year”.
Government’s guidance on timing of publication
“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.”
It suggests that the Government expects publication within six months of the end of companies’ financial year.
For organisations with a financial year running from January to December, this means that they are expected to publish their first slavery and human trafficking statements by 30 June 2017.
Stephen Simpson, principal employment law editor at XpertHR, commented: “The Modern Slavery Act does not strictly require employers with a financial year matching the calendar year to publish their 2016 slavery and human trafficking statements by the end of June 2017.
“However, employers are strongly encouraged to do so. Many such organisations will already have published their statement for 2016, or at least will be well advanced with the preparation of the statement.
“If you are a senior HR professional in a large organisation that has not begun preparing its statement, you should now be asking some serious questions as to why this has not happened.”
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. It must be signed by a director.
Modern Slavery Act: what might the statement include?
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.