Large employers with a financial year running from 1 April to 31 March should already be thinking about their modern slavery statement for 2016/17. What do you have to consider when writing a modern slavery statement, how should it be structured and what can it contain?
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.”
Commercial organisations carrying out business in the UK with an annual turnover of at least £36 million are required to publish a modern slavery statement for each financial year.
We set out eight steps for HR professionals to follow when drafting their statement.
1. Reiterate your commitment to tackling modern slavery
Employers could introduce their modern slavery statement by:
- reiterating their commitment to understanding modern slavery risks; and
- ensuring that there is no modern slavery in their own business and supply chains.
The introduction to the modern slavery statement can also provide other key information, including a bit more detail about the organisation and the financial year to which the statement relates.
2. Explain your organisational structure and supply chains
Modern slavery statements
Employers can give some information on the business activities they carry out, and the nature of their supply chain.
Details can be given of the countries or regions in which the employer operates directly, and its operations there.
Employers can flag up particular activities or countries that are high risk in relation to modern slavery.
3. Set out who has responsibility for anti-slavery initiatives
This section can set out who has responsibility for the employer’s anti-slavery initiatives.
Initiatives could include the implementation of policies, risk assessments, investigations, due diligence and training.
4. Link off to relevant policies
Employers can provide further details of policies and procedures relevant to their identification of modern slavery risks and prevention of modern slavery.
There is no need for employers to reproduce the full text of their policies. It is sufficient to provide a link off to the policies, for example to the employer’s corporate website.
5. State what due diligence of suppliers is carried out
Who should approve the modern slavery statement?
The modern slavery statement must be approved at the highest level, for example by the board of directors, and signed by a director.
Employers that undertake supplier due diligence can set out what they do when considering taking on new suppliers, and how they review their existing suppliers.
For example, large organisations may map the supply chain to assess particular product or geographical risks of modern slavery.
Employers can take steps against suppliers that do not meet the required standard, for example asking them to take action to improve and terminating the business relationship if the required improvement is not forthcoming.
6. Provide an overview of key performance indicators
Employers may have reviewed their key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015.
For example, employers may have, or be the process of:
- requiring staff to complete training on modern slavery;
- developing a system for supply chain verification; and
- reviewing their existing supply chains.
This section can set out what KPIs have already been met, or when they are expected to be achieved.
7. Explain how you train staff on anti-slavery measures
Where should a modern slavery statement be published?
Employers must publish the modern slavery statement on their website and include a link to the statement in a prominent place on the homepage.
Employers may require some groups of staff to undertake training on modern slavery, for example those working in specific countries or directly with supply chains.
The statement can provide an overview of the training offered, which could be a training course on modern slavery, or form a section of the employer’s wider ethics training programme.
8. Flag up any awareness-raising programmes
As well as training of some staff, employers could raise awareness of modern slavery issues among the wider workforce.
This could be done by distributing flyers, putting up posters, or circulating emails on the subject.
Where is the law on modern slavery statements?
Section 54 of the Modern Slavery Act 2015 requires large employers to produce a modern slavery statement for each financial year. 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.
This article was originally published on 11 January 2016. It was updated on 21 February 2017.