Personnel Today
  • Home
    • All PT content
    • Advertise
  • Email sign-up
  • Topics
    • HR Practice
    • Employee relations
    • Equality, diversity and inclusion
    • Learning & training
    • Pay & benefits
    • Wellbeing
    • Recruitment & retention
    • HR strategy
    • HR Tech
    • The HR profession
    • Global
    • All HR topics
  • Legal
    • Case law
    • Commentary
    • Flexible working
    • Legal timetable
    • Maternity & paternity
    • Shared parental leave
    • Redundancy
    • TUPE
    • Disciplinary and grievances
    • Employer’s guides
  • AWARDS
    • Personnel Today Awards
    • The RAD Awards
    • OHW Awards
  • Jobs
    • Find a job
    • Jobs by email
    • Careers advice
    • Post a job
  • XpertHR
    • Learn more
    • Products
    • Pricing
    • Free trial
    • Subscribe
    • XpertHR USA
  • Webinars
  • OHW+

Personnel Today

Register
Log in
Personnel Today
  • Home
    • All PT content
    • Advertise
  • Email sign-up
  • Topics
    • HR Practice
    • Employee relations
    • Equality, diversity and inclusion
    • Learning & training
    • Pay & benefits
    • Wellbeing
    • Recruitment & retention
    • HR strategy
    • HR Tech
    • The HR profession
    • Global
    • All HR topics
  • Legal
    • Case law
    • Commentary
    • Flexible working
    • Legal timetable
    • Maternity & paternity
    • Shared parental leave
    • Redundancy
    • TUPE
    • Disciplinary and grievances
    • Employer’s guides
  • AWARDS
    • Personnel Today Awards
    • The RAD Awards
    • OHW Awards
  • Jobs
    • Find a job
    • Jobs by email
    • Careers advice
    • Post a job
  • XpertHR
    • Learn more
    • Products
    • Pricing
    • Free trial
    • Subscribe
    • XpertHR USA
  • Webinars
  • OHW+

Modern slavery

Writing a modern slavery statement: a guide for employers

by Stephen Simpson 21 Feb 2017
by Stephen Simpson 21 Feb 2017

Large employers are expected to publish their annual modern slavery statement within six months of the end of the financial year, meaning that organisations with a financial year of 1 April to 31 March should publish their statement no later than the end of September each year. 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.

  • Example modern slavery statement: introduction

 

2. Explain your organisational structure and supply chains

Modern slavery statements

Which employers are required to publish a modern slavery statement?

What duties do employers have under the Modern Slavery Act?

What is the timescale for employers to prepare a modern slavery statement?

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.

  • Example modern slavery statement: organisational structure and supply chains

 

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.

  • Example modern slavery statement: responsibility

 

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.

  • Example modern slavery statement: relevant policies

 

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.

  • Example modern slavery statement: due diligence

 

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.

  • Example modern slavery statement: performance indicators

 

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.

  • Example modern slavery statement: training

 

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.

  • Model slavery statement: awareness-raising programme

 

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.

 

Avatar
Stephen Simpson

Stephen Simpson is a principal employment law editor at XpertHR. His areas of responsibility include the policies and documents and law reports. After obtaining a law degree and training to be a solicitor, he moved into publishing, initially with Butterworths. He joined XpertHR in its early days in 2001.

previous post
Breaking down barriers to build a diverse workforce
next post
Government failing to act on gender pay gap recommendations

Leave a Comment Cancel Reply

Save my name, email, and website in this browser for the next time I comment.

You may also like

Trust seeks better language and employability support for...

13 Jun 2022

Modern slavery: 10% of companies fail to publish...

26 Apr 2022

H&M signs pledge to protect female workers in...

1 Apr 2022

Dyson faces supply chain labour abuse claim

11 Feb 2022

Seasonal workers left without running water and unfairly...

12 Jan 2022

MPs critical of government rejection of Uyghur proposals

10 Jun 2021

Workers’ rights watchdog to be launched

8 Jun 2021

Modern slavery statement registry launched

11 Mar 2021

MPs ask Boohoo for evidence of progress on...

5 Mar 2021

Employment law in limbo: Key proposals to resurrect...

4 Feb 2021
  • NSPCC revamps its learning strategy with child wellbeing at its heart PROMOTED | The NSPCC’s mission is to prevent abuse and neglect...Read more
  • Diversity versus inclusion: Why the difference matters PROMOTED | It’s possible for an environment to be diverse, but not inclusive...Read more
  • Five steps for organisations across the globe to become more skills-driven PROMOTED | The shift in the world of work has been felt across the globe...Read more
  • The future of workforce development PROMOTED | Northumbria University and partners share insight...Read more
  • Strathclyde Business School expands its Degree Apprenticeship offer in England PROMOTED | The University of Strathclyde is expanding its programmes...Read more
  • The Search for Talent: Six Major Employer Pitfalls PROMOTED | The Great Resignation continues unabated...Read more
  • Navigating the widening “Skills Confidence Gap” in 2022, and beyond PROMOTED | Cornerstone OnDemand conducted a global study...Read more
  • Apprenticeships are the solution to your recruitment problems PROMOTED | Apprenticeships have the pulling power...Read more

Personnel Today Jobs
 

Search Jobs

PERSONNEL TODAY

About us
Contact us
Browse all HR topics
Email newsletters
Content feeds
Cookies policy
Privacy policy
Terms and conditions

JOBS

Personnel Today Jobs
Post a job
Why advertise with us?

EVENTS & PRODUCTS

The Personnel Today Awards
The RAD Awards
Employee Benefits
Forum for Expatriate Management
OHW+
Whatmedia

ADVERTISING & PR

Advertising opportunities
Features list 2022

  • Facebook
  • Twitter
  • Instagram
  • Linkedin


© 2011 - 2022 DVV Media International Ltd

Personnel Today
  • Home
    • All PT content
    • Advertise
  • Email sign-up
  • Topics
    • HR Practice
    • Employee relations
    • Equality, diversity and inclusion
    • Learning & training
    • Pay & benefits
    • Wellbeing
    • Recruitment & retention
    • HR strategy
    • HR Tech
    • The HR profession
    • Global
    • All HR topics
  • Legal
    • Case law
    • Commentary
    • Flexible working
    • Legal timetable
    • Maternity & paternity
    • Shared parental leave
    • Redundancy
    • TUPE
    • Disciplinary and grievances
    • Employer’s guides
  • AWARDS
    • Personnel Today Awards
    • The RAD Awards
    • OHW Awards
  • Jobs
    • Find a job
    • Jobs by email
    • Careers advice
    • Post a job
  • XpertHR
    • Learn more
    • Products
    • Pricing
    • Free trial
    • Subscribe
    • XpertHR USA
  • Webinars
  • OHW+