Part of a supply chain? The Modern Slavery Act 2015 could impact you
If your company is part of a supply chain then you need to be aware of the Modern Slavery Act 2015 (MSA), in particular the obligations under section 54.
With a similarly wide ethical reach as the Bribery Act the MSA is designed to combat slavery and human trafficking. However, it is the obligation to produce an annual slavery and human trafficking statement which is the immediate concern for businesses.
Slavery and human trafficking statement
Section 54 requires that for every financial year ending on or after 31 March 2016 a company that carries out business (or part of a business) in the UK and has a global turnover (including that of subsidiaries) in excess of £36 million must publish on its website, in a prominent position, a slavery and human trafficking statement.
The content of the statement is not prescribed, but the MSA suggests what should be covered and the Home Office has released its guidance. To view this note click here.
Supply chain transparency
Although not required to guarantee that its entire supply chain is slavery free, a company must set out what action it has taken in relation to all parts of its supply chain to ensure they are free from slavery.
This is where it gets interesting. When renewing agreements with existing suppliers or entering into contracts with new providers, what checks, investigations and guarantees will a company accept or require?
Considering that 31 March 2016 has come and gone, if you are part of a supply chain and want to maintain your existing relationships or be attractive to new clients, it is be a good idea to implement the following:
- A policy setting out the company’s commitment to preventing slavery and human trafficking. This could be a short document but should state how the company combats slavery, must have buy-in from the company’s decision makers and needs to detail how the processes are communicated to staff.
- Regular staff training on the company’s internal anti-slavery and human trafficking processes. This should be compulsory for existing staff and any new starters.
- Update any staff handbook and other relevant policies to make reference to the new policy.
- The company’s own practices should be frequently reviewed and documented.
- Commercial agreements with clients should include clauses requiring compliance with the MSA.