Modern Slavery Act & compliance

Modern Slavery Act & compliance

Modern Slavery Act 2015: compliance checklist

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The transparency in supply chain provisions came into force on 29 October 2015.

We've compiled a checklist that summarises the steps we recommend that businesses take to comply.

New UK Modern Slavery legislation is amongst the toughest in the world.

The Modern Slavery Act 2015 introduces two main offences concerning holding a person in slavery, servitude or forced or compulsory labour and arranging or facilitating the travel of another person with a view to that person being exploited.

Provisions relating to transparency in supply chains are now in force. Government Guidance relating to compliance with these provisions has been published.

A large number of organisations will be caught by the legislation. Organisations must comply with the Act if they:

  • supply goods and/or services; and
  • have an annual turnover of £36m or more; and
  • carry on a business or part of a business in any part of the United Kingdom

The transparency in supply chain provisions require organisations to prepare and publish a slavery and human trafficking statement for each financial year. Transitional provisions are in force to give organisations time to comply.

Information to be contained in the statement includes details of:

  • the organisation's structure, its business and supply chains
  • policies relating to slavery and human trafficking
  • due diligence processes relating 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 taken to assess and manage that risk
  • the effectiveness in ensuring that slavery in human trafficking is not taking place in its business or supply chains, measured against key performance indicators
  • training about slavery and human trafficking available to its staff

Our team has provided clients with sensible and pragmatic advice on how the Act will affect their business, and has worked with them to devise realistic compliance plans to ensure they can prepare for the implementation of the provisions.

Our compliance team can help you with:

  • a written board briefing to your board/senior management
  • risk assessments
  • drafting/reviewing your due diligence and auditing policies
  • drafting/reviewing your whistleblowing/human rights/CSR policies
  • developing a slavery and human trafficking statement
  • drafting/reviewing standard terms and conditions supply chain and third party contracts
  • anti-slavery training
  • advising on dealing with potential breaches of the legislation

Work highlights

  • Providing training courses for clients to help train management and employees on anti-slavery compliance
  • Advising clients on timescales and responsibilities arising under the Act including what is required to demonstrate compliance
  • Advising clients on terms and conditions of supply chain agreements
  • Advising on warranties to be obtained on merger or acquisition
  • Working with a US law firm to develop guidance for international companies caught by the Act
  • Speaking at national conferences and working with legal publishers to provide sector specific webinars