Modern slavery, including slavery, servitude, forced labour, and human trafficking, is a severe violation of human rights. The Modern Slavery Act 2015 mandates certain businesses to produce annual statements detailing actions taken to prevent modern slavery. Transparency is essential to inform the public, consumers, employees, and investors about the measures in place.

The Modern Slavery Act 2015

Section 54 of the Act requires businesses with a turnover of £36 million or more to publish a slavery and human trafficking statement each financial year. The statement should detail the steps taken to ensure slavery and human trafficking are not present in supply chains or business operations. Non-compliance may lead to legal action and reputational damage.

Who is required to comply?

Any organisation with a turnover of £36 million or more, including subsidiaries, must comply. This includes franchises and parent companies. Smaller organisations are encouraged to produce statements voluntarily to demonstrate commitment and provide assurance to larger clients.

Writing a slavery and human trafficking statement

Statements should be clear, concise, and accessible. They must include the steps taken to address modern slavery, relevant policies, due diligence processes, risk assessments, effectiveness measures, and staff training. Providing links to detailed documents is recommended.

The structure of a statement

A comprehensive statement should cover the organisation’s structure, business and supply chains, policies, due diligence processes, risk areas, and effectiveness measures. Annex E provides detailed guidance on the type of information to include under each heading.

Approving a statement

Statements must be approved and signed by senior management, ensuring accountability and leadership. This requirement promotes a top-down approach to tackling modern slavery, fostering a culture of zero tolerance within the organisation.

Publishing a statement

Statements must be published on the organisation’s website in a prominent location, with historical statements kept available for transparency. Organisations should publish their statements within six months of the financial year-end and continue to do so even if their turnover falls below the threshold.

Responding to an incident of modern slavery

In case of identified or suspected modern slavery, organisations should tailor their response to local circumstances, potentially involving NGOs, industry bodies, or local authorities. Persistent issues with suppliers may require reconsideration of commercial relationships.