RW Writes: I would like to ensure that I am prepared for the publishing of the Modern Slavery Statements before the next tax year in April. What do I need to consider when writing a Modern Slavery Statement in terms of structure and content?
Legislation has recently introduced the requirement for all businesses with an annual turnover of £36 million or more to publish a slavery and human trafficking statement. This statement has to be published in an accessible place on the company’s website. If the company does not have a website, then anyone who makes a written request to see the statement should be provided with a copy within 30 days. A Modern Slavery Statement should be issued every financial year.
The statement must include the steps which the company has taken in that financial year to ensure slavery and human trafficking is not taking place within their company or any of its supply chains. Alternatively, if the company has not taken any steps to ensure slavery free relations, then for the purposes of complying with the legislation their statement should contact this fact. The statement is more than a policy; it requires an employer to take steps and then write about the steps in the statement itself.
An organisation’s slavery and human trafficking statement should be structured in a way to contain the following information on the organisation’s structure, including any supply chains they may have; any slavery and human trafficking policies implemented; the parts of the business and supply chains which the company has identified as being under the largest risk of slavery and human trafficking and also how the company will evaluate its effectiveness and success in ensuring that slavery and human trafficking is not taking place in its business or supply chains. The organisation is free to measure this success in any way it sees appropriate.
Additionally the statement has to contain details of any training on the topic of slavery and human trafficking available to the staff. This would include, for example, how often the training takes place and the extent of topics it covers.
The statement must be approved by the highest level in the company, for example, by a director if there is a board of directors; or by a partner or a member if it is a partnership. Affected employers whose financial year ends on or before 30th March 2016 do not have to produce a statement for that financial year.