- structure, business and supply chains;
- any business policies relating to slavery and human trafficking;
- any training in place for staff on modern slavery;
- any due diligence processes in place;
- any parts of the business or supply chains that are at risk of slavery and human trafficking, and
- any steps the business has taken to assess and manage this risk.
The first deadline for publishing a modern slavery statement has now passed; for businesses with a financial year ending on 31st March 2016 the government’s recommended six month deadline was the 30th September 2016. For those employers whose financial year has not yet ended, or have missed the recommended deadline, we recap on who needs to write a statement below. Who needs to write a modern slavery statement? For financial years ending on or after 31st March 2016, large organisations who carry out business in the UK with an annual turnover of at least £36 million are required to write and publish a modern slavery statement. When does this have to be published? The Government has produced guidance which recommends that employers publish the statement as soon as reasonably practicable after the end of their financial year. They even suggest publishing the statement alongside other annual reports such as accounts. In practice, they are encouraging organisations to publish the report within six months of the financial year end. This means that businesses with a financial year end of 31st December 2016 should publish a modern slavery statement by the 30th June 2017. What should it contain? The requirement to publish a modern slavery statement is brand new so drafting the first statement can seem onerous. The effect of the statement is to create transparency in businesses and their supply chains in order to reduce modern slavery taking place. As such, the statement should contain any steps the organisation has taken during the financial year to ensure modern slavery is not taking place in these areas. This means that where the business has taken no steps the statement must state this. The law gives examples of information that can be included in the statement, including information on: