- The structure and supply chains of the organisation;
- Its policies on modern slavery;
- the steps taken to assess and manage its potential exposure to modern slavery;
- its effectiveness in ensuring that modern slavery is not taking place, measured against indicators that it considers appropriate;
- any training provided to staff on modern slavery.
From October 2015, commercial organisations that carry on a business or part of a business in the UK will need to publish a ‘modern slavery statement’. This new obligation is included in the Modern Slavery Act 2015 and affects only those organisations with an annual global turnover of £36 million or more. Although slavery in the traditional sense has been outlawed in the UK in the 19th century, modern slavery may still continue in the form of forced labour or human trafficking, for example. The Act serves to consolidate previous offences in relation to trafficking and slavery, increasing the maximum prison sentence for offenders to life imprisonment. The Government sees that employers have a role in the battle against modern slavery, and has therefore placed a duty on the largest of employers to publically show what they are doing to ensure modern slavery does not play any part in their organisation. To this end, a modern slavery statement will have to be published on the organisation’s website, with a link to it in a prominent place on the home page. If the organisation does not have a website, the statement must be supplied to anyone who asks for it within 30 days of the request. The statement will need to set out the steps that the organisation has taken in that financial year to ensure that slavery is not taking place, both in its own organisation and in its supply chains (in the UK and abroad). Where no steps have been taken, that fact must be included in the statement. Although there is no legal requirement to take steps to ensure slavery is not taking place, being forced to publicise the fact that no steps have been taken may create a negative public attitude towards the company. Although the required content of the statement has not yet, at the time of writing, been finalised, it is possible that it may include: