Anti-slavery and human trafficking policy

Certain larger commercial organisations are required to publish an annual slavery and human trafficking statement under the Modern Slavery Act 2015. As this may include information on the organisation’s policies relating to modern slavery, our policy is a useful one to put in place.

Annual statement

Under s.54 of the Modern Slavery Act 2015, relevant organisations are required to publish an annual slavery and human trafficking statement each financial year. The organisation needs to publish either a statement of the steps it has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains or any part of its business, or a statement that it has taken no such steps. The statement must be approved by the board or equivalent management body and signed by a director or equivalent. If the organisation has a website, it must publish the annual statement on that website and include a link in a prominent place on the home page. If the organisation doesn’t have a website, it must provide a copy of the statement within 30 days of receiving a written request. 

Application

The obligations apply to commercial organisations with a total annual turnover threshold of £36 million or more which are carrying on business, or part of a business, in the UK and which supply goods or services. Turnover is determined on a global scale and it includes subsidiaries. Both UK and non-UK incorporated commercial organisations may be caught, as well as partnerships. 

Content of statement

The government hasn’t been prescriptive with regard to the content of statements, but the core elements may include:

• an outline of the organisation’s business, structure and supply chains
• the organisation’s policies relating to modern slavery and human trafficking, including the due diligence and auditing processes implemented in its business and supply chains
• the parts of its business and supply chains where there are risks related to slavery and human trafficking, including the steps taken to assess and manage those risks
• details of the training about modern slavery available to its staff
• relevant performance indicators to gauge the organisation’s effectiveness in ensuring that modern slavery is not taking place in its business or supply chains.

Policy provision

If you’re an affected business, our Anti-Slavery and Human Trafficking Policy is designed to assist you generally in complying with the provisions as it gives your employees, contractors and other business partners guidance on modern slavery and the measures you’re taking to tackle it in your business and supply chains. It sets out your commitment to combating modern slavery, and that you expect the same from your contractors, suppliers and business partners. It also sets out who will be responsible on a day-to-day basis for monitoring and implementing the policy, the systems in place to encourage early reporting of suspected modern slavery, training on the policy for staff, communication of the policy to suppliers and contractors and the sanctions for breach of the policy. However, our policy isn’t the annual slavery and human trafficking statement, so you will need to produce that separately if you’re an affected business.