What is the Modern Slavery Act?

The Modern Slavery Act requires organisations supplying goods or services in the UK with a turnover of £36m or more to publish an annual Slavery and Human Trafficking Statement. The turnover threshold includes the turnover of any subsidiaries. 

Statements must set out the steps organisations have taken to ensure that slavery and human trafficking is not taking place in their business or in any of their supply chains. Whilst businesses will not face penalties for failing to take any steps, it is hoped that the public nature of their statements will make organisations match or exceed the standards of their competitors.

SMEs and the Modern Slavery Act – why does it affect smaller businesses?

Although the obligation to publish a Statement only applies to larger organisations, it will have a cascading effect down supply chains.

In order to substantiate the claims made in their Statements, large businesses will have to perform due diligence on their suppliers.  Increasingly, large organisations are including anti-slavery and human trafficking clauses in their contracts and will be unwilling to do business with SMEs that are non-compliant.

SMEs and the Modern Slavery Act – what should smaller businesses be doing?

This will depend on the nature and complexity of specific sectors and supply chains. Those in high risk sectors such as agriculture, telecommunications, hospitality and electronics and consumer goods manufacturing will have to undertake more auditing and monitoring.

Although SMEs will not have the same resources as larger organisations, they should carry out their own supply chain reviews and identify areas that are at most risk.

Practical measures are likely to include:

  • Development and communication of a relevant modern slavery policy
  • Staff training to increase the awareness of modern slavery, forced labour and human trafficking
  • Recruitment principles compliance to prevent labour exploitation
  • Linkage of anti-slavery and ethics auditing and monitoring to existing quality management systems
  • Development and use of anti-slavery clauses in supplier agreements
  • Implementation and monitoring of self-assessment ethical standards questionnaires for suppliers

If you require specific help in interpreting and meeting client requirements associated with the Modern Slavery Act, please contact me below or via email: kay@kayhealdhr.co.uk


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