The Modern Slavery Act 2015 is the first of its kind in Europe, and one of the first in the world, to specifically address slavery and trafficking in the 21st century.
The new legislation significantly enhances support and protection for victims, gives law enforcement the tools they need to target today’s slave drivers, ensures perpetrators can be severely punished, and includes a world leading provision to encourage business to take action to ensure their end-to-end supply chains are slavery free.
The Act includes a clause requiring companies operating in the UK to report annually on the steps they have taken to ensure that their international supply chains are slavery-free.
MODERN SLAVERY ACT AND SUPPLY CHAIN TRANSPARENCY
“Big Business will be forced to make public its efforts to stop the use of slave labor by its suppliers” From October 2015 the Transparency in Supply Chain Provisions require businesses to publish an annual statement if they have an annual turnover above the £36 Million threshold.
WHO IT AFFECTS AND WHAT YOU NEED TO DO
If you operate in the United Kingdom and have an Annual Turnover above £36 Million you will be required to publish a “slavery and human trafficking statement” setting out the steps you have taken to ensure slavery and human trafficking is not taking place in your supply chains or within your own business.
The statement must confirm the steps taken to ensure that slavery and human trafficking are not taking place in the business (or in any supply chain) or declare that no steps to confirm the existence of slavery or trafficking have been taken. It is expected that few businesses would take the latter option as it may place their ethical position into question and affect their reputation.
WRITING THE STATEMENT
The statement will be a public-facing document, written in simple language that is easily understood by everyone and written in English (may also be available in other languages relevant to the business and it supply chain).
LAYOUT OF THE STATEMENT
While the Act does not prescribe on the exact contents or length of the statement, from our research Sustainable Supply Chains offers guidance on what might be included and advises the statement be succinct and set out the steps taken during the financial year to ensure slavery and human trafficking is not taking place in any part of your business or supply chains.
Information to be contained in the statement includes details of:
Organisation’s structure, including its business and supply chains
Organisation policies relating to slavery and human trafficking
Companies’ due diligence processes relating to slavery and human trafficking in their supply chains;
Reporting on the parts of the company and its supply chains where there is a risk of slavery and trafficking taking place, and how to assess and manage said risk;
Reporting on staff training on slavery and human trafficking;
Reporting on companies’ effectiveness in ensuring that slavery and trafficking are not taking place in their businesses or supply chains (this could include measurement against KPIs)
Before writing the statement an Organisation will need to ensure it has something to write about, some good news stories, a defined organisational process for dealing with and eliminating instances of modern slavery or human rights violation from its business and supply chain.
The Sustainable Supply Chains Modern Slavery Act (MSA) Diagnostic Tool is generic and can be used by any organisations with an annual turnover above £36M. It will enable the reader to measure how well positioned you are to embed the MSA into your business and eliminate instances of modern slavery or human rights violation from your business and supply chain.
This tool is designed to help you understand how aligned your current processes and procedures are with best practice and how to embed best practice into your processes.