What is the legal development?
The Modern Slavery Act 2015 – since October 2015, commercial organisations with a global turnover of more than £36 million and carrying on business in the UK, must publish a modern slavery statement as soon as possible after their financial year end. We should start to see the first statements over the coming months.
The statement should set out the steps they are taking to ensure that slavery and human trafficking is not taking place within their business or throughout their supply chain.
The wider business community is slowly waking up to the extent of this obligation and the commercial, ethical and reputational challenges involved.
What does this mean in practice for employers?
While there may be a high threshold before a business is obliged to publish a statement, the fact that those statements have to reflect the entire supply chain means that any business (whatever its size) may be asked to provide the same information as part of its customer’s supply chain.
There is no statutory format for the statement. Each business will need to undertake its own risk assessment, review and consider internal processes and publish accordingly.
HR may not usually be involved with procurement or negotiating commercial contracts with customers and suppliers, but perhaps they now should? These are people issues after all and businesses will need to look at employment terms not only for direct employees, but throughout their supply chain.
For any values driven business, being unable to answer customer enquiries swiftly and confidently, with full knowledge of your own supply chain, may be commercially damaging.
This obligation may feel remote for the average business, but it could be a practical reality sooner than you anticipate. Apart from legal (and ethical) considerations, there will be commercial pressures to demonstrate an unaffected supply chain. Modern slavery and human trafficking is sadly happening within the UK and across the world and the issues cannot be ignored. Modern slavery statements are possibly just the first step…