10 steps to take following the Modern Slavery Act 2015
The Government has recently announced the turnover threshold for companies under the Modern Slavery Act. The threshold has been set at £36m - that was the lowest suggested amount in the consultation document.
It is estimated that about 12000 companies will be caught by the legislation.
As it stands, the legal disclosure requirements may not seem particularly burdensome; however, this legislation should be seen as a prompt for companies to take stock of the prevalence of the issue in business supply chains and an opportunity to manage and minimise the associated business risks, including risk to operations and reputation/ brand.
This is not to mention that legal requirements in this are also likely to become more stringent.
Here is a list that we have put together outlining 10 steps that companies should take to get a handle on modern slavery and human trafficking: -
1. Consider whether the organisation is defined as a ‘commercial organisation’ within the definition of the Act
2. Consider whether a response to the MSA will fi t within existing strategic objectives or the organisation –such as adopting an approach to the UN Guiding Principles on Business and Human rights
3. Understand the countries in which the organisation operates -some countries pose a higher risk in relation to incidents slavery than others and understand the organisation’s operations
4. Work with relevant personnel to map the organisation’s operations and supply chain
5. Develop or update existing policies to address human rights issues, including slavery, forced and bonded labour and human trafficking
6. Develop or update any existing checklists and purchasing policies
7. Develop or update supplier codes of conduct, tender requirements or any RFPs, and supplier contracts to account for the issue of slavery and human trafficking, including, for example, requirements on minimum labour standards in their supply chain
8. Develop or update due diligence procedures to incorporate the risk of slavery and human trafficking
9. Ensure that all employees are made aware of the policy
10. Make training on slavery and human trafficking available to staff
CLT Envirolaw has produced a new report which gives you everything you need to know about the new Act; what it means for your business, what has to be included in the slavery and human trafficking statement, and what enforcement action can be taken.Colleen Theron, Ardea International