Supply Chain Transparency – legal requirement to publish statement now in force

Section 54 of the Modern Slavery Act 2015 requires all commercial organisations with a global annual turnover of £36 million or above, who do any business in the UK, to publish a Slavery and Human Trafficking Statement each financial year.  The statement must be accessible from a link on your website’s homepage.  It should set out, among other detail, the steps taken by your organisation to guard against slavery and human trafficking in its supply chains.  Failure by a commercial organisation to publish a statement may result in the Home Secretary obtaining an injunction compelling it do so, and significant bad publicity. 

This new legal requirement comes into force on 29 October 2015. There is still time, however, to work on the content of your statement.  Any organisation whose current financial year ends on or after 31 March 2016 will have to publish a statement for this financial year, although ministers have indicated that they will be allowed up to six months after the year end to complete it. Organisations whose financial year ends before 31 March 2016, will not have to prepare a statement until their next financial year.

We are still awaiting promised guidance from the Home Office providing more detail on what to include within the statements.  We will be publishing a briefing note as and when that guidance is made available.  However, any organisation wanting advice on whether it is caught by this new law, or what steps it should be taking now to prepare for drafting its statement, should contact Jayne Hussey or Jessica Burt.