Modern slavery statements

The 2015 Modern Slavery Act introduced a requirement for large organisations to produce a modern slavery statement each financial year. The statement will set out the steps the organisation has taken to make sure modern slavery has not taken place in their business or in their supply chains.

Organisations are required to publish the statement on their website within six months of the end of their financial year.

The requirement aims to increase transparency in the business practices of large organisations. The publishing of the statement will allow the public, consumers, employees and investors to view the steps organisations are taking to help tackle slavery.

A template modern slavery statement is available in the 'Modern slavery statement' model documents.

Recent developments

Recognising the problems faced by organisations during the coronavirus crisis, the Home Office has published new guidance announcing that they can delay their next modern slavery statement by up to six months without facing a penalty.

The full text of the new guide can be found at this link. It makes clear that, when businesses do issue the required statement, it must include the reason for any delay. Furthermore, given that suppliers may be seeking to recruit additional workers in order to meet increases in demand, organisations need to ensure that they, and their suppliers, are maintaining rigorous checks during the recruitment process. This is to ensure that vulnerable workers are not being exploited by third parties seeking to profit from heightened demand.

The Home Office has released a consultation examining whether reporting requirements need to be made stricter. This includes asking whether mandatory reporting areas, rather than suggested areas, will make statements more comprehensive and uniform. In addition, the consultation is looking at introducing a single annual reporting deadline as well as requiring statements to be uploaded on to an online portal. The consultation closed in September 2019.

In July 2018, the government announced that they were commissioning an independent review of the Modern Slavery Act 2015. The review is aimed at strengthening the current provisions in place and increasing the progress which is currently being made to remove modern slavery by businesses.

For organisations, key areas the review will consider are:

• the development of understanding and awareness of the nature of modern slavery offences
• whether existing requirements to publish a modern slavery statement can be strengthened
• what steps can be taken to minimise the risk that forced labour and slavery are producing UK goods and services.