Governmental Relations

Contact: Boodle Hatfield LLP (London, England)

The Modern Slavery Act 2015 came into force this month. The Act introduces a requirement for organisations to make a statement on the steps that they are taking to ensure that their supply chain and their business itself is free from slavery and trafficking. The requirement applies to all organisations which are carrying on business in the UK, supplying goods or services with an annual turnover (including any subsidiaries' turnover) in excess of £36 million. Such businesses must publish this statement on their website and include a link to it in a prominent place on their homepage. If a company fails to make a statement, the Home Secretary can enforce the obligation by seeking an injunction in the High Court. 

There is no prescribed form of statement and the Act does not prescribe particular slavery and human trafficking policies which a company must implement. In fact, a company can opt to state that "no steps have been taken" in relation to slavery and human trafficking in supply chains. However making a statement that it has taken no such steps may have damaging consequences for the company's reputation. The government is expected to publish guidance on the statement sometime this month but it is envisaged that the statement may include information about the organisation's structure, business and supply chains; policies on slavery and human trafficking and information on the risk management steps taken.

Comment: 

We can expect more policies in this area as human trafficking is widespread within the EU.