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Modern slavery reporting requirement comes into force at the end of March

29 February 2016
Ending slavery

From the end of march companies with a turnover of more than £36million that import goods will have to report on their moves to end slavery in their supply chains.

The Modern Slavery Act 2015 requires firms with revenues of more than £36million a year that buy from abroad and sell in the UK to report on their efforts to ensure there is no slavery, forced labour or people trafficking in their supply chains.

From 31 March, companies that fall within the criteria, which will include larger international stone wholesalers and producers, will have to report against the transparency in supply chains requirement of the Modern Slavery Act.

It is estimated that more than 17,000 UK and international companies with UK operations will need to produce an annual modern slavery statement, which must be approved by the board of directors and signed by a director.

Annual Slavery and Trafficking Statement

The annual slavery and trafficking statement will need to include five general areas of activity. For businesses that already produce an annual Sustainability or CSR report, the statement can be included as part of that existing reporting.

The general areas covered are:

  • A brief description of an organisation’s business model and supply chain relationships
  • A business’s policies relating to modern slavery, including due diligence and auditing processes implemented
  • Training available and provided to those in a) supply chain management and b) the rest of the organisation
  • The principal risks related to slavery and human trafficking including, how the organisation evaluates and manages those risks in their organisation and their supply chain
  • Relevant key performance indicators

The government has produced guidance which sets out the kinds of information that might be included in a disclosure, and some case studies of good practice including:

  • who is required to publish a statement
  • how to write a slavery and human trafficking statement
  • how to approve and publish the statement

See the government’s Transparency in supply chains: A practical guide here.

If you need more help, a one-day training course on Modern Slavery has been established by the Ethical Trading Initiative (ETI) to help you understand the impact of the new Modern Slavery Act and the steps companies should be taking.

The course covers:

  • Understanding definitions & how they relate to the law: modern slavery, forced labour, trafficking, exploitation
  • Making a Modern Slavery Statement – legal requirements & how to approach it (reviewing existing statements, criteria for a good statement)
  • Due Diligence – what should be included, how it works
  • Remediation – key considerations and approach in ensuring access to remedy
  • Drafting your own statement with peer & stakeholder input 

Most modern slavery courses currently available are developed for and delivered to companies only. ETI’s course is different because it takes a multi-stakeholder perspective.

It will enable you to consider who will be reading & reviewing your Modern Slavery Statement and what should inform it.

While there are many approaches to due diligence and remediation, the ETI approach is informed by the ETI Base Code as well as international law and guidance. It includes perspectives from companies and the trades unions and NGOs that will be scrutinising company policy and practice.

The first course is being held on 8 March.

ETI will also deliver this course to teams within a single company, tailored to its particular business.

Or it will run the course under a partnership model, in which a company hosts the training and invites its suppliers to attend. Course material is tailored to take account of the company's specific requirements in relation to its suppliers.

To discuss these options, contact the ETI training unit: 020 7841 4350 or [email protected]

ETI offers bespoke consultancy / advisory support for companies developing a Modern Slavery Statement. This is delivered by ETI in partnership with Anti Slavery International. Contact Cindy Berman ([email protected]) to discuss this option.

 

 

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