Modern Slavery and Human Trafficking Statements for Businesses: Updated Guidance Published
The Government has published updated guidance on the obligation to publish a slavery and human trafficking statement.
Commercial organisations supplying goods or services from or to the UK with a global turnover of above £36 million are obliged to publish a slavery and human trafficking statement each financial year. The statement must set out the steps they have taken to ensure that there is no slavery or human trafficking in their business or supply chains, or say that no such steps have been taken. The Government published guidance in October 2015.
Government Guidance on Publishing a Statement
The Government has now updated its guidance. The wording of the updated guidance indicates that a statement “should aim” to include information about the organisational structure and group relationships; the countries where goods or services are sourced from; the make-up and complexity of supply chains; details of relationships with suppliers and others; policies on procurement and recruitment; staff training to increase awareness of modern slavery; and due diligence processes, risk assessments and performance indicators that could expose the business to the risk of modern slavery. The previous version was less prescriptive, simply indicating that a statement may contain this information. The guidance also adds a definition of child labour.
The guidance recommends that organisations should keep historic statements available online for comparison purposes and that they should continue to publish statements, even if their turnover falls below £36 million. It also indicates that it is best practice for the director who signs the statement to sit on the board that approved the statement and for the statement to include the date on which the board approved the statement.
The updated guidance also suggests that it may be helpful for smaller organisations to publish a statement on a voluntary basis if they are responding to supply chain due diligence queries (which might ask if they have a statement or policy setting out their approach to tackling modern slavery) or if they are bidding for contracts against businesses that have a modern slavery statement.
The updated guidance can be viewed here.
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