Are you aware of your business’ obligations under the Modern Slavery Act?

The government recently published its 2019 UK Annual Report on Modern Slavery and it makes stark reading.

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Are you aware of your business’ obligations under the Modern Slavery Act?

The report highlights that 5,019 offences of modern slavery were recorded in the UK in 2018, an increase of 49% on the previous year.

Whilst the causes of this increase are complex and could in part be due to improved recognition of the issue, it is sadly clear that modern slavery is not going away any time soon.

The shocking news of the deaths of 39 people found in a lorry in Essex and believed to be Chinese nationals this week has been a tragic reminder of this.

Given this background, it is perhaps unsurprising that the government has announced its intention to increase requirements on any business involved in fulfilling supply chain contracts.

While the government has yet to announce how these proposed changes will look, it seems likely that at the very least rules on auditing and supply chain transparency will be tightened.

In the meantime, businesses must be aware of their existing obligations under the Modern Slavery Act 2015.

Businesses with a total turnover of £36 million or more must prepare a yearly statement setting out what they are doing to combat slavery and human trafficking.

This statement should include – amongst other things – relevant policies and training and identify specific risks in their supply chains.

Whilst there is currently no penalty if qualifying businesses fail to publish such a report, the Secretary of State can enforce compliance via a civil injunction and there is also a huge risk of reputational damage to a business if the government carries out its threat to “name and shame” those that don’t comply. It also seems likely that the government may seek to introduce penalties for non-compliance in the future.

Therefore, if yours is a business likely to be affected by the Modern Slavery Act in any way, our advice is to ensure you are aware and fully compliant with your existing obligations and bear it in mind that these obligations are only likely to increase.

If you would like advice on your business’ obligations under the Modern Slavery Act 2015, please contact Carys Thompson at carys.thompson@keebles.com or call Carys on 0114 252 1485.

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