The Modern Slavery Act 2015 (the 'Act')
which received Royal Assent on 26 March this year, will introduce
new transparency requirements that will require businesses to prove
that no slavery and/or human trafficking is taking place within
their business and/or their supply chains. These requirements are
expected to come into force from October 2015.
The Act provides that the new transparency requirements will apply
to businesses that:
- are a 'commercial' organisation (i.e. a body corporate or partnership (whether or not incorporated or formed in the UK) which carries on a business or part of a business in the UK);
- supply goods or services; and
- have a total annual turnover of not less than a certain amount (although this amount is not set out in the Act, the Government recently published a report which indicated that the Government's intention is to set this threshold at £36 million).
The Act requires commercial organisations to prepare a slavery and human trafficking statement for each financial year. The statement should set out the steps taken by an organisation to ensure that no modern slavery or trafficking exists within their businesses or supply chains and a link to this statement should be placed in a prominent place on the organisation's website's homepage.
Charities have not been excluded from the scope of the Act and, if that had been Parliament's intention, then the Act would have been drafted to expressly exclude them. Therefore, charities who meet the three conditions set out above will need to comply with the requirements of the Act.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.