Qu.1: Does the Modern Slavery Act 2015 ("MODSA")
apply to your organisation? (If you are unsure see the
"Who?" section below or contact us).
Qu.2: Is your organisation's financial year end
on 31 March 2016?
If you answered "yes" to both questions then your
organisation is required to publish a modern slavery statement by
MODSA will apply to your commercial organisation if:
it has a total annual turnover of £36 million or
it carries on business in the UK; and
its financial year end was on or after 31 March 2016.
Those organisations that do not meet the above requirements may
still be required to assist in the preparation of statements where
they form part of the supply chain of a larger organisation.
MODSA requires commercial organisations to disclose on an annual
basis any steps taken to ensure their business and supply chains
are free from modern slavery and human trafficking – this is
known as an "anti-slavery and human trafficking
The statement may (not mandatory) include the
the organisation's structure, its business and supply
policies in relation to slavery and human trafficking;
due diligence process in relation to slavery and human
identifying parts of the supply chain where there are risks and
the steps taken to manage that risk;
performance indicators; and
training for staff about slavery and human trafficking.
Those organisations with a financial year end on or from 31
March 2016 must publish their statements within six months of the
organisations financial year end – meaning that some
organisations (i.e. those organisations whose financial year end is
on 31 March 2016) have until the end of this month
The material contained in this article is of the nature of
general comment only and does not give advice on any particular
matter. Recipients should not act on the basis of the information
in this e-update without taking appropriate professional advice
upon their own particular circumstances.
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In SSE Generation Limited v Hochtief Solutions AG and another decided on 21st December 2016, the Court of Session in Scotland considered a contractor's potential design liability under the NEC Form of Contract.
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