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 September 2016.

Who?

MODSA will apply to your commercial organisation if:

  • it has a total annual turnover of £36 million or more;
  • 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.

What?

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 statement".

The statement may (not mandatory) include the following information:

  • the organisation's structure, its business and supply chains;
  • policies in relation to slavery and human trafficking;
  • due diligence process in relation to slavery and human trafficking;
  • 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.

When?

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 to comply.

© MacRoberts 2016

Disclaimer

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.