Modern Slavery and Employers’ Responsibilities
12 April 2018
In order to tackle Modern Slavery, new anti-slavery laws have been brought into force in England and Wales in recent years. These laws require large businesses in the UK to outline steps they have taken to ensure that Modern Slavery is not taking place anywhere in their business or along their supply chains. This is to ensure that UK businesses (and those operating in the UK) are in no way complicit in the practice of Modern Slavery, either knowingly or unknowingly.
What is Modern Slavery?
Although legal slavery was abolished in the UK over 180 years ago, slavery is still happening throughout the UK and the rest of the world. Modern Slavery can take many forms, but in essence it can be defined as individuals being forced to work without proper remuneration or appreciation.
A person is recognised as being enslaved if they are owned or controlled by someone who forces them to work, either by threat or through coercion. Victims of Modern Slavery are sometimes dehumanised, being bought and sold as commodities and they might also be detained, without the freedom to move or travel as they wish.
It is estimated that there are over 40 million people currently living in Modern Slavery around the world. This includes men, women and children and includes those in forced labour, forced marriages and forced sexual exploitation.
In 2015 the Modern Slavery Act was introduced in England and Wales, in order to tackle all forms of Modern Slavery. There is a clause in the Modern Slavery Act called the Transparency in Supply Chains clause. Under this, all organisations operating in the UK with an annual turnover of at least £36 million are required to produce an annual slavery and human trafficking statement.
Smaller organisations can also choose to produce this statement if they wish. Some smaller organisations may choose to do this if they are bidding for work with larger organisations who request information on their approach to Modern Slavery.
The reason for the Transparency in Supply Chains clause is that complex supply chains make it almost impossible to determine whether slavery had been used in the production of a product. This means that many products in high street shops around the world could have been made by or contain ingredients grown by victims of Modern Slavery. In order to combat this, the UK Government requires all large businesses who operate in the UK (even if they are not based in the UK) to be clear and transparent at every stage of their supply chain.
The annual statement should contain details of the company’s supply chain, including the structure of the supply chain and any risk assessment that has been carried out on any parts of the supply chain that may pose a risk. It should also outline the steps that the business has taken to address that risk and any training on the subject of Modern Slavery that has been offered to staff.
The completed statement must be approved and signed by a senior person in the business, such as a director, member or partner. The reason for this is to ensure that the issue is given a serious level of attention and also to ensure a senior level of accountability. Ultimately, an organisation’s senior management are the best placed to create a workplace culture in which Modern Slavery is not tolerated.
Once it has been signed and approved, the organisation must publish the statement on their website, with a link through to it from a prominent place on the homepage. This makes the statement accessible to the public, suppliers, clients, customers, investors and employees.