Matters are moving quickly on the implementation of the key provisions of the Modern Slavery Act 2015. The Modern Slavery Act (Transparency in Supply Chains) Regulations 2015 have now been approved by the House of Lords, and it looks as though the requirement for organisations with a turnover of more than £36M per annum to prepare an annual slavery and human trafficking statement for each financial year of the organization, will come into force from next week.

This requirement (set out at section 54 of the Act) will mean that every commercial organization which meets the turnover threshold (and this will include charities and educational institutions, which sell goods or services at or above the requisite threshold), will need to provide an annual statement, either (a) setting out the steps the organization has taken during the financial year to ensure that slavery and human trafficking is not taking place either in any of its supply chains or any part of its own business; or (b) stating that it has not done this.

We are guessing that most large organisations will not want to admit that they have not taken reasonable steps to investigate the possibility of slavery in their supply chains, and that this legislation will prove to have been a significant step to eradicating the pernicious shame of slavery in the twenty-first century, in the supply chains of UK companies at least.

For more information on how to create a pathway to compliance, please contact katherine@mirkwoodevansvincent.com