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Complying with the Modern Slavery Act Obligations

  • Businesses with a turnover of more than £36 m
    • What is the minimum obligation our company needs to do to comply with the Modern Slavery Act if our business is caught by this legislation?
  • Businesses below £36 m but are required by a client to comply
    • What does our business need to do if one of our clients requires us to comply with the Modern Slavery Act as part of a tendering process?
  1.   Businesses with a turnover of more than £36 million

The Modern Slavery Act, requires businesses with a turnover of £36 million or more to produce and publish an annual slavery and human trafficking statement and to ensure they have no form of slavery in their supply chains.  The statement must be published on the company website.

If your business has a financial year that ends 31 March 2016, you must report on what you did in the previous financial year “as soon as reasonably practicable after the end of each financial year”.

We can help you put together this statement for a business with over £36m turnover for as little as £400.  The statement must summarise the steps the Company has taken during the previous financial year to ensure slavery and human trafficking are absent from its business or supply chains.  You must report this even if no steps have been taken and you should make this clear in your statement.

A. The Statement should include:

  • An outline of the organisation’s structure, business and supply chains.
  • Policies and due diligence in relation to slavery and human trafficking.
  • An identification of parts of the business and supply chains where there is a risk of slavery and human trafficking, and the steps the business has taken to assess and manage that risk.
  • An assessment of the businesses effectiveness in ensuring slavery and trafficking are not taking place in the business or supply chains measured against performance indicators if this is considered relevant.
  • Information about training that may be in place concerning slavery and human trafficking for staff.

B. Supplier Questionnaire

We realise it is impractical for a business to audit and monitor each and every supplier in its entire supply chain at all levels, however, it should be possible to identify key vulnerable countries, industries and suppliers and effectively risk-manage to try and reasonably ensure ethical procurement.

We suggest your business adds a supplier questionnaire to the tendering process to allow your business to audit and monitor your supply chain.

We can assist with the supplier questionnaire and advice you on spatially mapping your supply chain and identifying the risk areas for a business over £36 million turnover for as little as £550.

C. Buyers and Procurement.

We would advise that buyers in an organisation also try to:

  • Make it clear to new and existing suppliers that they understand the company’s approach to modern slavery in supply chains. So, even if their suppliers are smaller than the required £36 million turnover threshold, that they treat all suppliers alike when tendering for work and ask reasonable questions of them regarding their own supply chain and ways of working through the use of the supplier questionnaire
  • Monitor the replies from the supplier questionnaire and tendering process
  • Ensure that a provision is inserted into new terms and conditions with suppliers regarding Modern Slavery compliance.
  • Encourage whistleblowing to identify breaches of policy and contractual provisions and make sure potential whistle blowers are protected.
  • Undertaking random auditing of suppliers to check that the company’s standards are being adhered to.

 

  1. Businesses below £36 m, which are not required to comply with the Modern Slavery Act regulations, but are required by a client to conform to the legislation as part of a tendering process

What is the minimum a smaller business needs to do to show compliance as part of a tendering process?

  • We would advise as a minimum to publish a Modern Slavery Statement
    • We can produce these for you for a fixed fee for as little as £200 for a small business or £400 for a more bespoke policy
    • We can assist you with drafting a Supplier Questionnaire if your client requires you to have one for a smaller business for as little as £350.