What is it?
The Modern Slavery Act (MSA) is a UK law that came into effect on 1 October 2015. It places a legal duty on commercial organisations to produce and publish an annual statement. The statement must outline the steps they have taken to ensure their operations and supply chains are free of slavery and human trafficking or report that no such steps have been taken.
Does it apply to our organisation?
If your company has a turnover of £36M or
more and does business in the UK, even if it is incorporated or formed abroad,
then the Act applies and, to comply, your organisation has a duty to publish a
slavery and human trafficking statement annually. Your organisation must detail
what you are doing to address these
issues in your supply chains and your own business.
if you are a UK public sector entity or, a smaller organisation with turnover
below the amount identified that supplies a larger company that has to comply
with the Act, you
may be asked to disclose whether you have taken steps to ensure your own
operations and supply chains are free of slavery and human
What does the annual MSA statement need to include?
The statement by an organisation meeting the
turnover threshold must outline the steps it has taken during its financial
year to ensure slavery and human trafficking are not taking place—(i) in any of its supply chains, and (ii) in any part of its own business
The Act also states that organisations may
choose to say in their statement that no such steps have been taken. That said,
due to the increasing awareness of the tragic impact of slavery and human
trafficking on individuals, as well as the increasing risk of incurring
reputational and financial damage, organisations are choosing to be proactive.
Although the Act is not prescriptive, it suggests
the MSA statement reports on the policies, training, due diligence processes
and steps taken to assess and manage the risks of slavery and human trafficking
taking place as well as improvements in performance over time.