New guidance: Updated guidance for businesses (with supply chains) subject to UK anti-slavery laws

Businesses with a turnover of at least £36m who are operating in the UK, or supplying UK customers, will welcome updated guidance to help them comply with anti-slavery laws.

The anti-slavery laws are designed to prevent slavery in businesses and/or business supply chains. They require commercial organisations which provide goods or services, whether they operate in the UK or sell to UK customers, to publish a 'slavery and human trafficking statement' on their website (or most 'appropriate' one if they have more one).

The statement must set out the steps they have taken during the fiscal year to ensure no slavery or human trafficking has taken place in their business or supply chains (or, if appropriate, that none have been taken). If the organisation has no website, the statement must be provided to any person who makes a written request to see it, within 30 days.

The steps likely to have been taken include contractual clauses with suppliers to make them also comply with the new laws, even if those suppliers are themselves below the £36m turnover threshold.

The guidelines for organisations, Government Guidance: Transparency in Supply Chains, have been revised and reissued, with changes including:

  • Firmer recommendations in relation to the information to be included in statements
  • Signature of statements by a board director, with a reference to the date the board approved it
  • Maintaining old statements online so visitors can monitor changes made over time
  • New definitions relating to child labour
  • New recommendations on when statements should be published (as soon as possible after the year-end)
  • Higher expectations relating to human rights due diligence, which is to be treated as part of an organisation's wider corporate social responsibility
  • Encouragement for organisations with a turnover of less than £36m to produce a Transparency Statement and otherwise comply, proportionate to their industry, size and operational reach

Operative date

  • Now

Recommendations

  • Organisations subject to the modern slavery rules should:
    • View the guidance on the GOV.UK website
    • Review their relevant policies, procedures, contracts and relationships with suppliers, staff and staff/supplier training with a view to maintaining compliance with the law
  • Organisations below the £36m threshold should consider whether to comply 'proportionately'

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