18 March 2019 - Article
The Modern Slavery Act 2015 (the '*Act*'), which is now in force, introduces new transparency requirements that will require businesses to prove that no slavery and/or human trafficking is taking place within their business and/or their supply chains. These requirements are expected to be brought into force this week with the first organisations required to comply with the new requirements are those whose financial years end on or after 31 March 2016.
The Act provides that the new transparency requirements will apply to businesses that:
- are a 'commercial' organisation (i.e. a body corporate or partnership (whether or not incorporated or formed in the UK) which carries on a business or part of a business in the UK);
- supply goods or services; and
- have a total annual turnover of not less than a certain amount (although this amount is not set out in the Act, the Government recently published a report which indicated that the Government's intention is to set this threshold at £36 million).
The Act requires commercial organisations to prepare a slavery and human trafficking statement for each financial year. The statement should set out the steps taken by an organisation to ensure that no modern slavery or trafficking exists within their businesses or supply chains and a link to this statement should be placed in a prominent place on the organisation's website's homepage.
Charities have not been excluded from the scope of the Act and therefore, charities who meet the three conditions set out above will need to comply with the requirements of the Act.