The Modern Slavery Act: what does it mean? For the construction sector, modern slavery (a concept covering slavery, servitude, forced and compulsory labour, and human trafficking) can be a major supply chain issue, particularly for those involved in large or high profile infrastructure projects in challenging labour environments.
While modern slavery is a global phenomenon that all affected organisations should be tackling, for those subject to the new reporting requirements under the UK’s Modern Slavery Act 2015 (MSA), the issue of preventing modern slavery in supply chains is now a very public compliance challenge. Reporting requirements The MSA’s transparency provisions require “commercial organisations” supplying goods or services, with a minimum global turnover of GBP 36 million, and carrying on “business” in the UK, to publish an annual “slavery and human trafficking statement” on their website of the steps taken to ensure modern slavery is not taking place in their own business operations or in their supply chains. Turnover is calculated to include the turnover of subsidiaries and, although there’s no minimum level of UK “business” required to trigger the obligation, and no requirement to be physically located in the UK, the Government’s statutory guidance - Transparency in Supply Chains: A Practical Guide - states that a demonstrable business presence in the UK will be required to trigger the obligation.
Organisations with a financial year ending 31 March 2016 will be the first required to publish their statement. The Government expects statements to be published within six months of the organisation’s financial year end and to be developed and improved year on year. The MSA sets out a high-level framework of what may be included in a statement, covering the following key areas: – – A brief description of an organisation’s business model and supply chain relationships – – Policies relating to modern slavery, including due diligence and auditing processes implemented – – Training available on modern slavery – – The principal risks related to slavery and human trafficking (including how risks are evaluated and managed in their organisation and supply chains) – – Key performance indicators (allowing third parties to assess the effectiveness of the activities described in the statement) The statutory guidance provides further details on these themes, as well as guidance on how to respond to modern slavery, if it is identified in a supply chain.
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