I am not ashamed to admit that I hadn’t initially paid much attention to the introduction of the Modern Slavery Act 2015, (“the Act”) as I couldn’t see on what basis it would affect my clients or myself.
However, as I prepared to attend a seminar where supply chain reporting in terms of the Modern Slavery Act 2015, (“the Act”) was discussed I questioned my ambivalence.
Part of the supply chain
I thought about the fact that I either use, or am part of a supply chain. With that realisation, my interest was piqued! It also got me thinking that I may not be the only one wondering why I’ve been asked by my customers to confirm firstly that I am complying with my obligations under the Act and secondly, where my services are being supplied from.
Understanding my obligations, and yours
If you who are unaware of the Act, it was introduced in October 2015. The organisations obliged to comply with it are UK and non-UK entities, whether they carry on a business or part of a business in the UK. It applies to corporate bodies and partnerships which turn over a £36 million threshold, although if you’re below that threshold you still need to pay attention.
Removing modern slavery from the supply chain
Qualifying organisations must publish a Slavery and Human Trafficking Statement each financial year. In it they must confirm the steps they have taken to ensure that modern slavery is not taking place either through their own business activities or, notably, of those in the business’s supply chain. In addition, these organisations must have their statement or a link to it visible on their websites.
Why we all need to pay attention
While your business might not be turning over that level of income, if you supply goods or services to a company which is expected to comply with the legislation, then you can expect that client to ask you what steps you are taking to ensure that you comply with the Act.
For everyone that means that you have to look at your business and who you supply. A customer is entitled to ask you what steps you have taken to minimise any risk of slavery and human trafficking in order that it can meet its own obligations. It also means they can ask you where the goods you are supplying have come from. They can also go so far as to ask you to comply with their policy.
If you have any queries about the Act and how it will affect you and your business, then please contact me at jks@businesslaw.co.uk.
