Nearly 17,000 chief executives of UK businesses with an annual turnover of more than £36m have received a letter from the Home Office asking them to publish an annual Modern Slavery Statement regardless of whether those businesses are compliant currently. Those that don't risk appearing on a published list of non-compliant organisations.

Home Office statistics suggest only 60% of companies have complied with the publishing of a statement at all. Further, it has found that far fewer of those statements are compliant and many are poor in quality or fail to meet the basic legal requirements.

From 31 March 2019, the Home Office will be auditing all existing statements, with a view to publishing a list of non-compliant organisations. 

Companies should be aware that even if they are not doing anything to tackle modern slavery in their supply chain (although companies should consider the reputational impact and impact on their ability to do business effectively if they are not) they still have to publish a statement saying that they are not doing anything.

Now is a good time, therefore, for all businesses to review their existing approach to Modern slavery and in particular their Modern Slavery Act supply chain statements.

Businesses should aim to publish the statement within six months of financial year end.

As a minimum, all statements must be:

  • updated every year
  • published on the UK website of the business with a link in a prominent place on the homepage
  • approved by the board with the date of board approval indicated in the statement
  • signed by a director (or equivalent) with a note of the signatory's name, job title and date of signature

The statement should set out the steps that the business has taken to ensure that slavery and human trafficking are not taking place in the business itself or in its supply chains. Best practice is to include commentary on the following six areas:

  • structure and supply chains
  • policies on modern slavery
  • due diligence processes
  • risk assessment
  • measuring effectiveness
  • training for staff

Need help to draft a statement?

To avoid being named and shamed, please contact our expert Craig Weston who can review your existing statement or help you put proper reporting systems in place to make sure your business complies with the Modern Slavery Act.  

To contact Craig: +44(0) 207 421 3976 or craig.weston@irwinmitchell.com.