UK: Modern Slavery Act supply chain reporting obligation comes into force

A new UK supply chain reporting obligation came into force on 29 October 2015. Any large (worldwide turnover of £36 million or more) commercial organisation carrying on business in the UK, wherever incorporated, is required to comply.

We issued a briefing on the new reporting requirement in August 2015. An update of that briefing, which reflects the commencement date and Government guidance, is available here.

Further details

The UK Modern Slavery Act 2015 (section 54) imposes a new reporting obligation requiring commercial organisations to prepare a slavery and human trafficking statement for each financial year ending on or after 31 March 2016. The statement should:

• include the steps that the organisation has taken to ensure that slavery and human trafficking is not taking place in any of its supply chains and in any part of its own business (or a negative statement that the organisation has taken no such steps);
• be approved by the board and signed by a director (or equivalent); and
• be published on the company’s website, with a prominent link to it on the website’s homepage.

The MSA sets out the types of information that a slavery and human trafficking statement may include, for example due diligence processes and staff training. The Government has also published detailed guidance on how to comply with this new reporting requirement.