South: Companies must take steps on anti-slavery laws, says Blake Morgan

Thames Valley businesses have been advised about new guidance which requires them to take steps to ensure their supply chains do not involve human trafficking or slavery.

Allan Briddock, who heads the immigration team at Oxford and Reading law firm Blake Morgan, says organisations need to be aware of recently-issued Home Office guidelines relating to the Modern Slavery Act 2015.

Companies which supply goods or services and have an annual turnover of £36 million or more are required to produce an annual “transparency in supply chains” statement which is clear about the steps they have taken to ensure suppliers do not use slave labour or engage in human trafficking.

Briddock, a specialist in advising corporate clients on compliance with human rights legislation, said: “A turnover of £36m is not a high threshold and the requirement to produce a modern slavery and human trafficking statement is likely to hit medium-sized businesses hard, particularly in the retail sector.

“In addition this will affect many companies whose turnover is under the £36m threshold, if they are suppliers to larger businesses. We are likely to see big businesses including a clause in all contracts that all suppliers must not have modern slavery or human trafficking in their supply chains.”

The annual transparency statement may include information such as the organisation’s structure, business and supply chain, its policies in relation to slavery and human trafficking, the steps it takes to reduce and manage the risk, and the relevant training given to staff.

Organisations whose financial year ends before March 31, 2016, will not be required to produce the statement until the end of the following financial year.

Those whose year-end is after that date will need to produce their statement “as soon as practicable” after the end of the current financial year – Briddock advises that a six-month window would be acceptable.

He added: “All organisations which will be required to prepare the statement should start thinking about whether they have sufficient practices in place to ensure compliance.

“That includes the organisation looking at the questions it asks its suppliers and its own procurement policies, how it treats its staff, and training.

“The home secretary, Teresa May, has stated that peer and consumer pressure will be the driving force in eliminating modern slavery and human trafficking in supply chains. The success of the new requirement may, however, rest with the willingness and ability of the Home Office to enforce it.”