17 September 2019

Modern slavery: practical first steps for your business

With the obligation to publish a modern slavery statement currently only a legal requirement for businesses with an annual turnover of £36m, why might your business need one and where should you start?

Why bother?

 

Notwithstanding the high threshold on the requirement to publish a modern slavery statement, or Section 54 statement (pursuant to Section 54 of the Modern Slavery Act 2015), many smaller companies are taking up the cause for various reasons, eg:

– To meet requirements imposed by larger companies with which they deal, and which are themselves obliged to publish a Section 54 Statement
– To increase attractiveness to customers, investors and third parties
– To facilitate competition with other businesses which operate high ethical standards.

Whatever the motivation, producing a Section 54 statement can seem like just another time intensive exercise in good governance. But it is easy to achieve if you understand what your statement should look like and how the business should take it forwards.

 

What should a Section 54 statement look like?

 

A Section 54 statement is not intended to be a guarantee that your business and supply chain are free of modern slavery, but rather a summary of the steps your business is taking to address and prevent the risk of modern slavery.

It should be simple and clear and should reflect the characteristics of your business (e.g. size and structure, the nature of the business and the sector in which it operates and the nature and extent/geographical location of the business and supply chain). It need not be a lengthy or complex document.

 

Where to start?

 

Look at what steps your business already takes: are any policies and procedures (whether or not those are modern slavery specific) and quality/ethical accreditations in place already? You could also extend this review to other businesses within your supply chain.

Due diligence completed, you should also assess where the risks to your business arise. Are there gaps in the ethical standards to which your suppliers work? Do any of your suppliers operate in sectors or geographical regions in which the risk of modern slavery are regarded as more significant? Those risks do not need to be overcome before you can publish your statement. They should simply be identified as an area for improvement going forwards.

 

What are the next steps?

 

Consider where and how the statement should be published (e.g. on your website) and whether it should be circulated to suppliers etc. Always bear in mind that this should be a “living” document, reviewed and updated (ideally each year) to reflect any changes in risk profile or business operations, and any improvements made.

If you would like to discuss any queries relating to business and the Modern Slavery Act 2015, or would like assistance in assessing your risks or preparing a Section 54 statement, please contact Clare Murphy on 0121 3124785 or on cmurphy@hcrlaw.com.

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Clare Murphy, Partner
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