New guidance: Regulations and guidance issued for businesses subject to UK anti-slavery laws
Businesses operating in the UK, or supplying UK customers, with a turnover of £36m or more will welcome new regulations and guidance on complying with recent anti-slavery laws.
This update was published in Legal Alert - December 2015
Legal Alert is a monthly checklist from Atom Content Marketing highlighting new and pending laws, regulations, codes of practice and rulings that could have an impact on your business.
The anti-slavery laws are designed to prevent 'slavery' occurring in businesses and/or supply chains. They require commercial organisations that operate in the UK or sell to UK customers and provide goods or services, to publish a 'slavery and human trafficking statement' on their website (or, if they have more than one, the most 'appropriate' one).
The statement must set out the steps they have taken during the fiscal year to ensure no slavery or human trafficking has taken place in either their business or supply chains (or, if that is the case, that none have been taken). If the organisation has no website, the statement must be provided to any person who makes a written request to see it, within 30 days. Those steps are likely to include details of the relationship with suppliers such as contractual clauses
The new rules/guidelines confirm that:
- Businesses whose financial year ends between 29 October 2015 and 30 March 2016 do not need to provide a statement for their current financial year
- Businesses whose financial year-end is on or after 31 March 2016 must provide a statement within six months of their current financial year-end
- 'Turnover' means revenue from the supply of goods and services from both the organisation and its subsidiaries after deducting trade discounts, VAT and other taxes
- The statement should be in English, but can be in other languages as appropriate
- There are no specific rules as to the content of the statement, but the guidance provides useful, practical examples of what might be in it – such as the organisation's operating model, its relationship with suppliers, the due diligence it undertakes when choosing suppliers, the impact assessments it carries out and evidence of 'stakeholder engagement'
- There should be a 'prominent' link to the statement from the website home page
Organisations subject to the anti-slavery rules, or supplying goods or services to those who are, should:
- Consider whether their turnover, as defined, reaches the £36m threshold
- Review their policies, procedures, contracts and relationships with suppliers, staff and their staff/supplier training
- Calculate when they need to make their first statement, and what to put in it
Disclaimer: This article from Atom Content Marketing is for general guidance only, for businesses in the United Kingdom governed by the laws of England. Atom Content Marketing, expert contributors and ICAEW (as distributor) disclaim all liability for any errors or omissions.
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