Are you ready for the Modern Slavery Act 2015?
Browne Jacobson has been watching with interest as the Modern Slavery Act 2015 has evolved.
Browne Jacobson has been watching with interest as the Modern Slavery Act 2015 has evolved; at the end of last week, Section 54 of the Act, which is designed to increase transparency in organisations’ supply chains and firmly places the onus on organisations to monitor the condition of these, came into force.
We have flagged up the impending changes earlier this month and noted the necessary measures that affected organisations might be required to take.
Last week the government published the long awaited ‘Transparency in Supply Chains etc. A practical Guide’ providing guidance on compliance with the Act. Having considered the implications of this guidance, we have prepared a guidance note for our clients to refer to and a separate checklist of practical steps that can be taken now to aid compliance with S54. It considers:
- the (wide range of) organisations that S54 applies to;
- the measures that organisations are required to take to ensure compliance, particularly what the requisite ‘slavery statement’ must comprise;
- the sanctions for non-compliance.
Organisations should be particularly mindful of the fact that even where they do not themselves constitute an organisation that falls within the Section 54 threshold, they may be required to assist their customers and suppliers with their own supply chain analysis.
We would be happy to assist if you have any queries as to how your organisation can ensure it is compliant with S54 of the Act, particularly in relation to the practical steps we have identified.
Please get in touch with your usual Browne Jacobson contact for further advice or contact one of our advisors below.