already registered?

Please sign in with your existing account details.

need to register?

Register to access exclusive content, sign up to receive our updates and personalise your experience on brownejacobson.com.

Privacy statement - Terms and conditions

modern slavery - your risks and duties as the next deadline approaches

15 March 2017

Modern slavery is the fastest growing organised crime in the world. The UK is far from immune, being a leading country of destination. 

The number of recorded victims of modern slavery in the UK last year jumped by 40 percent compared to the previous 12 months. The Home Office considers that there are in excess of 10,000 potential victims of modern slavery in this country. In the last three years, the number of reports of modern slavery made to the Metropolitan Police increased by 242 percent. One in eight NHS professionals have been in contact with a patient they knew or suspected to be a victim of modern slavery.    

Modern slavery is the term used to encapsulate the crimes of slavery, servitude, forced or compulsory labour and human trafficking. The Modern Slavery Act 2015 (the 'Act') is the first of its kind in Europe, and one of the first in the world, to specifically tackle modern slavery.

The Act requires in scope organisations to publish a slavery and human trafficking statement, approved by the board and signed by a director, within six months’ of each financial year end and to publish it on it’s website with a link in a prominent place on the homepage. 

The statement should include various pieces of information and set out the steps the organisation has taken in the past year to ensure that modern slavery is not taking place in the organisation itself or in its supply chains regardless of where they are located.

Any organisation, in the public or private sector, in any part of a group structure will be required to comply if they:

  • are a body corporate or a partnership, wherever incorporated/formed
  • supply goods or services in the UK
  • have a total annual turnover of at least £36m.

Turnover includes that of any subsidiary regardless of where they are based.

It remains to be seen whether compliance will improve as the second tranche of statements are due to be published by 30 June 2017. The Independent Anti-Slavery Commissioner is on the record as being less than impressed with the low number of statements published to date and with the quality of most of them. A tick box approach is not good enough. 

Looking at your organisation and its supply chains objectively and showing you took a proportionate due diligence approach to combating modern slavery is key.  

Unless compliance improves significantly the government is almost certain to start publically naming and shaming non-compliant organisations in order to encourage the rest. The practice is perceived as being effective (and is inexpensive) in relation to employers who paid below the National Minimum Wage. 

Protecting your organisation by complying with laws introduced to combat such heinous crimes and breaches of human rights is highly recommended. 


Modern Slavery Navigator

To assist our clients, we have put together a suite of template documents that seek to arm an organisation with the tools its needs to prepare for the Section 54 requirements. Download our product summary for more information about how we can support you and your organisation with the Modern Slavery Act 2015.

training and events

19Sep

In house lawyers' forum

Being an in house lawyer isn’t just about the law – perhaps it never has been.

View event

21Sep

In house lawyers' forum

Being an in house lawyer isn’t just about the law – perhaps it never has been.

View event

focus on...

Legal updates

National Crime Agency sound the alarm on modern slavery in the UK

Shocking statements made recently by the National Crime Agency should eliminate any delusional belief that modern slavery is not prevalent in the UK today.

View

Legal updates

Access to justice - the impact of fees

On 26 July 2017, the Supreme Court handed down its decision in respect of Unison’s long-running challenge to the introduction of fees within employment tribunals.

View

Legal updates

Off-payroll - working in the public sector changes to the intermediaries legislation (IR35)

From 6 April 2017, changes have been introduced to the tax rules where individuals provide their services to a client in the public sector via an intermediary.

View

Legal updates

Modern Slavery Act 2015 update - another new Bill on its way

Until just before the UK general election, there was a Bill making its way through Parliament seeking to amend the requirements of section 54 - but as stated in our recent this Bill was dropped largely due to a lack of parliamentary time to consider its proposals prior to the election.

View

The content on this page is provided for the purposes of general interest and information. It contains only brief summaries of aspects of the subject matter and does not provide comprehensive statements of the law. It does not constitute legal advice and does not provide a substitute for it.