When Should My Organisation Publish its Modern Slavery and Human Trafficking Statement?

The 2015 UK Modern Slavery Act stipulates that all companies with an annual turnover of over £36 million must publish a Slavery and Human Trafficking Statement for 2016. The government guidelines recommend that a company’s Slavery and Human Trafficking Statement should be published prominently on its website within six months of the end of its financial year.  Here are the relevant dates for companies to produce their statement:

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Here is a practical checklist with the steps you need to take to ensure your statement is published on time.

Our Research shows that around 50% of companies have a financial year end of 31^st March. This means that over half of the companies with a turnover of over £36 million should have already published a Slavery and Human Trafficking Statement. As organisations get to grips with the new regulations under the Act, it is clear that not all the organisations are ranking so well.

The findings from a recent report by the Business and Human Rights Resource Centre shows that most organisations are still far from meeting the minimum requirements and showing that they take the Act seriously. The report gives an analysis of the FTSE 100 companies that have a statement due date of 30^th September or that have already published a statement. Findings show that:

• Only 56% of the Slavery and Human Trafficking statements met the minimum requirements of the Modern Slavery Act
• In the Structure, Business & Supply Chains category, the average score out of 5 was 1.8
• The Risk Assessment & Management category had an average score of 2.2
• Only M&S provided Key Performance Indicators in their statement, with the Effectiveness category scoring an average of 1 out of 5
• The highest scoring category was that of Due Diligent Processes. Nonetheless, it achieved an average score of only 2.3%

Twelve Months Prior to Publication – Understand Supply Chains and KPIs

• Develop measurable KPIs for your anti-slavery programme
• Review and update your company’s supply chain risk assessment
• Review and update due diligence measures

Six Months Prior to Publication – Communicate with Suppliers

• Review paid invoices and create a list of suppliers
• Write a supplier review questionnaire
• Prioritise which suppliers must submit answers to the questionnaires based on their significance to your core business
• Send out supplier review questionnaires
• Conduct spot checks and audits of high-risk suppliers

Four Months Prior to Publication – Review Slavery Policy and Training

• Review and update your company’s internal slavery policy
• Ensure that all staff including recent joiners have affirmed the policy
• Review relevant training options and enrol appropriate staff
• Collate KPI data and compare to previous year

Three Months Prior to Publication – Draft a Statement

• Write first draft of statement
• Ensure that the draft statement covers all six criteria recommended by the Act:

1. Structure, business and supply chains
2. Slavery and human trafficking policies
3. Due diligence procedures
4. Identifying, assessing and managing risk
5. Key performance indicators
6. Staff training on modern slavery

Two Months Prior to Publication – Communicate with BOD

• Send statement to board of directors for review and comment
• Determine who will need to approve the statement
• Identify which director will sign the statement

One Month Prior to Publication – Receive Statement Approval

• Complete the second draft
• Send to the board of directors for approval
• Send to the designated director to sign

Two Weeks Prior to Publication – Communicate with Website Manager

• Identify the person responsible for updating the company website and notify them
• Find a prominent place on the homepage to link the statement
• Inform the marketing department and draft a press release

The Day of Publication – Publicise your Statement

• Conduct a final proofread and spell-check of the statement
• Confirm that the statement is signed by director or equivalent
• Confirm that the statement covers all six criteria recommended by the Act
• Publish the statement on the website and homepage
• Distribute a press release

No Time like the Present

Whether your organisation’s deadline has passed or not, all organisations should begin the process of creating a Slavery and Human Trafficking Statement. With large companies such as Asos, Zara and M&S already exposed for modern slavery in their supply chains by a BBC Panorama report, now is the time to really understand your supply chains. Who are the suppliers? Are they being audited? Are children working in any of the factories in the supply chain? Are staff being paid according to the minimum wage?

Download our free guide to the publishing a slavery and human trafficking statement

If you need more information, download our free guide to the modern slavery act.