2017 marks the first year that all companies (with revenues of at least £36m) must provide a Modern Slavery Act disclosure. Many companies are now preparing their second statement and are seeking guidance on how to amend their statement and how to address ongoing training requirements.
Quick start guide to compliance with the Modern Slavery Act
Tomorrow, 18th October, marks UK Anti-Slavery Day. Created by an Act of Parliament to raise awareness of the millions of men, women and children held in slavery and deprived of their basic human freedom, it can also shine a light into the slivers of progress being made to tackle modern-day slavery.
“Modern slavery is like terrorism,” said International Development Secretary Priti Patel. “If we don’t tackle the root causes, the victims will come to Europe via Libya and Italy, and those problems will manifest themselves on the streets of London.”
The Modern Slavery Act 2015 has now been in effect for well over a year and businesses across the UK have had to adjust to ensure they comply with the Act. While this means large corporations such as ASOS have had to re-think the way they monitor and audit their suppliers. Some companies have yet to produce a slavery and human trafficking statement, a requirement under the Act for businesses with an annual turnover of over £36 million. Knowing what to look for in supply chains will help your procurement team identify potential red flags within your supply chain.
Action against modern slavery is ramping up. In just the month of May 2017, the Modern Slavery Helpline dealt with nearly 200 potential victims in the UK. In the first five months of this year, 1,179 potential victims of modern slavery were identified.
Yet this number is a drop in the ocean compared to the tens of thousands of men, women and children being held as slaves right now in the UK. The Modern Slavery Act 2015 not only brought in tougher laws and sanctions against slavery, but encourages businesses to ensure they are not participating in labour abuse in their supply chains.
The Modern Slavery Act – Section 54
Section 54 of the Modern Slavery Act mandates companies with an annual turnover greater than £36m publish an annual slavery and human trafficking statement. Companies with a financial year-end date of 31st December were required to produce and publish their statement by 30th June. Many still haven’t.
Since the first modern slavery statements were published a year ago, we have gained perspective on what companies can do to fight slavery in the supply chain and the benefits of a robust anti-slavery programme. On Tuesday 26th September at 12:00pm, Richard Beale will be joining VinciWorks to discuss the practical aspects of modern slavery compliance and answer any questions you may have.
Meet the expert
Richard Beale is the Global Director of Supply Chain at Marshalls plc. and has over 20 years of experience managing global supply chain and procurement in the FMCG, retail, financial services, private equity and manufacturing sectors. At Marshalls, Richard is piloting a cutting-edge supplier education programme focusing on the elimination of modern slavery.
Ensuring an organization promotes an anti-slavery culture is now more vital than ever. Organisations must therefore ensure their staff feel comfortable bringing up any concerns they have regarding slavery. All staff should be familiar with the organisation’s modern slavery statement and be able to identify a red flag worth raising with their employer. VinciWorks has therefore created a modern slavery whistleblowing policy template that can easily be updated to suit your organisation and staff.
The Modern Slavery Act 2015 has now been in force for over 18 months. The Act means large organisations must pay closer attention to the practices of their suppliers. This includes carrying out audits of their suppliers, investigating the physical conditions of the workforce and being on the look out for instances of child labour. Further, the Act dictates that organisations with a turnover of over £36 million are required to produce a slavery and human trafficking statement.
Huge fines and potentially prison if you breach modern slavery laws
A number of large companies have recently been exposed for having modern slavery in their supply chain. For example, major phone companies Samsung and Apple have faced claims by human rights organisation Amnesty of modern slavery. The claims relate mainly to cobalt mining in the Democratic Republic of the Congo, which is used in devices such as mobile phones and tablets.
30th June 2017 marks the next big deadline for Modern Slavery Act compliance. Organisations with a financial year-end date of 31st December are required to produce a Slavery and Human Trafficking Statement before that date.
Train your staff with our suite of courses
Since VinciWorks released its first course on modern slavery a year ago, thousands of employees and suppliers have used the course as part of their internal compliance programs.
Among the overwhelmingly positive feedback we received, many companies felt they needed a more comprehensive course for procurement teams and a shorter course for general staff. Here is the suite of courses we have created to suit the needs of an entire organisation.
1. Raise your Awareness
General staff in low risk industries
Basic overview and common signs of slavery
In June, the Law Society published its first slavery and human trafficking statement under the requirements of Section 54 of the Modern Slavery Act. This emphasises its call for the legal industry to be at the forefront of the fight against modern slavery. Overall, 87 law firms have published their own modern slavery statements – a good proportion of the medium to large firms that are legally required to.
Of course, while many law firms are publishing their own statements, a key part of a law firm’s work on modern slavery is to advise their clients on fulfilling their legal responsibilities. The Modern Slavery Act doesn’t require much more than the publication of a slavery and human trafficking statement, but how to prepare it, and best practice in doing so, is up to the individual relationship between lawyer and client.
How has the Law Society tackled this problem?
The Law Society set out their statement in three key parts, offering a good guide for those firms still grappling with setting out their priorities for addressing modern slavery in their supply chains.
VinciWorks’ suite of training on modern slavery now includes three courses:
Like all VinciWorks courses, the modern slavery courses can be fully customised to:
- Fit internal procedures
- Adhere to internal style
- Include extra relevant information
In fact, every word of the courses can easily be customised.
Below are examples of the four most common customisation requests that we have collected in order to help organisations better understand best-practice for customisation.
1. Opening quote
The course Modern Slavery: Prevention Exploitation features a quote by Theresa May underscoring the severity of modern slavery. Many firms have replaced this quote with a quote or letter from an executive that reiterates the organisation’s commitment to combating slavery.
This quote sets the tone for the course and conveys the deep responsibility that all staff should feel towards the issue.