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:

Financial Year End	Recommended Start Date	Statement Due Date
31st March 2016	1st April 2016	September 30th 2016
31st June 2016	1st July 2016	December 30th 2016
31st September 2016	1st October 2016	March 30th 2017
31st December 2016	1st January 2017	June 30th 2017

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

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Section 54 – What Does It Mean For My Business?

The Modern Slavery Act has been in force for little over a year. Some large corporations are already finding it difficult to keep track of modern slavery in their supply chains. For example, in June 2016, farmers Jaqueline Judge and Darrell Houghton were found guilty of trafficking Lithuanian workers to the UK and exploiting them as modern slaves. These men were expected to travel the country to catch chickens and often had lunch breaks and facilities such as toilet breaks withheld from them. This blog sheds some light on section 54 of The Modern Slavery Act.

Section 54, Part 1 – 4: Transparency in Supply Chains

Part 1 – 4 of The Act explains who is required by law to provide a statement and when it must be updated. If your organisation provides a good or service and has an annual turnover of at least £36 million, you are required to create an annual Slavery and Human Trafficking Statement. Here, a slavery and human trafficking statement is defined as a document detailing the steps the organisation has taken to ensure human trafficking and slavery does not take place in its supply chain or business. The statement should be updated each financial year and refer to the previous financial year.

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