Modern Slavery Act – preparing your second statement

A group of people being kept as modern slaves, including a mother with a baby

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.

Useful resources

Revised guidance on modern slavery statements

On 4 October 2017, the UK Home Office released revised guidance on how businesses should comply with the Modern Slavery Act. The Act, introduced in 2015, requires all large businesses to produce an annual statement setting out the steps they have taken to prevent modern slavery in their business and supply chains. This refreshed guidance lays out our expectations for these statements, including more explanation of what best practice looks like.

Key changes in the guidance include:

  • Encouragement for small organisations to voluntarily produce statements
  • Emphasis on businesses including information in relation to all six categories recommended in Section 54 of the Act
  • Statements should now be published as soon as “possible” after the financial year end, rather than as soon as “reasonably practicable”, but there is still no hard deadline for publication and the expectation remains that statements should be published within 6 months following the year end
  • Best practice to include the date that the Transparency Statement was approved by the board and to ensure that the director who signs it is also on the board that provided that approval

Training recommendation

Many organisations are choosing to use VinciWorks’ full suite of modern slavery training courses in order to tailor training appropriately to different job roles. A typical training plan is:

Training in second year and beyond

Since an organisation’s statement details the steps taken within that financial year, each year an organisation must update its training procedures for that year. For many organisations we recommend using the online course Modern Slavery: Raise Your Awareness as ongoing refresher training on modern slavery. The course only takes 10 minutes and provides a basic overview of the topic with common red flags.