While we tend to think of slavery as an evil of times gone by, human trafficking, slavery and forced working for inadequate compensation are becoming increasing concerns in our global economy.

The aim of the Modern Slavery Act is to ensure that large businesses (businesses with an annual turnover of more than £36 million) monitor and control their operations and supply chains and keep them free from human trafficking and slavery. To achieve this it requires them to make a statement each financial year on the steps they have taken to eliminate slavery and trafficking from their business model.

How does this affect smaller businesses?

If you sell directly to other small or medium sized businesses, or to consumers, the Act is unlikely to affect you.

If you deal with businesses turning over more than £36 million, though, you will be part of the supply chain that they’re required to report on. This means that you’re likely to see contractual requirements in new agreements, obliging you to report on how your company operates in respect of the Act.

So what should you be doing when requests for a ‘slavery and trafficking’ statement appear in tender documents or client contracts? First, remember that these reports are simply a data collection exercise for the large company in order for them to put together their own report, required of them by law. In responding to these requests, your statement might contain:

• Information about the structure and supply chain of your organisation.
• The due diligence processes your business carries out on its supply chains.
• Details of any part of the business or supply chain where there might be a risk of human trafficking or slavery.

Companies in high-risk areas such as farming and manufacturing might want to start paying closer attention to exactly how their suppliers manage to provide such competitive rates. Much like the Bribery Act 2010, the Modern Slavery Act 2015 requires us all to take responsibility not just for what we do, but for what is done in our name.

So while your business may not be required by law to submit an annual anti-slavery and trafficking report, being in a position to do so will boost your credibility and improve relations with any large company that requests one of you. In addition, if you are seeking to grow your company, considering these points in good time will stand you in good stead for when you cross the £36 million threshold.

If you’ve been asked for a slavery and human trafficking statement as part of a tender process, or in a client contract, and are unsure how to respond, get in touch and we’ll be pleased to help.

Callum Sommerton
Devant