Laura Clark, an employment specialist at Wilkin Chapman, advises farmers and landowners how best to ensure compliance of the Modern Slavery Act.
The Modern Slavery Act 2015 has been with us for a while now. Nevertheless, with traffickers and illegal/unlicensed gangmasters targeting the agricultural community, it remains relevant.
The Act consolidated offences relating to traffic and slavery, and requires large businesses (those with a turnover of at least £36 million) to publish a slavery and human trafficking statement every financial year.
The statement must set out what steps the organisation has taken in the previous 12 months to ensure that slavery and human trafficking is not taking place in its business or supply chains.
However, even if your own business does not meet the turnover threshold, if you supply a business that does have an obligation to produce the statement (such as large supermarkets), it is likely that these businesses will be asking you, as part of their supply chain, what processes and policies you have in place to tackle modern slavery.
You may therefore find it helpful to voluntarily produce a statement as a means of managing these requests and providing a level of assurance.
There is no prescribed form or length requirement for the statement, and it may include information about your policies in relation to slavery and human trafficking, your due diligence process, and the steps you take to assess and manage the risk.
With this in mind, even if you decide not to produce a statement, in order to provide a satisfactory response to the retailer, you should consider taking the following steps:
Carry out an exercise to map out your structure, business and supply chains;
Formulate policies in relation to modern slavery – this will involve collating current policies, identifying gaps, altering existing policies and drafting new ones as required;
Carry out a risk assessment – what are the parts of your business operations and supply chains where there is a risk of modern slavery taking place?
Carry out due diligence on your own operations and supply chains;
Train staff on modern slavery risks and impacts.
For more information or for assistance with ensuring compliance, please contact Laura on 01522 515945.