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Introduction to this document

Modern slavery and human trafficking statement

Larger companies have to produce a statement setting out what they do to ensure that there is no modern slavery or human trafficking in their business or supply chain. Use our drafting notes to help put the statement together.

Which companies need a statement?

The legal requirement under s.54 Modern Slavery Act 2015 to produce a modern slavery and human trafficking statement applies to companies or partnerships with an annual turnover of £36m or more that carry on business in the UK supplying goods or services.

If a company to which the requirement applies fails to produce the statement, the Home Office can apply to court for an injunction requiring it to do so (breach of which would be contempt of court).

Smaller companies can choose to produce a statement or they might be commercially required to, e.g. as part of a tendering process or because their customers expect it.

Contents

The statement needs to set out either the steps that the business has taken during that financial year to ensure that there is no modern slavery or human trafficking in its business or supply chain, or it has to state that no such steps have been taken.

The requirement is not to do something about slavery and human trafficking, rather to record what the business does. However, by requiring businesses to be transparent, they are encouraged to take action because it is not good for a company’s reputation to report year after year that it does nothing.

As the statement relates to a financial year, it should be an evolving document. If a business is just starting to put procedures in place or takes no steps, the statement should say so. The next statement can report on the progress made.

The legislation suggests the areas that need to be covered by the statement, which are the basis for our model, but it is not a compulsory list. Every company’s statement will be different, depending on the nature of their business and supply chain, and how evolved their policies and procedures are on this issue. Not all of the headings will be relevant and some businesses will need to include more information.

  • use plain English
  • don’t go into unnecessary detail. You can link to full policies if appropriate, rather than repeat them
  • if appropriate, divide the statement into steps taken per country or region, or for different business activities.

Publication

The statement must be published on the company’s website, with a link to it in a prominent place on the homepage. If your business does not have a website, the statement must still be produced and provided to anyone who requests a copy in writing.

Take action

If you suspect modern slavery or human trafficking is taking place in the UK in relation to your business or supply chain, report this to the police. If you believe this may be an issue abroad, it should be reported to local government, law enforcement or NGOs as necessary.