Modern Slavery Act Compliance

Overview

The UK Modern Slavery Act 2015 requires organizations to report on the risks of modern slavery in their operations and supply chains. It's a landmark law that has driven significant improvements in supply chain transparency.

Who Must Comply?

UK Entities

• Commercial organizations operating in UK
• Turnover of £36M+ annually
• Must publish annual statement

Non-UK Companies

• Supply goods/services to UK
• Must comply if operating in UK

Statement Requirements

Mandatory Criteria

1. Organization structure and supply chains
2. Policies in relation to modern slavery
3. Due diligence processes
4. Risk assessment
5. Training for staff

Recommended Criteria

• Relevant metrics
• Goals and performance indicators
• Consultation with stakeholders

What Is Modern Slavery?

Definitions

• Forced labor: Compulsory work through coercion
• Human trafficking: Recruitment/transportation through force
• Debt bondage: Work to repay debt
• Child labor: Harmful work by children

Signs

• Passport retention
• Restriction of movement
• Debt bondage
• Physical violence
• Withheld wages

Compliance Steps

Step 1: Map Supply Chain

• Identify direct suppliers
• Map sub-tier (where possible)
• Identify high-risk areas

Step 2: Assess Risk

• Country/industry risk
• Product/service risk
• Supplier risk

Step 3: Develop Policies

• Ethical sourcing policy
• Supplier code of conduct
• Whistleblowing procedures

Step 4: Implement Due Diligence

• Pre-qualification
• Contractual clauses
• Ongoing monitoring

Step 5: Train Staff

• Awareness training
• Procurement teams
• Due diligence processes

Step 6: Report

• Annual statement
• Board approval
• Public publication

International Expansion

Similar Laws

• Australia: Modern Slavery Act 2018
• California: Transparency in Supply Chains Act
• Canada: Fighting Against Forced Labour Act
• EU: Proposed directive

Compliance Overlap

• Single statement often covers multiple laws
• Align requirements
• Document approach

Practical Guidance

For Companies

1. Start with mapping: Understand supply chain
2. Develop policy: Clear expectations
3. Engage suppliers: Build capacity
4. Monitor: Regular assessments
5. Report: Publish annually

Common Mistakes

• Generic statements
• No board approval
• No consultation
• No performance tracking

Key Takeaways

• Required for UK organizations >£36M turnover
• Statement must be published annually
• Must cover operations and supply chains
• Increasing enforcement globally
• Due diligence essential
• Good practice even where not required