Time Is Running Out to Meet Your UK Modern Slavery Act Requirements

Time Is Running Out to Meet Your UK Modern Slavery Act Requirements

The grace period to comply with the now six-month old UK Modern Slavery Act 2015 is over.

Although the Act came into effect on October 29, 2015, many organizations were not in a position to comply with the law immediately. Companies whose fiscal year ended prior to March 31, 2016, are not required to publish a statement for the 2015 financial year.

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However, companies with fiscal years ending March 31, 2016, or later will be required to publish their compliance statement for 2015, within six months of the year-end date. These organizations will be the first required to publish statements under the Act.

Under the UK Modern Slavery Act, in-scope companies must produce a slavery and human trafficking statement each fiscal year. The statement must disclose the company’s efforts to ensure their supply chains are free from slavery and human trafficking. Some suggested inclusions are:

  • The organization’s structure, its business and its supply chains
  • Its policies in relation to slavery and human trafficking
  • Its due diligence processes regarding slavery and human trafficking in its business and supply chains
  • The parts of its business and supply chains vulnerable to slavery and human trafficking, and the steps it has taken to assess and manage that vulnerability
  • Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate
  • Slavery and human trafficking training available to its staff

These statements can only include activities undertaken within the previous fiscal year, although companies may want to also set out their targets and plans for the coming years in their statement. If a company’s fiscal year ended on March 31, 2016, only activities taken between April 1, 2015 and March 31st, 2016 can be included.

Once created, companies must publish their slavery and human trafficking statements on their website and host a link to the statement in a prominent location on its homepage. Companies without a website must submit a written statement within 30 days of receiving a request for that information.


What Does This Mean for Your Company?

The CORE Coalition, a UK-based civil society network, put out a report analyzing 75 early slavery and human trafficking statements.

Of the statements reviewed, only 22 met the minimum legal standards set forth in the UK Modern Slavery Act. Of those, only nine met both the legal requirements and addressed all of the suggested criteria.

The results of this analysis suggest many companies still have a long way to go to achieve full compliance with this law. For those among the first wave of companies to comply, there is still time to review compliance statements and ensure all of the requirements are met.

However, if a company’s fiscal year-end was on March 31, 2016, any additional activities taken to comply with the UK Modern Slavery Act will be irrelevant until the following reporting year. The same is not true for companies with fiscal year-ends that have yet to arrive.


Complying with the Act

There is still time for many organizations to meet the UK Modern Slavery Act’s legal requirements, as well as to undertake best practices.

Assent Compliance offers a third-party software solution designed to help companies plan, implement and execute an industry-leading anti-human trafficking and modern slavery compliance program. With a team of regulatory experts available to consult on the Act’s legal requirements, companies will be better prepared to comply with the new law.

Working with Assent allows companies to list this partnership on their statement, along with the compliance activities the two organizations will undertake together. These activities include supply chain due diligence, anti-human trafficking and modern slavery corporate policy review, risk assessments and mitigation, training and more.

For more information on the UK Modern Slavery Act and how Assent can help your company comply with the law, contact our regulatory experts at info@assentcompliance.com.

To learn more about the UK Modern Slavery Act 2015 and other human trafficking and modern slavery regulations, read our eBook Human Trafficking, Slavery & Your Supply Chain.

Are you unsure whether or not your company is in scope of the UK Modern Slavery Act, or other anti-human trafficking and modern slavery regulations? Find out now with the help of our Human Trafficking & Slavery Scoping Guide. Click here to download the guide.

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The UK Modern Slavery Act: 5 Things You Need to Know

The UK Modern Slavery Act: 4 More Things You Need to Know

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