The Modern Slavery Act 2015 (Commencement No. 3 and Transitional Provision) Regulations 2015 have been made. They confirm that Section 54 relating to transparency in the supply chain will be in force on 29 October 2015.
The UK Modern Slavery Act 2015 introduces a new area of compliance for commercial organisations.
Under the Act commercial organisations, supplying goods or services, with a turnover of £36 million or above will have to publish an annual statement setting out what they are doing to ensure that there is no modern slavery both in their own organization and in any of their supply chains. The turnover calculation includes those organisations that are only carrying out part of their business in the UK, as well as including the turnover of foreign subsidiaries, so supply chains can be complex particularly as services are caught as well as goods.
Although the provisions come into force on Thursday, it is important for organisations not to panic. Transitional provisions provide that organisations with a financial year-end from 29 October up to and including 30 March 2016 will not be required to make a slavery and human trafficking statement for the financial year 2015/16.
Organisations with a financial year-end of 31 March 2016 will be required to publish a slavery and human trafficking statement for the financial year 2015/16 within 6 months of their financial year-end.
For general guidance on the steps to take now please refer to our previous update.
Watch this space: statutory guidance accompanying the provisions is expected to issue shortly.
If you are in any doubt about how the provisions apply to your business or supply chain, please contact Ron Reid on 03700 86 8471 or Jos Kirkwood on 03700 86 8347.
This document is for informational purposes only and does not constitute legal advice. It is recommended that specific professional advice is sought before acting on any of the information given.