If your company turns over more than £36 million (m) per annum, the law requires you to publish a slavery and human trafficking statement.
Does your company have a website? If your answer is yes, you'll need to link to your statement from your homepage.
If you’re not sure what we mean by this, open up the BrightHR homepage and scroll all the way to the bottom. In the light blue area, you’ll find the link in white text in the left-hand column: Slavery & Human Trafficking Statement.
You need something like this on your website’s homepage.
If your company doesn’t turn over £36m, you still need to be aware of the UK’s effort to tackle slavery. Many small businesses are suppliers for large companies that do turn over more than the £36m.
As a result, the large firms want to know what your stance on modern slavery and human trafficking is. If you’re a supplier, your clients need to know that you’re following the law and so it’s a great idea for you to have information such as a statement, and to have policies on anti-slavery, too.
Not got a website? Not a problem. But you still need to have a statement if your turnover is above the £36m mark. If anyone makes a written request for your statement, you must send them a hard copy within 30 days.
Modern slavery act guidance
Part 6, Section 54 of the Modern Slavery Act 2015 suggests that your modern slavery statement should include:
- Your organisation's structure.
- The type of business you're in.
- Your supply chain.
- Your due diligence processes around slavery and human trafficking in your business.
- Any part of your business and supply chain where there's a risk of slavery and human trafficking, and what steps you are taking to assess and control the risk.
- Your policies regarding slavery and human trafficking.
- Any training your business offers around slavery and human trafficking.
Explain your organisation's structure, business operations, and supply chain
Okay, so your aim here is to open your slavery and human trafficking statement in an honest way, starting with how your company goes about its business.
Use this part to make clear:
- Which countries your business operates in.
- Whether your company is part of a group.
- What other companies—if so—are in the group.
- The cities in which your company has offices.
- The cities in which the other group companies have offices.
Who controls your company or the parent group? Often, this is a board of directors. For example, here at BrightHR, we're part of the Peninsula Group of Companies. Our board of directors controls The Group.
Next up, make sure your modern slavery statement explains what it is that your business does.
As you’ll see, The Peninsula Group’s operations involve providing business and legal services to other businesses, and we do this via telephone, email, and face-to-face consultancy. We do this 24/7, 365 days a year.
Outline your due diligence
Make clear that you carry out due diligence in ensuring that slavery and human trafficking doesn’t take place within your organisation, nor within your supply chains.
If you don’t currently take any steps to prevent modern slavery, you should state this. If you’re planning to take steps in the future, state this as well.
How can you control the risk?
- Keep an up-to-date list of your suppliers and your operations. This list should include all contact details.
- Confirm on your statement that your list is up to date.
Your anti-slavery policies
First, make sure you have a whistleblowing policy. This gives your staff the chance to report any activity or behaviour they come across and believe to be illegal.
Next, make clear that you have a zero tolerance for slavery and human trafficking. You should communicate this stance to any suppliers you have, and make sure that these suppliers are not conducting any such activity.
You should include all policies in your company’s staff handbook. Send staff new copies when you update any policy, and provide further copies of any policy documentation during training sessions.
Read through BrightHR’s statement and you’ll work out what your anti-slavery policy template needs to look like.
Training for your staff
Combating human trafficking and modern day slavery in your business requires all of your staff to know what it is.
When a new hire joins your business, give them awareness training on modern slavery. This should include what one of your staff needs to do when reporting what they believe to be any wrongdoing relating to slavery or human trafficking.
Hire or nominate a group compliance manager
This employee will handle all concerns in your business to do with modern slavery. They’re responsible for handling annual reviews of your company’s efforts to combat all instances of modern slavery—in your organisation(s) and your supply chains.
Keep your statement up to date
Publish an updated statement at the end of each financial year. This statement should be live on your website no later than six months after the end of the financial year—usually, therefore, by the end of September.
Either the board or the board’s most senior director should sign off the statement each year.
Modern slavery is a serious subject—and you need to make sure you’re following the law.
When you’re a BrightHR customer, you get free employment law advice from our experts. We call them the BrightAdvice team.
So for further help with the modern slavery act requirements when writing your statement, give us a call on 0800 783 2806 and book your free demo of BrightHR today.