The UK Modern Slavery Act 2015 has left many organisations in the UK wondering how best to tackle their anti-slavery supply chain statement.

Since October 2015, under Section 54 commercial organisations with a turnover of more than £36m must produce a ‘slavery and human trafficking’ statement for each financial year, setting out what they have done to ensure there is no modern slavery in their business or supply chains. The government has issued guidance but little in the way of a template to follow; though the legislation does set out the following:

A slavery and human trafficking statement for a financial year is—

  • (a) a statement of the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place—
    • (i) in any of its supply chains, and
    • (ii) in any part of its own business, or
  • (b) a statement that the organisation has taken no such steps.

An organisation’s slavery and human trafficking statement may include information about—

  • (a) the organisation’s structure, its business and its supply chains;
  • (b) its policies in relation to slavery and human trafficking;
  • (c) its due diligence processes in relation to slavery and human trafficking in its business and supply chains;
  • (d) the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk;
  • (e) 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;
  • (f) the training about slavery and human trafficking available to its staff.

It is notable that organisations can say no steps have yet been taken, but this is unlikely to show the organisation in a good light, and should not be considered beyond the first year, where some leniency may apply.

It’s also worth remembering that organisations have to give the statement a prominent position on their homepage, so customers and competitors will be looking out for it.

Some organisations below the £36m t/o threshold have elected to publish a statement anyway, in order to emphasise their efforts in this area. Of course many of them will be suppliers to those larger organisations, so they are likely to come under scrutiny from their customers anyway, as they attempt to prove their own case.

What organisations have done about the Act and what they have said?

Vinci Construction UK is a construction and facilities company and part of a group with £2bn turnover a year, employing around 9,000 people.

It says, where appropriate, its supply chain should be registered with Constructionline, or have completed the company’s pre-qualification process.

Its statement adds that the company will: “carry out audits on supply-chain partners that incorporate physical audits of suppliers’ records pertaining to workers on our projects, to ensure that they are compliant with our requirements and expectations. Suppliers employing or providing non-UK nationals undergo appropriate investigation to understand their recruitment methods and their management of permits and working visas.”

Millennium & Copthorne Hotels is a leading global hospitality management and real estate group, with 120 hotels in 79 businesses around the world.

It has several business models – for example, it own hotels operated by third parties, such as Hilton and AccorHotels, while also franchising its brands for use by third-party hotel owners who, in turn, operate their hotels. So, as its statement notes, it has “varying degrees of control over operational policies and procedures and the review and selection of suppliers”.

While the hotel group has many safeguards in place, it says: “We do not believe an organisation can ‘achieve compliance’ in this important area and will continue to look for ways to improve upon our existing policies and procedures.” Unusually, it also invites comment from employees and other stakeholders.

London Universities Purchasing Consortium (LUPC) was the first UK public sector consortium to publish a slavery and human trafficking statement.

A non-profit professional buying organisation owned by its members, LUPC made the move despite its annual turnover being below the legal £36m threshold. As its members spend around £200m annually through supply agreements, it was felt it warranted a statement.

In it, LUPC identified the principal risk categories as office supplies, laboratory consumables, ICT equipment and some estates services, such as cleaning and security services.

LUPC said many suppliers in higher risk categories have committed to the Base Code of the Ethical Trading Initiative, and it was trying to persuade its remaining suppliers in these categories to join them.

There are plenty more examples including Reynolds Catering Supplies, John Lewis Partnership, Haymarket Media Group, Pendragon, AB InBev and Gleadell Agriculture.

Simply googling the organisations name and ‘Modern Slavery’ on any of these will show that there is a variety of different approaches.

If you need further help a register has been set up by CIPS and anti-trafficking charity Unseen to host a searchable database whereby you can find details of what companies are doing to combat slavery in their supply chains. This site can be found at tiscreport.org.

Feel free to contact us for more information.