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Is Your Organisation’s Annual Turnover Over £36m? Look Out For The Modern Slavery Act…

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Is Your Organisation’s Annual Turnover Over £36m? Look Out For The Modern Slavery Act…

Is Your Organisation’s Annual Turnover Over £36m? Look Out For The Modern Slavery Act…
December 07
08:38 2015


Katie R picCatering operations in Scotland today seem far removed from the world of slavery and human trafficking, but the new Modern Slavery Act means many food and drink businesses face reporting requirements on those subjects. Katie Ruark looks at who is covered and what they must do to comply.

What’s it all about?

The Modern Slavery Act 2015 requires all commercial organisations with a worldwide turnover of at least £36m to prepare an annual slavery and human trafficking statement. The business does not have to be UK registered and companies with only small UK sales but whose worldwide turnover exceeds the threshold, must also comply with the Act.

When does it come into force, and how do companies comply?

The law was introduced in October and is already in force, which means reporting requirements are now looming for many businesses. This, in turn, could have potential consequences for their reputation. Even where it seems that a firm is far removed from the world of slavery, consideration must be made of its supply chains; and for food businesses, this can stretch across the globe.

Does the law only apply to registered companies?

No. It applies to ‘commercial organisations’, a definition which includes any corporate body, partnership, LLP or limited partnership, whether formed in the UK or abroad. If an organisation supplies goods or services in the UK, then it qualifies.

What do those affected by the Act need to do?

The compliance requirement is to publish a statement each financial year detailing what steps an organisation has taken to ensure that slavery and human trafficking have not taken place within its operations.

It is possible to do nothing and make a statement declaring that no steps have been taken, which must be published prominently on the organisation’s own website. However, for most businesses this is a commercially unattractive option; organisations face serious reputational damage if they look like they are not taking slavery seriously, even though they are not involved in any malpractice.

We want to publish a statement; what should it include?

Organisations have the freedom to decide on the exact format and content of any such statement, but it is recommended that information on the following issues is included: The business and supply chain structure; policies on modern slavery, including diligence and auditing processes to guard against slavery and human trafficking; steps taken to assess and mitigate risks; and training available to staff.

The statement must be approved by the board of directors and signed by a director or partner.

How do we put all that together?

Organisations should take the following into account:

1) Decide who has responsibility for the statement

2) Review HR practices to ensure that all employees have the right to work and are paid at least the minimum wage

3) Map out your supply chains for audit and ensure these go beyond immediate suppliers

4) Identify and prioritise any high risk areas in the chain, and ensure that targeted reviews are conducted on those suppliers

5) Draft policies on how your business will deal with slavery and human trafficking if it is detected

6) Ensure that commercial contracts impose reporting obligations on suppliers and their sub-contractors

7) Provide suitable training to staff who work with suppliers to ensure they spot any issues

8) All of the above can be detailed in the statement to show an organisation is taking slavery and human trafficking seriously.

Katie Ruark is an employment lawyer with Maclay Murray & Spens LLP and a member of the firm’s Food and Drink team.

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Catering Scotland

Catering Scotland

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