Do Suppliers Have To Check For Modern Slavery?

              

Do Suppliers Have To Check For Modern Slavery?

Suppliers, specifically those with an annual turnover exceeding £36 million and operating in the UK, are obligated to comply with the Modern Slavery Act 2015. This requirement entails the publication of an annual, board-approved statement outlining the measures taken to identify, assess, and prevent forced labour within their supply chains. Adhering to this legislation requires comprehensive due diligence practices, rigorous risk assessments, and effective staff training to foster awareness and compliance throughout the organisation.

• Who Must Comply? The Modern Slavery Act requires commercial organisations that supply goods or services to comply if they have an annual turnover of £36 million or more in the UK marketplace. This requirement is critical for ensuring responsible business practices in the context of human rights.
• What is Required? Companies must prepare and publish an annual "Transparency in Supply Chains" (TISC) statement on their corporate website. This statement serves as a public declaration of the steps taken to combat slavery and human trafficking within their operations and supply chains.
• Due Diligence Obligations: Organisations must implement a rigorous due diligence framework. This includes identifying, assessing, and managing risks associated with slavery and human trafficking that may arise in both their direct operations and supply chain activities. Such a proactive approach is essential to mitigate potential vulnerabilities.
• Public Procurement Requirements: Under the Public Procurement Notice (PPN) 009, suppliers to the public sector must demonstrate that they have taken appropriate actions to address modern slavery. Failure to comply may lead to exclusion from public contracts, especially for those found guilty of offences related to slavery or human trafficking.
• Risk Factors to Consider: Certain industries are regarded as high-risk for modern slavery, including those that are labour-intensive or reliant on migratory workforces, as well as regions historically associated with elevated risks of human trafficking. Companies should conduct risk assessments tailored to these factors.
• Utilisation of Assessment Tools: Suppliers are encouraged to leverage the Modern Slavery Assessment Tool (MSAT) to effectively identify and address potential gaps in their compliance measures. This tool can help evaluate their policies and practices against industry best practices.
• Content of the TISC Statement: The Transparency in Supply Chains statement must be comprehensive and include key information such as the organisational structure, the policies in place to combat modern slavery, the due diligence processes followed, and the results of risk assessments related to slavery and human trafficking.
• Accountability Measures: Organisations that fail to adhere to the provisions of the Modern Slavery Act risk significant reputational damage. Additionally, investors are increasingly scrutinising the robustness of companies' anti-slavery policies, underscoring the importance of transparent and effective compliance frameworks.
• Exemptions for Smaller Companies: Although smaller companies with an annual turnover of less than £36 million are not legally required to produce a TISC statement, many larger clients often request compliance from their suppliers, creating a de facto obligation for smaller entities as well.

For organisations seeking further guidance on their reporting obligations, it is advisable to consult the Modern Slavery Statement Registry, which provides detailed information and resources on compliance with the Modern Slavery Act.