The United Kingdom (UK) recently published an updated guidance on reporting obligations under section 54 of the UK Modern Slavery Act, which requires that all organizations with an annual turnover of more than 36 million pounds produce a statement outlining actions they have taken to combat modern slavery in their supply chains.
The update, released two years after the 2015 publication of the first guidance, provides information to companies on how to write a slavery and human trafficking statement, who is required to publish one, and how to get the statement approved within the company.
Given updates of this kind are not common, these revisions send a clear message to companies that the elimination of modern slavery and the promotion of human rights in the corporate sector is a key priority of the UK Government.
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The most significant changes to the guidance include:
- Smaller organizations are being encouraged to participate:. Suppliers may be asked by their customers whether they have a statement or policy on modern slavery. For this reason, the guide now encourages organizations with an annual turnover of less than 36 million pounds to produce a statement voluntarily.
- More comprehensive systems to approve statements: The updated guidance recommends having a director who sits on the board that approved the statement also sign it. Additionally, the statement should include the date on which the board officially approved it.
- Full disclosures recommended: The language of the guidance has been amended to encourage companies to cover all six suggested disclosure topics rather than cherry-pick them. Instead of saying statements “may” include certain information, the guidance suggests organisations “should aim to include” that information.
Why Do These Updates Matter to My Company?
For companies publishing modern slavery statements, the updated guidance recommends changes to the statement approval process; how annual reports are published, historically recorded, and reviewed for annual progress; and future reporting requirements (e.g. year-over-year improvements and reporting, even if company turnover falls below 36 million pounds annually).
For companies that have not yet published a statement, or for small organizations needing support in meeting their clients’ reporting requirements, Assent offers turnkey services that can help. Our Human Rights Module assists companies in performing due diligence, enabling them to demonstrate their efforts to eliminate modern slavery from their supply chain and highlight year-over-year improvements.
For more information on combating modern slavery and human trafficking in your supply chain, download the free eBook “Human Trafficking, Slavery & Your Supply Chain.” Alternatively, arrange to speak to our modern slavery experts at info@assentcompliance.com.