By Stephanie Gallagher, JD
stephanie.gallagher@corporatecompliance.org
Live from the 2016 European Compliance & Ethics Institute, a presentation by Justine Currell, Deputy Head, Modern Slavery Unit, UK Home Office.
Modern slavery is a prevalent issue in today’s business climate and something that all businesses need to consider. Human trafficking and forced labor are all too prevalent, and organizations cannot turn a blind eye.
Ms. Currell shed light on the requirements of transparency in supply chain, the timeline of the UK Modern Slavery Act, challenges, the development of statutory guidance and next steps.
During the course of the discussion, Ms. Currell asked a striking question that a lot of organizations are likely asking themselves: “How can I guarantee that there is no slavery in my supply chain”? The answer is that you simply cannot make such a guarantee, elevating the need for successful implementation of policies and procedures to ensure transparency in the supply chain. Businesses must conduct due diligence and assess the risk in each of the supply chains of each product that a company provides. Here are a few key points from the presentation, the slides are available here.
The Requirements of Transparency in Supply Chains:
- Commercial organizations with a turnover of £36m or more, and providing goods or services in the UK – ANY company over £36m.
- A statement will be required for each financial year of the organization.
- The statement must contain the steps an organization has taken to prevent modern slavery in their supply chains and own organization.
- The statement must be signed by someone senior in the organization.
- The statement be published on the organizations website and a link in a prominent place on the home page.
What can be Included in a Statement?
An organizations statement may include:
- Structure of business and its supply chains
- Policies
- Due diligence
- Assess and manage risk
- KPIs
- Training
Sector collaboration is a crucial element in this issue.
Next Steps
- Go live for provision – 31 March 2016
- Central repository for statements
- Reducing burdens through international alignment
- Business event held 21 March 2016
- Home Office research project 2016 – 2018
The full PowerPoint presentation is available here.
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