In 2015, the UK government introduced the Modern Slavery Act, giving law enforcement greater tools to identify and apprehend anyone involved in enslavement or human trafficking.
You might not think that slavery is an issue that UK-based organisations need to be concerned about, but that’s unfortunately not true. The police recorded 8,730 modern slavery offences in the fiscal year 2020–2021 and have conducted more than 3,000 anti-slavery operations since the Modern Slavery Act came into effect.
Many UK-based organisations are unknowingly working with third parties that are involved in modern slavery. This most commonly occurs with forced labour on farms, in construction and in manufacturing. However, any industry that’s driven by a demand for cheap products and services is susceptible.
If the UK is to eliminate the threat, organisations must not remain silent. They must take action to identify and report any suspicious behaviour associated with slavery.
That begins with a modern slavery statement, and in this blog we outline our six-step guide to creating one.
What is a modern slavery statement?
Whenever an organisation is subject to a regulation, it should create a statement outlining its responsibilities and the steps it must take to achieve compliance.
You probably have a data protection statement, for example, and a modern slavery statement much the same. You must acknowledge the risks of modern slavery and your role in preventing it, as well as in outlining the policies that you have introduced to mitigate the threat.
Who is required to create a modern slavery statement?
Commercial organisations must publish a modern slavery statement if the following criteria are met:
- It is a ‘body corporate’ or partnerships, wherever incorporated or formed
- It carries on a business, or part of a business, in the UK
- It supplies goods or services
- It has an annual turnover of £36 million or more
Turnover encompasses the income of the organisation and subsidiary undertakings, including those operating wholly outside the UK.
What to include in a modern slavery statement
The Modern Slavery Act doesn’t contain specific guidance on what a statement should cover or how it should be structured. However, it does include examples of information that might be included and how it should be written.
For example, it is a public-facing document, which means you should provide information that you believe will be of interest to customers and other stakeholders. By contrast, you shouldn’t include confidential information about the way you operate.
As a public document, it should also be written in simple language to ensure that everyone understands the points you are making.
But what about specifics? Here are six topics that every modern slavery statement should contain:
1. Organisational structure and supply chains
Your modern slavery statement should begin with an introduction to your organisation. You should list what products or services you offer, where you are based and the locations of your customers and supply chains.
You should also note whether you have a parent company or subsidiaries. However, you don’t need to mention third parties or contractors by name.
Additionally, this section should also state your commitment to social responsibility and the eradication of slavery. It’s a good idea to reference the Modern Slavery Act by name and explain that the statement and your overall policies comply with its requirements.
2. Policies in relation to slavery and human trafficking
Next, you should state that your organisation has created policies to tackle slavery and human trafficking. You may decide to describe those policies in broad terms, but you don’t need to go into depth. This is because policies are subject to change and, if altered, would require you to rewrite your statement.
You can instead direct readers to another document where they can review your policies, whether that’s a page on your website or a physical document that they can request access to.
If you do choose to describe your policies, you should focus on objectives rather than actions. For example, you might note that you are strengthening your supplier engagement process or that you are establishing a framework that better enables people to report slavery.
3. Due diligence processes
Organisations’ biggest exposure to slavery is most likely to be in their supply chains. You should acknowledge this in your statement and note that you are performing due diligence checks on potential partners to identify suspicious activity.
4. Risk assessment and management
As with due diligence checks, you should note the importance of risk assessments and the steps you are taking to manage third parties.
Whereas the previous section looked at future or ongoing activities, you should use this section to detail steps you have already taken to identify risks. This might include on-site audits of organisations in your supply chain, interviewing employees within the supply chain and annual questionnaires for suppliers to complete.
If you haven’t yet performed any of these activities, you should use this section to state your intention to carry out tests. However, as with your discussion of policies, you should avoid listing specific examples of things you haven’t yet completed.
5. Key performance indicators
To assess the effectiveness of your anti-slavery measures, you should document KPIs (key performance indicators) such as staff training levels and the number of reported incidents of suspicious activity.
Your statement should outline what KPIs you are using. However, you aren’t required to publish your findings.
6. Training on modern slavery and trafficking
Finally, you should address the steps you are taking to educate employees on modern slavery.
This should include a summary of online and in-person training courses that your organisation provides, in addition to other activities, such as awareness campaigns and seminars.
Some organisations also provide dedicated training and resources page on their website, which employees can view to learn about modern slavery and how to report incidents.
Do your staff know the risks of modern slavery?
If you’re looking to demonstrate your organisation’s commitment to eradicating slavery and human trafficking, GRC E-Learning is here to help.
Our Modern Slavery Staff Awareness E-learning Course contains everything you need to identify and eliminate the threat of forced labour. This online course shows what modern slavery looks like in the UK and demonstrates what role individuals can play in creating a safe and equitable work environment.
The course also explains organisations requirements under the Modern Slavery Act, and explains how its requirements work alongside environmental, social and corporate governance.