The UK Home Office has recently issued letters to organisations which it believes are legally required to publish Slavery and Human Trafficking Statements under the Modern Slavery Act 2015 (MSA 2015).
MSA 2015 places a “transparency” responsibility on certain businesses to issue a public statement every year showing what steps it has taken to ensure that slavery and human trafficking is not taking place in any part of its business or in its supply chains. If no such steps were taken then the organisation must make that clear in its statement. Organisations will be caught by the obligation to publish a statement if they (1) supply goods or services in any sector; (2) carry out any part of their business in the UK (regardless of place of incorporation) and (3) have an annual total turnover of at least £36million, which is to be arrived at by totaling the turnover of the organisation and the turnover of any of its subsidiary undertakings.
There are guidance materials on what the UK Government considers to be best practice. If your business has been contacted by the UK Home Office then we recommend assessing which organisations within your corporate group meet the MSA 2015 qualifying criteria for publication of a slavery and human trafficking statement, and whether any existing statements are legally compliant.
For further information please see our recent Modern Slavery Act Statements Compliance Update, or if you would like advice on responding to the UK Home Office then please get in touch with Paul Marshall or Adam McCabe.
On December 12, 2018