Modern Slavery Act 2015: Home Office plans to audit supply chain transparency statements from 31 March 2019

The Home Office has been writing directly to chief executives of UK businesses, requesting that they publish an annual Modern Slavery Statement, or risk appearing on a published list of non-compliant organisations

The letters are addressed to 17,000 UK companies and LLPs which the Home Office believes are in scope of the requirement to publish an annual statement (regardless of whether those businesses are compliant currently). The Home Office estimates that only 60% of companies have so far complied. Further, it has found that some of those statements are poor in quality or fail to meet the basic legal requirements. 

From 31 March 2019, the Home Office plans to audit all statements, with a view to publishing a list of non-compliant organisations. Now is a good time, therefore, for all businesses to review their existing statements. 

Businesses should aim to publish the statement within 6 months of financial year end. As a minimum, all statements must be:

• updated every year
• published on the UK website of the business with a link in a prominent place on the homepage
• approved by the board with the date of board approval indicated in the statement
• signed by a director (or equivalent) with a note of the signatory's name, job title and date of signature 

The statement should set out the steps that the business has taken to ensure that slavery and human trafficking are not taking place in the business itself or in its supply chains.  Best practice is to include commentary on the following six areas:

• structure and supply chains
• policies on modern slavery
• due diligence processes
• risk assessment
• measuring effectiveness
• training for staff

Please get in touch with Katie Kinloch on the contact details below, or your usual AG contact, if you need any further information on this or other issues.