What do we already know?
We updated you in our February 2016 Newsletter Government reforms (1): Modern slavery disclosure obligations that organisations which:
- have a worldwide turnover in excess of £36 million per year;
- supply goods or services; and
- carry on business, in whole or in part, in the United Kingdom;
would need to comply with the UK’s Modern Slavery Act 2015 (MSA) disclosure obligations.
Part of these obligations is to publish an annual slavery and human trafficking statement for each financial year (‘MSA statement’). The MSA statement is to include what steps the organisation has taken to ensure that human trafficking is not taking place in any of its supply chains or its own business.
These MSA statements are to be published on an annual basis and as soon as reasonably practicable after the end of each financial year – Government guidance suggests within six months. Organisations with a financial year ending on or after 31 March 2016 will need to comply with the above duty in respect of that financial year (i.e. 2015/16). Organisations whose next year end falls before 30 March 2016 will not be required to publish a statement until the end of the following financial year i.e. 2016/17.
This is a timely reminder that if your organisation’s financial year ends on or after 31 March 2016 your slavery and human trafficking statement is due by the end of September 2016. Those organisations with a later financial year end are free from this immediate deadline, but are best advised to be proactive now so as to ensure that you are ready to publish your MSA statement in good time next year.
If you would like support with either the preparation of your MSA statement or reviewing/amending your staff policies in light of this new requirement, please contact our Senior Solicitor, Anne-Marie Boyle at or another member of the team.