On 11 March 2021, the Home Office announced the launch of its new registry for slavery statements. Whilst at the moment the registry is only voluntary, in due course it will become mandatory for organisations which are legally required to produce a statement, to submit that statement to the registry. Large organisations are therefore encouraged to submit their statements online.
Under Section 54 of the Modern Slavery Act 2015 (‘MSA’), large businesses are required to produce a statement each year setting out the steps that they have taken to ensure that their business and supply chains are slavery free, or a statement that they have taken no steps to do this.
A commercial organisation must publish an annual modern slavery statement if all of the following apply:
- It is a body corporate or a partnership, wherever incorporated or formed.
- It carried on business, or part of a business, in the UK.
- It supplies goods or services.
- It has an annual turnover of £36million or more.
Where an organisation does not meet the section 54 requirements (for example, if it is a smaller organisation with turnover under £36million), it can still choose to voluntarily produce a “slavery and human trafficking statement”. Furthermore, suppliers may ask smaller organisations if they have such a statement or policy, particularly if they are bidding for contracts with larger businesses above the £36million turnover threshold. In this case it may therefore help smaller organisations to voluntarily produce such a statement, in order for it to manage those requests and provide a level of assurance to their customers.
Those organisations who wish to upload their statements to the registry, should do so by visiting https://modern-slavery-statement-registry.service.gov.uk/ for further information.
The intention is that the online registry will make it easier for organisations to show that they are complying with the MSA and it will also allow any member of the public, or other organisations to search for statements.
If you need any advice or assistance on the need for a modern slavery statement or the contents of them, then please contact a member of our corporate and commercial team on 01524 548494 or 01228 552600.