The UK Modern Slavery Act became law on the 26th March 2015. It aims to prevent all forms of labour exploitation, and to increase transparency of labour practices in supply chains. Under the additional clause (clause 6) added retrospectively to the Act, it also requires eligible commercial organisations (over £36m turnover per annum) to make a public statement as to the actions they have taken to detect and deal with forced labour and trafficking in their supply chains – the ‘Transparency in Supply Chains obligation’.
There is clear direction from HM Government, in the guidance issued with the Act, that eligible organisations will commit time and resources to understanding, and working to combat, the issue of slavery in its supply chain. Additional specific direction came from the then Home Secretary Teresa May that organisations must increase their supply chain accountability.
Under the Act, eligible organisations must publish an annual statement in line with their financial year end. All eligible organisations must have published by 30 June 2017. All eligible organisations must then publish annually.
The scope of the obligation is to state the steps the organisation has taken (or state that no steps have been taken), to detect and deal with forced labour or human trafficking in the supply chain. Whilst a non-compliance statement was deemed acceptable for the first year of publication, there is an expectation of evidenced year on year improvement in the actions carried out within the organisation to detect and deal with forced labour or human trafficking in the supply chain.
For clarity, ‘supply chain’ has a much wider implication than just the purchasing of goods and services carried out, by procurement teams. It also includes the supply chain of the carrying out of its own business.
As ‘supply chain’ also includes the carrying out of its own business, HR recruitment for permanent staff, bank and agency staff, and other bought in medical and non-medical consultants falls within the scope of the Act.
SWFT will be identifying which policies require the addition of appropriate reference to the Modern Slavery Act and its requirements. These will then be updated in line with policy ratification process for approval if required. The Trust’s e-learning module on Equality and Diversity will be updated as necessary to include training on the awareness of human trafficking and forced labour, and provide advice on what to do if this is suspected. The module will be mandatory for all new staff and refresher training, and participation can be monitored and reported on if required.