The Home Office launches its Modern Slavery Statement Registry
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Partner
United Arab Emirates
I am the head of the firm's International Commercial Group, and established the cyber-security team back in 2010. I am a commercial lawyer engaged in providing a full spectrum of legal support to clients for their day to day business.
Many businesses will by now have received notification from the Home Office that the Government’s modern slavery statement registry is open for business. In its response to the “Transparency on supply chains” consultation in September last year the Home Office stated its intent to require organisations that pass the Modern Slavery Act (MSA) threshold to publish their statements on a Government-run reporting service.
The formal obligation to publish is waiting on the anticipated overhaul of the MSA which has, no doubt, been delayed by the Government focus on COVID and Brexit. The Home Office letter encourages organisations to publish their statements voluntarily in the registry now and in advance of the legislative change.
The express purpose of the register is to provide a resource with public access to encourage public scrutiny and incentivise transparency from businesses over the measures they take to address modern slavery and human trafficking. The register will permit open evaluation enabling ethical decisions to be taken by consumers, investors, potential business partners and the like.
As a reminder, the threshold referred to above is that an organisation:
- is a ‘body corporate’ or a partnership, wherever incorporated or formed;
- carries on a business, or part of a business, in the UK;
- supplies goods or services; and
- has an annual turnover of £36 million or more (with the turnover aggregated with its global subsidiaries).
If you fall outside the threshold but are in the supply chain of an organisation that is required to comply with MSA you can, nevertheless, expect to be questioned on your activities to prevent modern slavery as your compliance obliged customer has a clear responsibility for policing their supply chain. That applies to organisations in the supply chain wherever they are in the world.
The Home Office letter also serves as a reminder of other expected changes when the MSA is given its overhaul. The measures to be introduced include:
- bringing the public sector within the reporting requirements of s 54 of the MSA;
- mandating the current recommended topics to be covered in a transparency statement;
- requiring publication of statements in the Government register;
- providing a single reporting deadline of30 September; and
- introducing financial penalties for non-compliance.
If you would like to know more or would like support in how you address the requirements of the Modern Slavery Act please feel free to get in touch.
To find out more, join our webinar, Modern slavery and Ethical, Social and Corporate Governance - the advantages to businesses in doing the right thing on 24th March, 9am GMT.
