Eliminating modern slavery: what steps should your business take?

26 July 2018

“Modern slavery significant problem in NI”…“PSNI receive 31 trafficking and modern slavery cases”…“People being kept as human slaves on a daily basis across Northern Ireland”. These are just a few headlines from recent months which spell out very clearly that, despite its supposed abolition almost 200 years ago, slavery is alive and well today. It was against this background that the government introduced the Modern Slavery Act in 2015. But what does all this talk of slavery and a Modern Slavery Act possibly mean in real terms for Northern Ireland businesses?

Eliminating modern slavery: what steps should your business take?

The enactment of the Modern Slavery Act means that businesses with a total global turnover of £36 million or greater must publish a statement confirming that they have taken steps to ensure that no form of modern slavery or servitude is taking place within their business or supply chain. Although there is no pro forma or prescribed style, statements must be signed by key individuals within the organisation (such as directors) and made available prominently on the company’s website.

Given our SME economy, the reality is that the £36 million threshold is unlikely to be one of concern for the vast majority of businesses operating in Northern Ireland. However, this doesn’t mean our eclectic mix of smaller employers, producers and suppliers can afford to turn a blind eye. Any business, particularly those providing goods or services to larger organisations, may well be asked to provide a statement or policy setting out their approach to tackling modern slavery. In fact, the directly affected organisations, in complying with their statutory obligations, are under a duty to conduct due diligence in their supply chain too.

Given that next Monday, 30 July is World Day against Trafficking in Persons, there is no time like the present to have a think about whether your business could benefit from drawing up a modern slavery statement – you never know when you might be asked for one.

Bearing this in mind, these are just a few pointers on what you might wish to include in any such policy/statement:

  • A summary of the steps your business has taken to ensure that slavery/human trafficking hasn’t infested its labour/supply chain;
  • Details of any policies/training geared towards eliminating modern slavery from the business itself; and
  • Information on any “whistleblowing” policies/procedures under which employees or customers can confidentially raise concerns over suspected forced labour.

Smaller businesses don’t necessarily need to publish any such statement publicly or on their website, but producing it voluntarily to would-be customers and clients could provide a level of assurance and create the impression of a business which is on its toes and alert to potential legal obligations.

John Kelly is a solicitor specialising in employment law at Worthingtons. For further information on this topic or for assistance with any employment law query, John can be contacted by telephone on 028 90434015 or by email at johnk@worthigntonslaw.co.uk.

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