Anti-Slavery Laws: Guidance about Transparency in Supply Chains

When anti-slavery legislation came into force with the implementation of the Modern Slavery Act 2015, it represented a major legal development for business organisations. Updated statutory guidance for businesses subject to UK anti-slavery laws has now been published with a focus on transparency in business supply chains.

In Government Guidance: Transparency in Supply Chains, the statutory guidelines for organisations on addressing anti-slavery issues in the context of their supply chains has been updated. In this practical guidance, the Government states that the challenge for business organisations is “to take serious and effective steps to identify and root out contemporary slavery which can exist in any supply chain, in any industry”. The aim of the guidance is to help businesses with their compliance, ie. ensuring slavery and human trafficking are not found in their business or supply chains.

The updated guidance is lengthy, and includes a useful overview of the law, as well as helpful appendices and additional resources which businesses will find useful. Notably, it includes new definitions relating to ‘child labour’, which is defined as children below 12 years working in any economic activities; those aged 12 - 14 who are engaged in more than light work; and all children engaged in the worst forms of child labour.

The 2015 Act requires all businesses operating in the UK (or supplying UK customers) which provide goods or services which have a turnover of at least £36 million to tackle the issue of slavery – including in their supply chains. This means publishing a slavery and human trafficking statement on their websites under section 54 which sets out the steps they have taken to ensure modern slavery is not taking place in their business and supply chains. If no steps have been taken, their statement should say so. If the business does not have a website, it must provide a statement within 30 days to anyone who asks in writing to see it.

The Anti-Slavery Statement
The guidelines include advice on:

• who must publish a statement
• how to write a statement
• how to approve and publish the statement

Note that the guidelines also give firmer recommendations about what information should be included in these statements, and set out higher expectations relating to human rights due diligence.

Businesses will find the case studies in the guidance useful. Organisations subject to the legislation will welcome this updated guidance a timely reminder of the necessity for transparency in their supply chains to minimise the risk of modern day slavery in business. All businesses must be vigilant and continue to improve in this area.

You can read the guidance in full here.



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