The modern slavery reporting obligation currently only applies to businesses with a UK turnover in excess of £36m. Any requirement involving turnover tends to affect supply agencies disproportionately (for example, the apprenticeship levy) because the supply workers’ wages inflate the agencies’ turnover.
However, even if your business turnover is lower than the threshold, you may soon have to publish a modern slavery statement for commercial reasons, if the Modern Slavery (Transparency in Supply Chains) Bill makes its way on to the statute books. This Bill is scheduled to have its second reading on 24 March 2017.
Modern slavery compliance already relies upon a trickle down mechanism (click here for our previous article) using commercial pressures to force compliance through the supply chain. The new Bill goes further by proposing to amend the existing legislation to extend its application to the public sector. If enacted, public sector hirers will have no option but to exclude businesses without a modern slavery statement from their supply chains, in order to comply with their obligations under the relevant public procurement legislation.
The legislation also provides that the Secretary of State is to produce an easily accessible list of all organisations required to publish a modern slavery statement. These organisations are also required to include the statement in their annual report and accounts.
Sofie Lyeklint, Legal Consultant at Lawspeed, comments: “If, or rather when, the Bill becomes law, how much business will you lose if you fail to publish a modern slavery statement? The cost of complying with the legislation needs to be weighed against the cost of lost business, not to mention the PR cost of failing to show your commitment to preventing the human misery caused by modern slavery.”
Modern slavery compliance is not simply a question of staying just the right side of the law; it is increasingly becoming a commercial necessity. Are you ready to publish your first modern slavery statement? If not, contact Lawspeed for compliance advice tailored to the recruitment industry, on 01273 236 236.
