With the recent introduction of the requirement under the Modern Slavery Act 2015 for companies with a minimum turnover of £36 million to publish an annual slavery and human trafficking statement, the issue of modern slavery is gaining ever more awareness.
The issue has gained considerable publicity in the recent week, with the High Court holding a UK company liable (for the first time) for victims of trafficking. In the recent case, DJ Houghton Chicken Catching Services Ltd was found civilly liable for, among other things, failing to pay six Lithuanian workers the agricultural minimum wage and depriving the workers of facilities to wash, rest, eat and drink. The amount of compensation is yet to be determined, however it is thought it could be considerable.
Whilst the requirement to publish a modern slavery statement only applies to those companies meeting the minimum turnover threshold, the guidance to the Act suggests that a statement is included concerning those parts of a company’s business and supply chains where there is a risk of slavery and/or human trafficking taking place and the steps that company has taken to assess and manage any such risks. Accordingly, it is likely that the larger companies will require its suppliers to produce a statement regarding its policies and procedures to ensure that neither its own business nor its suppliers are engaging in any form of slavery and/or human trafficking.
Should you have any questions regarding the requirement to publish a slavery and human trafficking statement and/or in relation to any other issues concerning the requirements of the Modern Slavery Act, please do not hesitate to contact a member of our employment team: