The Modern Slavery Act 2015, which came into force on 29 October 2015, is a piece of legislation that has mostly gone unnoticed by the majority of the financial services industry.
RWA has recently received several enquiries from clients asking if they need to take any action regarding the legislation, as they have been asked to supply a copy of the firm’s modern slavery statement by insurers.
While the financial services industry is not immune from the perils of modern slavery, with 'linger chains' and outsourcing overseas, it is not an issue that is necessarily high-risk and the need to produce a statement is only a requirement in specific circumstances.
You only have to produce a statement if you are a commercial organisation with an annual turnover of more than £36 million and are involved in the supply of goods and services, or conducting business (i.e. trade or profession) or part of its business in the UK. If you meet these criteria you are covered by section 54 of the Act and require the statement.
The Act will also cover partnerships, group companies and those with a non-UK based parent organisation.
Statements must be updated each fiscal year and must be publically accessible on your website.
Turnover is defined as the amount derived from the provision of goods and services as part of the ordinary activities of the organisation.
For completeness, such a statement would have to include a range of key matters, including but not limited to:
- Organisational structure
- Supply chains
- Staff training
- Details of slavery and human trafficking policies
- Methodologies for measuring and recording that slavery and human trafficking has not taken/is not taking place in its business or supply chains
- Supply chain slavery and human trafficking due diligence processes
Such statements have to be approved by a director or partner.
Many insurers now have statements on their websites and so do many household names such as Amazon. Feel free to refer to these to shed more light on the subject.