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Modern Slavery Policy For Small Business: Templates & Do You Need One?

Jan 13, 2022

Sadly, Modern Slavery is a crime which the ONS states is currently taking place across the UK. Examples of modern slavery include trafficking people, forced labour and servitude. The practice sees individuals gain, either personally or commercially, from exploitation of the victim. Find stats about the prevalence of modern slavery across the UK in this government produced infographic.

Given that Modern Slavery is happening across the UK, the UK government have introduced policy working to end modern slavery. Here we look specifically at the requirement for some organisations to publish an annual Modern Slavery Statement because of the Modern Slavery Act 2015.

What is a Modern Slavery Policy?

Information relating to Modern Slavery Policy and statements on the gov.uk website defines a Modern Slavery Statement as describing ‘the steps your organisation has taken during the financial year to deal with modern slavery risks in your supply chains and your own business.’

Publishing a Modern Slavery Statement is a requirement for certain organisations set out in Section 54 (Transparency in Supply Chains) of The Modern Slavery Act 2015.

Does your small business need a Modern Slavery Policy?

Exact details about which organisations need to publish an annual Modern Slavery Policy can be found on the gov.uk website.

But government information states that a commercial organisation is required to publish an annual statement if all the criteria below apply:

  • it is a ‘body corporate’ or a partnership, wherever incorporated or formed
  • it carries on a business, or part of a business, in the UK
  • it supplies goods or services
  • it has an annual turnover of £36 million or more

It is your organisations responsibility to determine whether this requirement applies to you or not.

Your small business can also voluntarily choose to publish a statement looking at how you tackle modern slavery in your business and supply chain.

How to write a Modern Slavery Policy

There is no set outline that a Modern Slavery Policy will need to follow – organisations can decide themselves how much information to include and how to present their policy. However, statutory guidance from the Home Office suggests you cover the following 6 areas in your policy

  • Organisation structure and supply chains
  • Policies in relation to slavery and human trafficking
  • Due diligence processes
  • Risk assessment and management
  • Key performance indicators to measure effectiveness of steps being taken
  • Training on modern slavery and trafficking

Information on how to write a Modern Slavery Statement and suggested structure can be found in the guidance from the Home Office.

Be aware that the government are working on changes to the way Modern Slavery Statements must be reported and mandating the topics that must be included. Whilst it is not certain exactly when these changes will come into effect it will be something your business should keep an eye on if you are required to publish a Modern Slavery Policy.

It is vital that your business upholds its obligations under a range of rules and laws which will govern your business operations. Another area it is important not to overlook is that of insurance and having the right cover in place to protect all aspects of your business. If you have any questions about your business insurance don’t hesitate to get in touch with us on 020 8290 9080 or email us at business@anthonyjones.com.

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