This is an example document and should be adapted to suit your circumstances.
Law relating to this document
Leading statutory authority
Modern Slavery Act 2015
Transparency in supply chains etc: a practical guide
Stronger together initiative
Ethical trading initiative
Gangmasters Licensing Authority
Global slavery index
Business and human rights resource centre
International Labour Organisation: forced labour, human trafficking and slavery
Guiding principles on business and human rights: implementing the United Nations "protect, respect and remedy" framework
Section 54 of the Modern Slavery Act 2015 requires commercial organisations to prepare a slavery and human trafficking statement for each financial year of the organisation. The statement must set out the steps that the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business. If the organisation has not taken any such steps, it must still publish a statement to that effect.
Although s.54 of the Modern Slavery Act 2015 was brought into force on 29 October 2015, the requirement to prepare a slavery and human trafficking statement applies only to financial years ending on or after 31 March 2016. This means that an organisation with a financial year running from 1 April to 31 March must publish a statement for its 2015/16 financial year.
Section 54 states that the organisation's statement may include information on:
the organisation's structure, business and supply chains (covered in Organisational structure and supply chains in this model statement);
its policies in relation to slavery and human trafficking (covered in Relevant policies);
its due diligence processes in relation to slavery and human trafficking in its business and supply chains (covered in Due diligence);
the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps that it has taken to assess and manage that risk (covered in Organisational structure and supply chains);
its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate (covered in Performance indicators); and
the training about slavery and human trafficking available to its staff (covered in Training).
These headings are recommendations only and organisations may choose to set out their statement differently.
The duty applies to commercial organisations with a total turnover of at least £36 million per year. "Commercial organisations" that are covered by the duty are body corporates and partnerships that carry on a business, or part of a business, in the UK, supplying goods or services. See FAQs > Which employers are required to publish a slavery and human trafficking statement? for more details.
The slavery and human trafficking statement must be approved at the highest level of an organisation, for example by the board of directors, and signed by a director if the organisation is a body corporate, or approved by the members and signed by a designated member if the organisation is a limited liability partnership.
The organisation must publish the slavery and human trafficking statement on its website and include a link to the statement in a prominent place on the homepage. If it does not have a website, it must provide a copy of the slavery and human trafficking statement within 30 days of any written request for one.
HR departments are unlikely to produce their organisation's modern slavery and human trafficking statement in isolation. Other areas of the business should also be heavily involved in the statement's preparation, including the legal, ethical trade, risk management, procurement, and facilities management departments.
As modern slavery and human trafficking statements must be available to the public, they should be written in simple language that is easily understood. Organisations should avoid including jargon that is sector-specific, or used only within the organisation.
A modern slavery and human trafficking statement does not have to set out the text of every document to which it refers. It is sufficient for the statement to provide links to supporting documentation, such as policies.
Organisations should build on their modern slavery and human trafficking statements each year and statements should evolve and improve over time.
This model modern slavery and human trafficking statement is an example only to provide a starting point for employers and should be adapted to represent accurately steps your organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in supply chains. The steps that your organisation should take will depend on many factors, including the organisation's sector, its structure and supply chains, and countries in which its suppliers work.
Section 54 of the Modern Slavery Act 2015 and the accompanying statutory guidance is not prescriptive about what organisations should include in their slavery and human trafficking statement. However, the statutory guidance says that organisations should include in the statement all the steps that they have taken.
If an organisation has taken no steps to ensure that modern slavery is not taking place in its business and supply chains, its slavery and human trafficking statement must state this.
If an organisation to which the requirement applies fails to produce a slavery and human trafficking statement for a particular financial year, the Secretary of State may bring proceedings in the High Court requiring the organisation to do so.