Slavery

UK: UK Modern Slavery Act Disclosure Requirements In Effect

The UK Modern Slavery Act, which was signed into law on March 26, 2015, is now in effect.  In addition to setting forth muscular penalties and enforcement mechanisms to address practices including "slavery, servitude,  and forced or compulsory labour" and "human trafficking", the Act requires qualifying commercial organizations to publically disclose what actions they have taken to eliminate prohibited practices from their businesses and supply chains—or to disclose that they have taken no action.  According to guidance published by Home Secretary Rt Hon Teresa May MP, the disclosure requirement is intended to "require businesses to be transparent about what they are doing and will increase competition to drive up standards" in this area of human rights.

The Act's disclosure requirement applies to every organization carrying on a business within the UK with a "total annual turnover" or total revenue of Ј36 million or more, including any organization that is part of a "group structure" that meets these requirements. Starting with businesses whose fiscal years end on March 31, 2016 or later, all organizations must submit these "Modern Slavery Act Transparency Statements" to the Secretary of State annually at the end of their fiscal year. While this disclosure requirement does not "mean that the organisation in question must guarantee that the entire supply chain is slavery free," it does require that these statements "should capture all the actions [the company] has taken," including where the organization has taken no steps.