Modern Slavery Act & Partnership Companies

The Modern Slavery Act sets out a range of measures on how modern slavery and human trafficking is dealt with in the UK. It came into force on 29 October 2015 and although it may not seem directly relevant to businesses, there are areas for companies to consider.

Does your business need to comply?

If your business has a global turnover of over £36m and operates a business, or part of a business, anywhere in the UK then you will need to comply.

What are the requirements?

All obligated businesses must publish a Slavery & Human Trafficking Statement for each financial year.

This statement should disclose either:

  • the steps your business has taken during the financial year to ensure that slavery and human trafficking is not taking place in your own operations and supply chain; or
  • that you have taken no such steps, although this may introduce additional reputational risks.

What should be included in the statement?

There are six areas which should be considered when writing a statement:

  • Your business structure and a summary of its operations/supply chains;
  • Relevant policies to slavery and human trafficking e.g. supply chain or human resources policies;
  • Due diligence processes in relation to slavery and human trafficking in your business and supply chains;
  • The parts of your business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps you have taken to assess and manage that risk;
  • The effectiveness of your approaches in ensuring that slavery and human trafficking is not taking place in your business or supply chains; and
  • Training of key employees about slavery and human trafficking.

Who should approve the statement?

The person required to approve the statement depends on your company’s corporate body:

  • Limited Liability Partnership (LLP) - must be approved by the members and signed by a designated member.
  • A corporate body, other than an LLP - must be approved by the board of directors (or equivalent) and signed by a director (or equivalent).
  • Limited Partnership - must be signed by a general partner.
  • Any other kind of partnership - must be signed by a partner.

Where should you publish the statement?

You should publish the statement on your website with a prominent link to it on your homepage.

What is the timeline for action?

Any business with a financial year ending on or after 31 March 2016 will need to publish a Slavery & Human Trafficking Statement ‘as soon as reasonably practicable’ after the end of each financial year for which they are producing the statement.

While the Act does not set a deadline for this, businesses should look to publish their statements within six months.

What happens if you do not comply?

The Secretary of State may force you to disclose the statement through an injunction. However, the Government is hopeful that the pressure from stakeholders will encourage businesses to comply without the need to bring civil proceedings in the High Court.

For confirmation of whether your business will need to comply, or assistance with the drafting or publishing of your statement, please contact Louise on the details below.

For more information, contact:

Louise Morriss, BFP ACA FCCA: Managing Director
London Office
+44 (0)20 7430 5892 /