Section 54 of the Modern Slavery Act requiring commercial organisations, with a certain minimum turnover, to prepare a slavery and human trafficking statement for each financial year came into force yesterday, 29 October 2015.
One set of Regulations, set the minimum total turnover at £36 million. They also provide that total turnover will be determined by taking into account the global turnover of the organisation and its subsidiary undertakings. The total turnover includes the amount derived from the provision of goods and services falling within the ordinary activities of that organisation and its subsidiary undertakings, after deducting trade discounts, value added tax and other taxes.
Companies with a financial year-end from 29 October up to and including 30 March 2016 will not be required to make a slavery and human trafficking statement for the financial year 2015/16. However all organisations with a financial year ending on or after 31 March 2016 will be required to publish a slavery and human trafficking statement for the financial year 2015/16 within 6 months of their financial year-end.
The Home Office has also just published its guidance on slavery and human trafficking statements, which we are reviewing – Transparency in supply chains: a practical guide
Please contact us on how to draft your organisation’s slavery and human trafficking statement. We are finalising our precedents, including precedents for commercial agreements.