HR Expert: Is modern slavery just an issue for big companies?

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A client of mine has begun the process of tendering for a contract. It’s the first time they have done so for a big business, and there’s a lot of paperwork to complete. One form in particular is causing them trouble. It’s asking for a modern slavery statement, and what actions they are taking to manage the risk of modern slavery. My client is a small business, surely this doesn’t apply to them?

The answer to this is both yes and no, and it’s no wonder you and your client are questioning this. Unfortunately, modern slavery and trafficking continues to be a serious problem. Home Office statistics show that there were 3,998 potential victims of modern slavery referred to them between April to June 2023, a 16% decrease compared to the preceding quarter (4,739) and a 4% decrease from the same period in 2022 (4,161) (nevertheless, despite the decrease, these numbers remain high). Your client, it would seem, has been caught up in another organisations efforts to prevent these crimes.

In 2015, the ‘Modern Slavery Act’ was enacted, which put a requirement on eligible businesses to produce a modern slavery statement. Businesses that must do this are ones that are involved in the supply of goods or services and have an annual turnover £36 million or more. At some point in the future, the government will extend this requirement to public bodies also.

The statement must include information about their structure, business, supply chains, policies, due diligence processes, assessment and management of the risk of slavery and trafficking. It must also detail the steps it has taken during the preceding financial year to ensure slavery and trafficking is not taking place in its business or supply chain, as well as its effectiveness in preventing slavery or human trafficking in these steps.

The requirements above are likely why your client has been asked to produce their own statement, as part of the organisations obligations to report in their statement the steps it has taken to ensure modern slavery is not taking place in its supply chain.

Alternatively, it may be that the organisation offering out the tender simply wants to do as much as it can to put a stop to these crimes.

Either way, the effect is the same: whilst your client is not legally required to publish their own modern slavery statement, doing so may help them to win the tender for which they are currently bidding. And if not this one, it is likely to come up when they bid for others too.


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