In summary, the Act requires any commercial organisation carrying on a business in the UK and with an annual turnover of £36 million or more to produce a slavery and human trafficking statement at the end of each financial year.
The statement must either set out the steps the business has taken that year to prevent modern slavery in its supply chains and business or simply confirm that it hasn’t taken any such steps. However, the government’s hope is that businesses caught by the turnover threshold will feel pressured into taking action to avoid attracting adverse publicity.
The guidance provides advice on a number of topics, including on how to write and structure the statement and the procedure to follow for approving and publishing it. Whilst it does not dictate the details that businesses should include in their statements, it does suggest that they might set out information about the due diligence processes they have in place to reduce the risk of modern slavery occurring in their businesses and supply chains.
It also advises businesses to investigate the working conditions in their supply chains with support from “expert, independent third parties” and recommends that they speak to workers as part of their investigations. This is worth noting, as members may find that working conditions on their farms will come under closer scrutiny as a result.
The guidance does stress, however, that all due diligence processes adopted by those caught by the turnover threshold should be proportionate to the risk presented.
This is in line with the consultation response submitted by the NFU earlier this year, which called for the measure to be a targeted and proportionate means of addressing modern slavery, rather than an unnecessary burdensome catch all provision.