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Modern Slavery Act: new tools to support compliance

With the Act’s first deadline just two weeks away, the Washington-based Electronic Industry Citizenship Coalition (EICC) has published material to support companies to...

The UK’s Modern Slavery Act was came into force in October last year with the aim of combatting slavery and human trafficking in global supply chains.

Modern slavery is described as slavery, servitude, and forced or compulsory labour and human trafficking. The International Labour Organisation estimates that there are 21 million people in forced labour in the world today.

The Act requires any company, in any sector, carrying out business in the UK and with a total global annual turnover of £36m or more to produce a slavery and human trafficking statement for each financial year of the organisation.

Businesses with a year-end of 31 March 2016 will be the first businesses required to publish a statement for their 2015/16 financial year.

The statement, which should be signed by a senior person in the business, must set out what steps you have taken during the financial year to ensure that modern slavery is not occurring in your supply chains and in your own organisation. If you have taken no steps, you must still publish a statement to this effect.

The Act is clear that the statement must then be published on your website, with a link in a prominent place on your homepage.
Failure to comply could lead to the Secretary of State seeking an injunction through the High Court. Ignoring the injunction is punishable with an unlimited fine. More likely pressure to comply will be driven through NGO pressure – as seen in California, which was the first region to enact regulations to try and tackle modern slavery.

It’s up to you how to frame the statement, but the template published by the EICC suggests some wording and outlines what activity you are recommended to report on.

It’s an area where the EICC, which was established in 2004 by a group of electronics companies to create an industry-wide standard on social, environmental and ethical issue in the electronics industry supply chain, is very active on. It is actively working to address worker’s rights in the supply chain. For example, by requiring factories in the electronics supply chain to adopt the EICC Code of Conduct, which they are audited against, with the results shared between member companies.

Advice on steps to take if you identify or suspect modern slavery either here or abroad is outlined in the Home Office’s practical guide to help companies comply with the Act. The guide also outlines exactly what constitutes modern slavery.

You can download the EICC’s toolkit and its Q&A comparing and contrasting the UK and Californian regimes below.

EICC Modern Slavery Act toolkit (docx)

EICC Modern Slavery Act Q&A (pdf)

 

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