I’m getting a lot of calls from recruitment agencies with questions about a “Modern Slavery Statement” as this subject is appearing more and more in tenders. This is because companies with a turnover of over £36 million per annum are now obliged to publish a modern slavery statement under the Modern Slavery Act 2015 and this of course applies to our clients. The Act specifically demands that the statement must include “the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business”.
So as you can see this statement needs to cover not only their own approach to preventing slavery and human trafficking, but how they ensure that their suppliers (yup – that’s us!) and indeed the suppliers of suppliers right down the chain meet their own high standards in this area.
With the exception of the agencies that are covered by the Gangmasters Licensing Act, most recruitment companies that I’ve spoken to feel that the risks associated with modern slavery and human trafficking don’t really apply to them. After all – surely modern slavery and human trafficking are much more prevalent overseas and this doesn’t really relate to the UK does it?
Unfortunately not! The British Government estimates that there are at least 13,000 people in modern slavery in the UK today. In 2015, 3,266 people in the UK were identified as potential victims of slavery and human trafficking – this is an increase of 40% on the 2014 figures. The most common countries of origin were from Albania, Nigeria and Vietnam. However there were also a significant number of British nationals referred as potential victims, which put the UK as the fifth most common country of origin for referrals. So, as you can see modern slavery and human trafficking are rather closer to home than many of us would like to think!
So what does the law say on this subject?
Section 54 of the Modern Slavery Act 2015 requires employers to produce a Modern Slavery Statement and publish this on their website with a link to it on the home page. The Government has not been prescriptive on what must be contained; however, Section 54 suggests that this statement might include information on:
- The company’s structure, business and supply chains.
- Its policies in relation to slavery & human trafficking.
- Its due diligence processes in relation to slavery and human trafficking in its business and supply chains.
- The parts of its business and supply chains where there is a risk o slavery and human trafficking taking place, and the steps that it has taken to assess and manage that risk.
- Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business of supply chains, measured against such performance indicators as it considers appropriate.
- The training about slavery and human trafficking available to its staff.
Many tenders are now asking for a Modern Slavery and Human Trafficking statement or company policy. Simply saying “no” or “not applicable” in response to these questions will at best make it appear that you are not diligent when it comes to legislation, ethical trading and best practice and at worst make your tender non-compliant, losing you the business.
We recommend that this is an area that all recruitment agencies look at; and the time to research and write a statement and policy is not when you are up against a tender deadline!
So if you need more information on this subject or you are interested in our new Modern Slavery & Human Trafficking Policy Template, please call us or check out our new Modern Slavery Policy Template now.
