The Act applies to all organisations with a turnover or group turnover - that is, the total turnover of a company and its subsidiaries - of £36 million or more which are either incorporated in the UK or carry on a business in the UK.
A commercial organisation is required to comply with the reporting requirements if:
The term "carries on a business" is not defined in the Act. Guidance issued by the Home Office (here) suggests that a "common sense approach" should be applied to determine if a company carries on a business in the UK. The guidance specifies that it does not matter if the organisation pursues primarily charitable or educational aims or purely public functions. The organisation will be caught if it engages in commercial activities and has a total turnover of £36m - irrespective of the purpose for which profits are made.
The statement has to set out the steps that an organisation has taken during that financial year to ensure that slavery and human trafficking are not taking place:
What needs to be included in the statement?
The Act contains a list of information that may be included within an organisation's statement, as follows:
Who must approve the statement?
In the case of a charitable company then its anti-slavery statement must be approved by the board of directors/trustees and be signed by a director.
Where should the statement be published?
The anti-slavery statement must be published in a prominent location on the organisation's website, with a link to the anti-slavery statement on the organisation's homepage.
There is a toolkit available which includes:
Please contact Edwina Turner or Sarah Greenhalgh.
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