The UK Home Office has reportedly written to more than 17,000 companies to request that they register on the Modern Slavery Contact Database by November 18.
Every UK organisation with a total annual turnover of £36 million or more is required to produce a Modern Slavery statement for each financial year. As such, they are encouraged to register on the Home Office’s contact database and are required to publish an up-to-date statement by 31 March 2019, and every year thereafter.
According to government figures, only 60 per cent of in-scope companies have previously published a Modern Slavery statement. The Home Office reportedly sent letters to those organisations that it believes fall under the remit of the Modern Slavery Act.
Writing in a blog on this issue, Andrew Dale, Partner; Michael Littenberg, Partner; and Amanda Raad, Partner, all from Ropes & Gray, commented: “We recommend that companies sign up for the contact database, even though there is no legal requirement to do so. Signing up for the contact database will help companies comply with the requirements of the Modern Slavery Act and prepare their statements, since they periodically will receive guidance updates from the Home Office.”
Section 54 of the Modern Slavery Act 2015 requires certain organisations to develop a slavery and human trafficking statement each year. The slavery and human trafficking statement should set out what steps organisations have taken to ensure modern slavery is not taking place in their business or supply chains.
This guidance document provides details on:
- who is required to publish a statement
- how to write a slavery and human trafficking statement
- how to approve and publish the statement
“If a company fails to produce a statement for a particular fiscal year, the Secretary of State may seek an injunction through the High Court requiring the company to comply. If the company fails to comply with the injunction, it will be in contempt of a court order, which is punishable by an uncapped fine,” warned the trio from Ropes & Gray.
