The Modern Slavery Act 2015 (the “Act”) introduces changes in UK law focused on increasing transparency in businesses and in supply chains, with the overall aim of combatting slavery and human trafficking.
As we previously reported, the Act requires commercial organisations of a certain scale and which are carrying on business or part of their business in the UK to disclose the steps which they have taken (if any) to ensure their business and supply chains are free from modern slavery (that is, slavery, servitude, forced and compulsory labour and human trafficking). This disclosure takes the form of an “anti-slavery and human trafficking statement”, which must be published each financial year on the organisation’s website. The first statements are required for financial years ending on or after 31 March 2016 and should be published within six months of the organisation’s financial year end. This means that the first such statements can be expected in September 2016.
Of particular interest for Irish clients is the extra-territorial reach of the Act: it applies not only to UK organisations, but also to businesses that are incorporated and headquartered outside the UK but that conduct business within the UK.
For a full briefing on the Act and to determine whether your organisation is in scope, please contact Emily Comber or Paul White or your usual William Fry contact.
Contributed by Aoife Kavanagh
