The Modern Slavery Act 2015 has introduced the need for commercial organisations with an annual turnover of at least £36 million to make such a statement widely available for every financial year which ends on or after 31 March 2016. Given the unfamiliar territory, there are a few things for HR professionals to consider to ensure they get this important statement right.
The why, who, and how
Always begin with an introduction that underlines your commitment to ensuring that there are no modern slavery practices in your organisation. Following on from this, outline details of the supply chains used by your company and the countries or regions in which they operate.
In addition to this, it is useful to include links to supporting policies from your organisation that detail procedures in place to monitor and identify risks and issues relating to modern slavery.
You should also include who in your organisation has responsibility for making sure that there are anti-slavery initiatives in place and that all procedures are followed. Anti-slavery initiatives should be in place and include practices such as risk assessment and staff training.
By extension of this, outline what due diligence is carried in relation to suppliers in order to comply with policies. Here employers can identify areas of high risk and take steps against suppliers that do not meet the required standards as laid out in the Modern Slavery Act. It can also be mentioned if supplier relationships are terminated as a result of risk assessments.
Awareness and training
Some employers, particularly those with global suppliers, may need to implement training for staff that are responsible for these areas and details of such should also be included in your document. As an extension of this, include additional information on awareness-raising or training company-wide such as posters, or email circulations. Sensitivity training for all employees could also be a part of this.
With the bulk of your statement including the above, you should incorporate changes to KPIs and how they have been adapted to accommodate the Modern Slavery Act. Details of KPIs already met should be laid out, together with timeframes as to when others should be met.
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