Modern Slavery Act 2015 – HR implications

Hannah Gormley

You could be forgiven for thinking that the Modern Slavery Act 2015 is not a topic appropriate for the HR agenda. After all, how is trafficking and slavery relevant to the workplace in the UK? As unlikely as it sounds, modern slavery is the business of UK businesses says the Government, as there are steps that can be taken to protect workers from being abused and exploited in organisations and global supply chains.

In a nutshell, the Act requires certain businesses to produce a Slavery and Human Trafficking Statement setting out the steps they have taken to ensure that there is no modern slavery in their own business and their supply chains. The Act came into force on 29th October 2015, and the first organisations which will have to publish their Statements are those whose current financial year ends on 31 March 2016.

What are the implications for HR?

Although the Act is not directly relevant to HR on a day-to-day basis, everyone expects HR to be the font of all knowledge, so it is important for HR to know about the rules and how they impact on the organisation and staff. The following list provides a few areas to think about.

  • Which policies may need review and amendment? Likely candidates are: whistleblowing, anti-bribery, CSR and procurement policies, which may need tweaking to make reference to the obligations under the Act.
  • Employers should document that the workforce are paid the national minimum wage and have the appropriate right to work in the UK.
  • Those in the organisation responsible for the oversight of the investigation and production of the Slavery and Human Trafficking Statement may want support and assurances from HR about documentation and wage levels.
  • Employers may want to charge HR with the responsibility for training and guidance on identifying slavery and human trafficking issues particularly for staff working in areas of the business such as procurement where these issues will be of paramount importance.

This is one of those areas that falls between a number of business areas but it is likely that that queries will find their way to HR as the default option. Our corporate team have produced an alert setting out the details, please contact Cleuma Nascimento, if you would like to receive a copy, and the Government has issued a practical guide that can be found here.

Comments published on Employment Talk do not necessarily reflect the views of Allen & Overy.

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