The Modern Slavery Act came into force in March 2015. The Act aims to prevent all forms of labour exploitation and increase transparency of labour practices in supply chains.
S.54 of the Act requires organisations to report on the processes and due diligence taken to ensure that their supply chains are slavery free. This 'Transparency in Supply Chains' clause requires organisations with a worldwide turnover of £36m or more and that have a 'demonstrable' presence in the UK to produce and publish a slavery and human trafficking statement each financial year ending on or after 31 March 2016. The statement is a summary of the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any part of its business or its supply chains. A statement needs to be published regardless of whether any steps have been taken or not. While a disclosure stating that the company does nothing to prevent such practices is legally compliant under the law, such a disclosure can leave a company susceptible to negative publicity from customers and human rights organisations.
The Home Office has published a practical guide to the Transparency in Supply Chain clause which sets out the basic requirements of the legislation, as well as advice on what can be included in a statement to give assurance to those scrutinising the statements, but there is no tick-box obligation to be completed using a standard form.
To help the seafood industry better understand the reporting requirements Seafish ran a workshop on 10 March 2016 to help seafood companies understand the wording of the legislation, but also the practical steps which companies in the seafood sector should take to consider the appropriate levels of risk assessment, and action, that they should put in place to address potential modern slavery issues, both in their supply chain and their direct operations. This guidance note has been produced to provide more specific information about how companies in the seafood sector might think about the content of their statement.
For a registry of Transparency in Supply Chain modern slavery statements see: