Uniac - July 2022

4 The Modern Slavery Act (2015) obliges all organisations, including universities, whose annual turnover exceeds £36 million, to produce an annual statement that describes the steps they have taken to ensure that there is no modern slavery in their own business and their supply chains. Modern slavery in the context of the 2015 Act includes slavery, servitude and forced or compulsory labour, and human trafficking. Home Office guidance argues that, rather than focusing on precise definitions, businesses have a moral duty to influence and incentivise continuous improvements in supply chains and a responsibility to ensure that workers are not being exploited, that they are safe and that relevant employment laws (including wages and working hours), health and safety and human rights laws and international standards are adhered to, including freedom of movement and communication. Non-compliance with the Act could result in legal enforcement; however, it is more likely to cause reputational damage. The Government launched an online modern slavery statement registry on 11 March 2021. Whilst all organisations are strongly encouraged to submit their most recently published statement on the registry to demonstrate they have reported, in future it will be mandatory to submit statements to the registry. This forms part of the proposed changes to strengthen the reporting requirements of the Act, including mandating the six reported areas contained in a statement as per the currently recommended areas to include under the Home Office’s statutory guidance (see relevant section below). Given it is six years since the requirements of the Act came into force and the proposed changes described above, it is timely to review institutions progress in this area. Whilst the Act does not prescribe the structure and content of annual statements in detail, the only absolute requirements are that: • a statement must be made (the statement should be updated every year and published within six months of the end of the financial year) Introduction 1. Modern Slavery Act 2015 – May 2022 Demonstrating compliance with the minimum legal requirements