The new obligation on commercial organisations over a certain size to publish a slavery and human trafficking statement has come into force today.
There will, however, be transitional provisions to allow affected businesses sufficient time to understand the new requirements and produce a statement.
- Businesses with a year-end date on or after 31 March 2016 will be the first businesses required to publish a statement for their 2015-16 financial year.
- Businesses with a year-end date on or before 30 March 2016 will not be required to publish a statement for the 2015-2016 financial year of the organisation. So, for example, a business with a financial year end of 31 December 2015 will have to produce its first statement for the financial year ending 31 December 2016.
The Act does not set a time limit for when a statement must be published, but the Government has indicated that it expects businesses to publish their statements “as soon as reasonably practicable” after the end of the financial year and in all cases no later than six months after the year end.
As promised, the Government has also published a practical guide for affected businesses which includes further details on which businesses will be affected and “guidance” on the information that could be included in a slavery and human trafficking statement.
We have published an updated briefing note summarising the key points for employers and the steps that businesses should be taking to satisfy this new obligation.