Having received the regular newsletter from HRC Law, it occurred to me that I wasn’t aware of this new requirement and wondered whether our clients and friends of PM+M were also unaware. As finance professionals, your PM+M team cannot advise you on the law but we should raise the issue and build awareness.
Jane Wilkinson, a solicitor at HRC advised that if your organisation supplies goods or services and carries on (part of) a business in the UK it will have to publish an annual slavery and human trafficking statement (the Statement) for each financial year ending on or after 31 March 2016, if its global turnover exceeds the £36 million threshold. This threshold includes the turnover of subsidiary undertakings too, so it’s not as huge a number as it first sounds.
The Statement must disclose what steps the organisation has taken to ensure that human trafficking is not taking place in any of its supply chains or its business; or state that it has taken no such steps (with the latter approach being a potential PR disaster!). Home Office Guidance outlines what should be included in the Statement and HRC Law can provide further support and guidance.
Even if you’re below the turnover threshold, it’s probable that (some of) your customers and suppliers will be caught by the requirement to produce and publish a Statement. As you will form part of their supply chain, they’ll be looking to you for assurances about your practices, procedures and supply chains. Thinking about this and preparing accordingly could help you to outshine your competitors and stay ahead of the game.
So, from PM+M’s point of view, this isn’t a case of this won’t ever impact our clients – it very well could and it very likely already is.