Large charities will have to produce an annual statement setting out the steps they are taking to ensure that slavery is not occurring in their supply chains, the government has said.
The Home Office yesterday published guidance on the Modern Slavery Act 2015, which is designed to tackle human rights abuses arising from forced or compulsory labour and human trafficking and became law in March.
It says that organisations, including charities, with an annual turnover of £36m or more operating in the UK must produce an annual statement for the financial years ending from 31 March 2016 setting out what they are doing in this area.
It says that the government has not been prescriptive about the layout or the content of a slavery and human trafficking statement, but it must be written in plain English and available on the organisation’s website.
"It is up to organisations how they present information in the statement and how much detail they provide," it says.
"However, organisations must include in the statement all the steps they have taken. The information presented in the statement will be determined by the organisation’s sector, the complexity of its structure and supply chains, or the particular sectors and nations its suppliers are working in."
Organisations that do not comply with the requirement to produce a statement could be served with an injunction requiring them to comply. Any organisation that ignores the injunction could face an unlimited fine, the guidance says.
Hugo Walford, an associate in the charities team at the law firm Withers LLP, warned that charities might feel unclear over what they should include in the statement.
He said that the reputational damage for any charities that failed to comply with the act could be severe, particularly in the current climate of added media scrutiny of charities’ activities.
This could mean that charities will not want to do just the bare minimum in their first statements on the matter. He added that charitable trusts would not be caught by the act.