Modern Slavery: Are You Involved Without Knowing It?

The warning follows the Royal Assent of The Modern Slavery Act earlier this year, which seeks to abolish the slavery and human trafficking industry which currently affects 27-30 million people worldwide.

Although relatively straightforward for British suppliers to prove themselves clear of slavery, the new Act may prove a challenge to businesses which source products from abroad.

Modern slavery could take the form of migrants being employed without permission to work in the country in question, and the creation of an ‘ethical working practices policy’ which suppliers must comply with as part of their contract with you will assist in eradicating it from your supply chain.

Simon Bates, head of commercial at Jordans Corporate Law Limited said, “The new Act has very broad ranging powers, making it something that everyone in the food supply chain needs to take seriously – not just the larger companies that are immediately affected by it.

“Modern slavery might seem a remote problem for the UK food sector, but these practices go on in many countries – including Britain, sadly. And if a major food manufacturer or even a retailer is found to source from companies involved in these practices, it becomes their problem too.

“In many ways, the food industry is the sector that can be most affected by modern slavery, due to the complexities of the supply chain. Materials can come from many different countries, and they are often grown or processed in remote locations.

“While the main thrust of the Act is aimed at ‘larger’ companies, the definition of ‘larger’ has not yet been spelled out – that is expected in the next few months. But as those larger companies will be looking hard at their supply chain, even smaller suppliers could be under scrutiny very shortly.

“You must produce a ‘slavery and human tracking statement’ for each financial year setting out the steps you have taken to ensure your business and your supply chain are free from slavery (or a statement that no such steps have been taken). If you have a website you must publish the statement on it and include a link to the statement on your homepage.”