Modern Slavery

The Modern Slavery Act 2015 was introduced to protect people from exploitation and reinforces several of the provisions of the European Convention on Human Rights.  It created three types of criminal offences, namely:

• slavery or servitude
• forced or compulsory labour, and
• human trafficking and committing an offence with intent to commit human trafficking.

These offences carry serious penalties, including life imprisonment if convicted on indictment.  

Our clients often find themselves uniquely placed to tackle modern slavery.  In particular across the local government, housing, health and care sectors our clients are well-placed to identify and support victims through safeguarding and through housing, homelessness and community services.  

We understand  that the significant level of third party revenue expenditure commonly incurred by our clients makes it crucial that the supply chains they procure from are free from modern slavery; and, as modern slavery permeates a whole range of services (children’s services, adult social care, housing and community services), it is important that a joined up approach is adopted. 

Specific transparency provisions in the Modern Slavery Act require commercial entities with an annual turnover of £36m or more to report annually on their actions to identify, prevent and mitigate modern slavery in their supply chain. 

Mandatory guidance exists that requires certain in-scope organisations (NHS bodies, Central Government Departments, their Executive Agencies and Non-Departmental Public Bodies) to take steps to mitigate the risk of modern slavery in government supply chains. 

We support our clients to ensure they have a framework of policies, procedures and contractual arrangements in place that contribute towards the prevention of modern slavery within the organisation and supply chain.  Specifically, we can assist with advice on:  

• Modern Slavery Statements;
• Robust due diligence processes;
• Housing management policies and procedures to mitigate against the risk of properties being used to house the victims of modern slavery;
• Risk management;
• Safeguarding, in particular for children and adults with social care needs;
• Health and Safety;
• Recruitment;
• Immigration;
• Whistleblowing;
• Procurement processes; and
• Terms and Conditions and codes of conduct for employees, suppliers and contractors.