The government has made two sets of regulations relating to the Modern Slavery Act 2015 (MSA):

  1. The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. Section 54 of the MSA requires commercial organisations to prepare a slavery and human trafficking statement for each financial year in which their total turnover is above the prescribed amount. These Regulations came into force on 29 October 2015 and set the amount at £36 million in terms of total turnover. They also provide that total turnover will be determined by taking into account the global turnover of the organisation and its subsidiary undertakings. The total turnover includes the amount derived from the provision of goods and services falling within the ordinary activities of that organisation and its subsidiary undertakings, after deducting trade discounts, value added tax and other taxes.
  2. The Modern Slavery Act 2015 (Commencement No. 3 and Transitional Provision) Regulations 2015. which bring section 54 of the MSA into force on 29 October 2015. There is a transitional provision which provides that the requirement only applies in respect of financial years ending on or after 31 March 2016.

If you wish to discuss anything mentioned above please contact David Roath.