As we warned some time ago, proposed changes in the law mean
that even recruitment agencies with modest turnovers could now be affected by
the modern slavery legislation (click here for previous article).
The modern slavery reporting obligation currently only
applies to businesses with a UK turnover in excess of £36m. Any requirement
involving turnover tends to affect supply agencies disproportionately (for
example, the apprenticeship levy) because the supply workers’ wages inflate the
However, even if your business turnover is lower than the
threshold, you may soon have to publish a modern slavery statement for
commercial reasons, if the Modern Slavery (Transparency in Supply Chains) Bill makes
its way on to the statute books. This
Bill is scheduled to have its second reading on 24 March 2017.
Modern slavery compliance already relies upon a trickle down
mechanism (click here for our previous article) using commercial pressures to
force compliance through the supply chain. The new Bill goes further by proposing
to amend the existing legislation to extend its application to the public
sector. If enacted, public sector hirers will have no option but to exclude
businesses without a modern slavery statement from their supply chains, in
order to comply with their obligations under the relevant public procurement
The legislation also provides that the Secretary of State is
to produce an easily accessible list of all organisations required to publish a
modern slavery statement. These organisations are also required to include the
statement in their annual report and accounts.
Sofie Lyeklint, Legal Consultant at Lawspeed, comments: “If,
or rather when, the Bill becomes law, how much business will you lose if you fail
to publish a modern slavery statement? The cost of complying with the legislation
needs to be weighed against the cost of lost business, not to mention the PR
cost of failing to show your commitment to preventing the human misery caused
by modern slavery.”
To help recruitment agencies prepare for the changes, Lawspeed has developed a comprehensive set of products designed to help agencies comply with the legislation and satisfy public sector hirers that they have taken appropriate steps to combat modern slavery. From recruitment specific guidance, checklists for registering candidates, MSA training and audits, through to Anti-Slavery and Anti-Human Trafficking policies and SHTs tailored to the recruitment sector, Lawspeed can help.