59 Virtual Brochure – March 2025 Modern Slavery Act 2015 Introduction Modern slavery includes servitude (the imposition, by coercion, of an obligation to provide services) and forced compulsory labour, and human trafficking. Per Home Office guidance, businesses have a moral duty to influence and incentivise continuous improvements in supply chains and a responsibility to ensure that workers are not being exploited, are safe, and that relevant employment laws (including wages and working hours), health and safety and human rights laws and international standards are adhered to, including freedom of movement and communication. The Modern Slavery Act (2015) requires organisations whose turnover exceeds £36 million to produce an annually updated statement describing the steps taken to ensure there is no modern slavery in their business and supply chains. Statements include steps taken to identify modern slavery in the organisation and supply chain, published prominently on the website and approved at the highest level of governance. Non-compliance with the Act could result in legal enforcement; however, it is more likely to cause reputational damage. Uniac has reviewed a number of Higher Education institutions’ arrangements for ensuring compliance with the Modern Slavery Act. This briefing note has been drafted to provide examples of common findings and themes, plus identified good practice which institutions may wish to consider in the continuing development of their own modern slavery arrangements. Home Office guidance Home Office guidance (which is likely to become mandatory in future) recommends that annual statements include descriptions of six specific areas: • the organisation’s structure, its business and its supply chains. • policies in relation to slavery and human trafficking. • due diligence processes. • the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk. • its effectiveness in ensuring slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate. the training about slavery and human trafficking available to staff
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