UK Modern Slavery Act Obligations Take Effect
Businesses with financial year-ends of 31 March or later must start publishing annual statements under the UK’s Modern Slavery Act (the MSA). The statements must set out the steps that businesses have taken to ensure that slavery and human trafficking are not taking place within their businesses or supply chains. The MSA applies to businesses that supply goods or services to the UK or that carry on a business or part of a business in the UK, and that have a total annual turnover of £36 million or more. It does not matter where a business is headquartered or incorporated, which means that the MSA will apply to non-UK businesses that conduct business in the UK and meet the turnover threshold.
The requirements to publish a statement came into effect on 29 October 2015, but businesses with a financial year-end between 29 October 2015 and 30 March 2016 were not required to publish a statement for that financial year. Businesses with a year-end of 31 March 2016 are the first to be required to publish a statement. The MSA does not specify a hard deadline for when a statement must be published, but the UK government’s guidance indicates that the statement should be published within six months of the year-end.
This information is provided by Vinson & Elkins LLP for educational and informational purposes only and is not intended, nor should it be construed, as legal advice.