In a previous post we explained the new requirement for large commercial organisations to produce an annual ‘slavery and human trafficking statement’ setting out the steps taken by that organisation to combat slavery and human trafficking within its own business and its supply chains. New regulations published this week give some guidance on when an organisation will be required to publish such a statement.
As expected, the Government has confirmed that the requirement will apply to a commercial organisation with a turnover of not less than £36 million. An organisation’s turnover will be aggregated with that of all its subsidiary undertakings (as defined in section 1162 Companies Act 2006) to see whether this threshold has been met.
‘Turnover’ for this purpose means the amount derived from the provision of goods and services as part of the ordinary activities of the commercial organisation (and its subsidiary undertakings) less trade discounts, VAT and any other applicable taxes.
Timetable for publication
The Government has also confirmed that the new requirement will only apply in respect of financial years ending on or after 31 March 2016, although details of the exact filing period (that is, when the statement must be published following the end of a financial year) are still awaited.
The Home Office has also published a practical guide giving advice on who is required to produce a statement, the content of that statement and how that statement should be approved and published. This contains some ‘top tips’ for writing a statement as well as some case studies and examples that should help organisations when preparing a slavery and human trafficking statement for the first time.