There are currently estimated to be up to 13,000 victims of modern slavery in the UK according to the Home Office.  The Modern Slavery Act 2015 was introduced to tackle this crime, with a UK taskforce recently introduced to police activity, as well as £33m to fund overseas anti-slavery initiatives.  You should be sure that your operations and supply chains are trafficking and slavery free to avoid legal breaches, but as importantly, reputational damage.

It may not be immediately obviously that modern slavery affects the hospitality sector. However it is relevant particularly because of the volume of low skilled workers and the often short term nature of appointments.  This is an area where it is possible for unscrupulous individuals or agencies to put people into forced or bonded labour and take away their travel documents, wages and freedom.

The Modern Slavery Act 2015 (Transparency of Supply Chains) Regulations were introduced to achieve greater transparency in business and to increase corporate responsibility in the fight against modern slavery.

How do the Regulations affect you?

The Regulations will apply to your business if it was incorporated in the UK (or carries out business in the UK supplying businesses or services) and if it has a turnover of more than £36million.

If this is the case you will need to carry out an audit of your supply chain and publish an anti-slavery statement.  The hospitality sector should pay particular attention to the checks that agencies carry out on staff that they supply to you. The other area to be vigilant is over the origins of food that you purchase – for example, are you happy that it is not harvested by workers who are being exploited?

To find out more about your obligations see Freeths’ article: Modern Slavery – a new duty to audit and report

The content of this page is a summary of the law in force at the present time and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.