Whilst the concept of slavery in today’s working world may seem surprising, the volume of low skilled jobs in the hospitality sector can provide the opportunity for unscrupulous individuals or agencies to put people into forced or bonded labour. This can entail taking away their travel documents, withholding wages and curtailing freedom.

The Modern Slavery Act 2015 introduced Regulations aimed at achieving greater transparency in business, as well as heightened corporate responsibility. They oblige any UK business with turnover above £36m to publish an annual statement setting out the steps taken to ensure there is no slavery in their business or supply chain.

The Government, in its drive to prevent modern slavery, has recently published updated guidance to help businesses to comply with the Regulations. It sets out guidance on how to write, approve and publish a statement, as well as what best practice looks like. Annex E covers the information which should be included in the statement.

The Guide can be found here.

Failure to comply

Failing to comply with the obligation to report can lead to the Secretary of State applying for an injunction – and ultimately is punishable with an unlimited fine. Perhaps a greater sanction will be the adverse publicity and fall in investor confidence which will result from a failure to investigate and tackle this issue and publish an annual statement.

More about your obligations

To find out more about the Regulations, see our previous 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.