Modern Slavery Act – What To Look Out For

The Modern Slavery Act sets out what businesses should do to ensure that they are not directly or indirectly affected by Modern Slavery.

The UK Government’s National Referral Mechanism (NRM) shows that there were 6,414 referrals made in three months, which is a 34% uplift on the previous quarter’s figures.

This is a very concerning jump and highlights that Modern Slavery has not been brought fully under control.

So what can you and your organisation do to protect against falling foul of the Modern Slavery Act?

Right to Work Checks

Make sure that whenever your organisation engages new employees or contractors, you conduct a thorough Right to Work Check.

This entails looking at original documentation and ensuring that the documents are not forged, faked or copied.

The best way to do this is to ask for a valid passport and compare it to the individual’s face-to-face.

Failing this, you can request a valid Work Visa or ask for their Government Share Code to check their Right to Work Status.

Whatever methods you use to complete a right-to-work check, make sure that you insist on seeing original documents.

Copy them, sign them as a true likeness and keep them on file.

The fines for hiring people without the right to work in the UK are up to £60,000 per offence.

Only Use Valid Bank Accounts

Any employee must have a personal bank account registered in their name before an employer makes any payments to them.

This can be a joint account, but their name must be on the paperwork.

Ask for a recent Bank Statement or a letter from the bank confirming their account details and address.

Corroborate this with another piece of photo evidence, e.g. a driver’s licence.

If the individual cannot comply with the above requirements, you should ask why they do not have their own bank account.

If in doubt, do not hire them.

Audit Suppliers & Agencies

If your organisation uses agencies to supply labour or you use suppliers in risky areas of the world, then you should conduct an audit to ensure that your company is not inadvertently wrapped up in any acts of Human Trafficking or Slavery.

Make sure you conduct checks on all new suppliers or agencies to ensure that no new issues slip into the supply chain by stealth.

Policies & Procedures Are Key

Ensure that all employees, contractors and associates of the organisation know and understand the policies on Human Trafficking, Slavery, Equal Opportunities and Whistleblowing, and where to find them.

It is key for all workers to alert their organisation if they suspect suspicious activities within the supply chain.

They need to know that they can report any concerns in the strictest of confidence.

Train Managers on the Policies and Procedures

Managers are the key to making sure that Modern Slavery and Human Trafficking are not allowed to creep into the organisation’s structures or processes.

Ideally, this should be done at least once per year and updated when any changes are introduced.

All training in this area should be tracked, and records should be kept on who was trained and when.

If there are ever any issues, these records will be key in showing that the organisation took reasonable steps to prevent Modern Slavery and Human Trafficking.

Summary

The latest Government stats show that Modern Slavery and Human Trafficking are prevalent in today’s UK business environment.

The Modern Slavery Act 2015 provides guidelines and rules to ensure that UK businesses do not engage in this activity.

At HR Smart, we provide HR Manager services to help your business, as well as an HR Helpline.

Should you have any questions or concerns in this area, we would urge you to contact Jon Rush at jon@hrsmartuk.com or call us on 01903 754107 where we will be able to help and guide you.