The United Kingdom (UK), following the lead of the United States, has become the latest jurisdiction to impose new requirements on private sector employers that are designed to combat human trafficking. Section 54 of the recently enacted Modern Slavery Act, which has gone into effect, will soon require employers operating within the jurisdiction of the UK – including U.S. businesses with UK operations – to annually disclose steps that they have taken to ensure that slavery and trafficking are not occurring in their own business or supply chains.
While the new law has officially gone into effect, covered employers will not be required to file their first report until the end of their financial year. Companies with financial years ending March 30, 2016 or before need not report until the end of their next financial year.
The UK1s Home Office has published guidance further explaining the laws requirements and the governments expectations for compliance.
The text of the UK Modern Slavery Act is available here.
A copy of the Home Office guidance regarding the supply chain transparency provisions is available here.