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Anti-Slavery and Human trafficking Policy Template for the UK

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What is an Anti-Slavery and Human Trafficking Policy?

An Anti-Slavery and Human Trafficking Policy sets clear rules and procedures to prevent forced labour and exploitation within an organisation and its supply chain. It demonstrates a company's commitment to complying with the Modern Slavery Act 2015, which requires organisations to take responsibility for slavery and human trafficking in their operations and supply chains.

The policy requires businesses to assess suppliers, train employees to recognise warning signs, and establish secure reporting channels for concerns. It also outlines steps for investigating potential violations and cooperating with authorities including the National Crime Agency and local law enforcement. Many companies adopt these policies to meet legal obligations, safeguard workers, and uphold ethical business standards.

Frequently Asked Questions

When should you use an Anti-Slavery and Human Trafficking Policy?

Organisations need an Anti-Slavery and Human Trafficking Policy when operating in sectors with complex supply chains, such as manufacturing, retail, agriculture, or hospitality. This policy becomes essential when engaging with international suppliers, expanding operations across the UK and beyond, or tendering for public sector contracts that require human trafficking compliance.

It's particularly important when establishing new supplier relationships, employing temporary workers, or operating in regions with identified labour trafficking risks. The Modern Slavery Act 2015 requires all organisations with an annual turnover exceeding 拢36 million to publish an annual slavery and human trafficking statement. The policy helps protect both workers and the organisation's legal position and reputation.

What are the different types of Anti-Slavery and Human Trafficking Policy?

  • Basic Compliance Policy: Covers core requirements under the Modern Slavery Act 2015, focusing on employee training and reporting procedures 鈥 ideal for smaller organisations.
  • Comprehensive Supply Chain Policy: Includes detailed supplier due diligence, auditing protocols, and corrective action plans 鈥 suited for large retailers and manufacturers.
  • Public Sector Contractor Version: Features specific provisions required by public procurement rules and Cabinet Office guidance for organisations supplying government contracts.
  • Industry-Specific Policies: Tailored for high-risk sectors such as agriculture, textiles, construction, or care services, with sector-specific indicators and prevention measures.
  • Multinational Operations Policy: Incorporates UK legislation alongside international standards and cross-border compliance requirements for organisations operating globally.

Who should typically use an Anti-Slavery and Human Trafficking Policy?

  • In-House Legal Teams: Draft and update the policy to ensure compliance with the Modern Slavery Act 2015 and relevant regulations whilst protecting organisational interests.
  • Human Resources Directors: Implement training programmes and manage reporting systems for potential violations and concerns.
  • Supply Chain and Procurement Managers: Assess suppliers and monitor compliance throughout the supply network.
  • Senior Management and Board Members: Approve policies and commit resources for implementation, enforcement, and annual slavery and human trafficking statements.
  • Compliance and Risk Officers: Oversee policy enforcement, conduct audits, and liaise with the National Crime Agency and law enforcement where required.
  • All Employees and Contractors: Adhere to policy guidelines and report suspected violations through designated confidential channels.

How do you write an Anti-Slavery and Human Trafficking Policy?

  • Supply Chain Mapping: Document all suppliers, contractors, and business partners to identify potential risk areas and vulnerability points.
  • Legal Requirements Review: Research the Modern Slavery Act 2015, relevant regulations, and industry-specific guidance applicable to your organisation.
  • Organisational Assessment: Evaluate existing processes for worker verification, supplier assessment, and reporting mechanisms.
  • Training Plan: Outline how employees will be educated about trafficking indicators, recognition of exploitation, and reporting procedures.
  • Enforcement Strategy: Define clear consequences for violations and investigation procedures for addressing concerns.
  • Documentation and Monitoring System: Create systems to track policy compliance, training completion, due diligence assessments, and incident reports.

What should be included in an Anti-Slavery and Human Trafficking Policy?

  • Policy Statement: Clear commitment to preventing slavery and trafficking in operations and supply chains in line with the Modern Slavery Act 2015.
  • Scope Definition: Specify which employees, workers, contractors, suppliers, and business activities are covered by the policy.
  • Compliance Standards: Reference the Modern Slavery Act 2015, relevant sector guidance, and any other applicable legislation your organisation follows.
  • Due Diligence Procedures: Detail supplier assessment processes, risk evaluation criteria, and ongoing monitoring arrangements.
  • Reporting Mechanism: Explain confidential reporting channels, whistleblower protections, and safe disclosure procedures.
  • Training Requirements: Outline mandatory training frequency and content for staff at all levels.
  • Investigation Protocol: Specify procedures for investigating alleged violations and cooperating with authorities.
  • Annual Statement Commitment: Confirm the organisation's commitment to publishing an annual slavery and human trafficking statement if required.
  • Review Schedule: State how regularly the policy will be reviewed and updated to reflect changes in legislation or business operations.

What's the difference between an Anti-Slavery and Human Trafficking Policy and a Compliance and Ethics Policy?

Whilst both documents focus on ethical business conduct, an Anti-Slavery and Human Trafficking Policy differs significantly from a Compliance and Ethics Policy in several key ways:

  • Scope and Focus: Anti-slavery policies specifically address forced labour and trafficking concerns, whilst Compliance and Ethics policies encompass broader ethical conduct including bribery, conflicts of interest, and general business integrity.
  • Legal Requirements: Anti-slavery policies must comply with the Modern Slavery Act 2015 and specific anti-trafficking legislation, whereas Compliance and Ethics policies address multiple regulatory frameworks across various business practices including the Bribery Act 2010 and regulations on financial crime.
  • Implementation: Anti-slavery policies require detailed supplier due diligence and specific training on exploitation indicators, whilst Compliance and Ethics policies typically involve general ethics training and broader organisational risk management.
  • Enforcement Mechanisms: Anti-slavery policies need explicit procedures for investigating trafficking concerns and reporting to the National Crime Agency or law enforcement, whilst Compliance and Ethics policies focus more on internal misconduct and corporate governance procedures.

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Jurisdiction

England & Wales

Reviewed by

&

Category

Policies

Cost

Free to use

Last updated

About the Anti-Slavery and Human trafficking Policy

  • Supply Chain Mapping: Document all suppliers, contractors, and business partners to identify potential risk areas and vulnerability points.
  • Legal Requirements Review: Research the Modern Slavery Act 2015, relevant regulations, and industry-specific guidance applicable to your organisation.
  • Organisational Assessment: Evaluate existing processes for worker verification, supplier assessment, and reporting mechanisms.
  • Training Plan: Outline how employees will be educated about trafficking indicators, recognition of exploitation, and reporting procedures.
  • Enforcement Strategy: Define clear consequences for violations and investigation procedures for addressing concerns.
  • Documentation and Monitoring System: Create systems to track policy compliance, training completion, due diligence assessments, and incident reports.

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