The Modern Slavery Act 2015 applies to all organisations with a turnover, or group turnover - that is, the total turnover of a company and its subsidiaries - of £36 million or more which are either incorporated in the UK or carry on a business in the UK. Section 54 of the Act requires those organisations to prepare and publish a statement setting out the steps that they have taken during that financial year to ensure that slavery and human trafficking are not taking place:

• anywhere in their supply chains.
• in any part of their own business.

The law came into force on 29 October 2015. The requirement to publish an anti-slavery statement only applies for financial years ending on or after 31 March 2016. There are draft Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 which provide that the combined turnover of a commercial organisation is the turnover of that company and its subsidiaries. Businesses should now be considering whether they are subject to these new disclosure requirements and preparing their approach to compliance. A commercial organisation is required to comply with the reporting requirements if:

• it is incorporated or a partnership.
• it "carries on a business, or part of a business" in the UK.
• its turnover or the turnover of a parent company and its subsidiaries is equal to or greater than £36 million per annum – although this threshold is still to be formally confirmed by way of secondary legislation.
• it supplies goods or services.

ERCOFTAC adheres to this policy.