Scarinci Hollenbeck, LLC, LLCScarinci Hollenbeck, LLC, LLC

Firm Insights

UK’s New Human Trafficking Rules May Impact U.S. Businesses

Author: Dan Brecher

Date: August 20, 2015

Key Contacts

Back

The United Kingdom’s Modern Slavery Act recently took effect. For U.S. businesses operating across the pond, it is important to understand how the statute’s human trafficking supply chain disclosure rules may impact your compliance initiatives.

human trafficking

Under the Modern Slavery Act, a “commercial organization” must prepare a slavery and human trafficking statement for each financial year. The mandatory corporate disclosure must state the steps the organization has taken to ensure that slavery and human trafficking are not taking place in any of its supply chains and in any part of its own business, or that the organization has taken no such steps.

A “commercial organization” is broadly defined as a corporation or partnership that carries on a business, or part of a business, in any part of the United Kingdom. However, the disclosure obligations apply to companies with a turnover of over £36 million.

A default slavery and human trafficking statement

Pursuant to the UK statute, a company’s statement may include the following information:

  • The organization’s structure, its business and its supply chains;
  • Its policies in relation to slavery and human trafficking;
  • Its due diligence processes in relation to slavery and human trafficking in its business and supply chains;
  • The parts of its business and supply chains where there is a risk of slavery and trafficking taking place, and the steps it has taken to assess and manage that risk;
  • Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate; and
  • The training about slavery and human trafficking available to its staff.

It is important to highlight that the statute does not create an affirmative obligation to develop a compliance program to address human trafficking in the supply chain. However, companies must publicly disclose that they do not have any policies or procedures in place. Accordingly, the British government is relying on pressure from the public, as well as advocacy organizations, to encourage corporations to voluntarily adopt measures to combat slavery and human trafficking in their supply chains.

When the Modern Slavery Act kicks in

The UK’s mandatory annual reporting requirements take effect in October. The Secretary of State is expected to publish additional compliance guidance in the near future.

In the United States, California is currently the only state to require businesses to disclose the steps they are taking to combat slavery and human trafficking. However, federal legislation could be on the horizon.

Last month, U.S. Representatives Carolyn Maloney (D-NY) and Chris Smith (R-NJ) introduced the Business Supply Chain Transparency on Trafficking and Slavery Act of 2015 (H.R. 3226), which would require publicly traded companies with over $100 million in annual worldwide gross receipts to disclose their policies on human trafficking, slavery, and forced labor on their websites as well as in annual reports filed with the Securities and Exchange Commission (SEC).

No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.

Scarinci Hollenbeck, LLC, LLC

Related Posts

See all
Guardianships in New Jersey: When a Loved One Can No Longer Manage Personal or Financial Affairs post image

Guardianships in New Jersey: When a Loved One Can No Longer Manage Personal or Financial Affairs

When a family member can no longer make important decisions for themself, the question is often not whether the family will step in, but whether they have the legal authority to do so. A spouse may manage household finances, or an adult child may arrange medical care and pay bills. Still, informal assistance does not […]

Author: Marc J. Comer

Link to post with title - "Guardianships in New Jersey: When a Loved One Can No Longer Manage Personal or Financial Affairs"
New Jersey’s Revised UHAC Regulations: What Residential Developers Need to Know About Affordable Housing Commitments post image

New Jersey’s Revised UHAC Regulations: What Residential Developers Need to Know About Affordable Housing Commitments

New Jersey residential developers with affordable housing obligations should carefully review their existing approvals, development agreements, and proposed deed restrictions in light of the State’s revised UHAC regulations (Uniform Housing Affordability Controls). The regulations, which took effect on November 6, 2025, significantly change the administration and physical requirements for affordable housing units. For developers with […]

Author: Wendy Rubinstein Quiroga

Link to post with title - "New Jersey’s Revised UHAC Regulations: What Residential Developers Need to Know About Affordable Housing Commitments"
“No Comment” Culture: Why Silence Is Often the Riskiest Legal Strategy post image

“No Comment” Culture: Why Silence Is Often the Riskiest Legal Strategy

A “no comment” response is sometimes the right call when a legal problem arises. As a blanket policy, however, it lets allegations go unanswered, deadlines pass, evidence disappear, and manageable disputes grow into expensive litigation. The businesses that fare best are usually the ones that say little publicly while acting decisively behind the scenes. When […]

Author: Sean M. Pena

Link to post with title - "“No Comment” Culture: Why Silence Is Often the Riskiest Legal Strategy"
Utility-Scale Battery Storage Projects: A Legal Roadmap for Developers, Property Owners and Other Stakeholders post image

Utility-Scale Battery Storage Projects: A Legal Roadmap for Developers, Property Owners and Other Stakeholders

Utility-scale battery energy storage systems (BESS) are becoming an increasingly important component of the electric grid throughout New Jersey, New York, and Pennsylvania. As renewable generation expands, electricity demand increases and grid operators seek greater flexibility, battery storage can help balance supply and demand while providing additional capacity and reliability. For developers, battery storage presents […]

Author: Nicholas Wall

Link to post with title - "Utility-Scale Battery Storage Projects: A Legal Roadmap for Developers, Property Owners and Other Stakeholders"
Navigating Disputes: Hire a Partnership Dispute Lawyer post image

Navigating Disputes: Hire a Partnership Dispute Lawyer

A falling out between partners can be disastrous for any business. In many cases, the partnership will not survive. If you are in an unworkable situation with your partners, it may be time to consult a partnership dispute lawyer experienced in handling partnership breakups and dissolutions before the situation deteriorates any further. It is easy […]

Author: Jay McDaniel

Link to post with title - "Navigating Disputes: Hire a Partnership Dispute Lawyer"
Section 363 Sales in Bankruptcy: What Businesses, Lenders, and Buyers Need to Know post image

Section 363 Sales in Bankruptcy: What Businesses, Lenders, and Buyers Need to Know

When a company enters Chapter 11 bankruptcy, many assume the process will culminate in a lengthy reorganization plan. However, distressed businesses are increasingly being sold through a different mechanism — a sale under Section 363 of the United States Bankruptcy Code. A Section 363 sale allows a company, as a debtor-in-possession in bankruptcy, to sell […]

Author: John D. Giampolo

Link to post with title - "Section 363 Sales in Bankruptcy: What Businesses, Lenders, and Buyers Need to Know"

No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.

Sign up to get the latest from our attorneys!

Explore What Matters Most to You.

Consider subscribing to our Firm Insights mailing list by clicking the button below so you can keep up to date with the firm`s latest articles covering various legal topics.

Stay informed and inspired with the latest updates, insights, and events from Scarinci Hollenbeck. Our resource library provides valuable content across a range of categories to keep you connected and ahead of the curve.

Let`s get in touch!

* The use of the Internet or this form for communication with the firm or any individual member of the firm does not establish an attorney-client relationship. Confidential or time-sensitive information should not be sent through this form. By providing a telephone number and submitting this form you are consenting to be contacted by SMS text message. Message & data rates may apply. Message frequency may vary. You can reply STOP to opt-out of further messaging.
“If you would like to submit a file, please email it directly to info@sh-law.com.

Sign up to get the latest from the Scarinci Hollenbeck, LLC attorneys!