UK Modern Slavery Act - Considerations for Swiss Commercial Organizations

Human Rights

Swiss companies conducting business in the UK or with a UK-based parent company may be required to disclose efforts undertaken to prevent modern slavery and human rights abuses within their supply chain.

Under the UK Modern Slavery Act, any commercial organization with a global annual turnover of £36M or more that provides goods or services in the UK is required to produce an annual statement detailing the steps taken to address human rights abuses and modern slavery. These obligations extend to foreign commercial organizations that (a) carry out business, or part of a business in the UK, or (b) whose supply chain is integrated with that of a UK-based parent company. In the latter case, the UK parent’s transparency statement must include all steps taken by its subsidiaries.

The mandatory slavery and human trafficking statement implies an underlying obligation for concerned companies to analyse their own supply chains, both up and downstream, to identify human rights abuses by stakeholders, such as the hidden use of bonded labour.

The transparency statement may include due diligence efforts taken towards communicating company policies, developing risk management processes, as well as implementing awareness training or other actions to instill relevant policies into company culture. If an organization has not taken any measures in relation to slavery and human trafficking, this must equally be disclosed.

For more information on the UK Modern Slavery Act and how to comply with its obligations, including guidance on how to identify operations at risk of human rights violations, contact MME’s Trade Compliance team.

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