Home Office Central Registry for modern slavery statement goes live - first universities publish statements

Every commercial organisation is required to publish a modern slavery statement each year it meets all of the following criteria:

• it is a ‘body corporate’ or a partnership, wherever incorporated or formed;
• it carries on a business, or part of a business, in the UK;
• it supplies goods or services; and
• it has an annual turnover of £36 million or more.

The Government has stated that as long as the organisation is incorporated (by whatever means) or is a partnership, it does not matter if it pursues primarily charitable or educational aims when considering whether it can be said to be carrying on a business. A common-sense approach is required.

The Home Office recently launched a central registry for modern slavery statements. A growing number of educational organisations, including a number of universities, have published statements on the registry. Statements can be published for distinct parts of an organisation or a global statement can be produced. At the time of writing approximately 1,200 statements have been published on the registry.

Organisations need to create an account to register their organisation and submit their statement. Uploading information to the Home Office registry is (at this point) voluntary - although the government has indicated that in future publication to the central registry will be mandatory. The Home Office will use the information to publish a summary in its modern slavery statement registry and include a link to the full statement on each organisation’s website.

The Government has said that it hopes having a central registry “will radically enhance transparency making it easier for consumers, investors and civil society to hold organisations to account for the steps they have taken to root out modern slavery.”

The shift towards centralising the publication of modern slavery statements, in terms of location and timing, seems bound to encourage many in-scope organisations to re-visit their approach to the subject as greater visibility, including between competitors, becomes the norm. If it’s time to re-think your approach to your next modern slavery statement and you would like any assistance with this please get in touch.