AI告诉营业额超过3600万英镑的英国公司，可以在财务年度内随时发布现代奴隶制声明
AI tells a UK company with £36M+ turnover that it can publish its modern slavery statement anytime within the financial year
ID: legal/uk-modern-slavery-statement-deadline
版本兼容性
| 版本 | 状态 | 引入 | 弃用 | 备注 |
|---|---|---|---|---|
| Modern Slavery Act 2015 §54 | active | — | — | — |
| Home Office Guidance (2023) | active | — | — | — |
根因分析
英国《2015年现代奴隶制法案》第54条要求，奴隶制和人口贩运声明必须在财务年度结束后6个月内由董事会批准并由董事签署；在财务年度内随时发布是错误的，存在不合规和潜在禁令风险。
English
UK Modern Slavery Act 2015 §54 requires that the slavery and human trafficking statement be approved by the board and signed by a director within 6 months of the end of the financial year; publishing anytime within the financial year is incorrect and risks non-compliance and potential injunction.
官方文档
https://www.legislation.gov.uk/ukpga/2015/30/section/54解决方案
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Set a calendar reminder for 5 months after the financial year end to ensure board approval and publication within the 6-month window. Create a dedicated 'Modern Slavery Statement' page on the company website with the current and previous year's statements.
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Use a compliance automation tool that tracks financial year end and triggers a workflow for drafting, board approval, and publication with alerts at 5 months post-year-end.
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If the statement is late, immediately publish an approved statement and document the delay with a board resolution explaining the oversight; this reduces risk of injunction but does not guarantee immunity.
无效尝试
常见但无效的做法:
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85% 失败
The statement must be approved by the board of directors and signed by a director before publication; publishing an unapproved version is non-compliant and may be treated as a failure to comply with §54.
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90% 失败
The 6-month deadline is statutory; there is no grace period. After 6 months, the company is in breach and the Secretary of State can seek an injunction via the High Court.
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75% 失败
The Act requires the statement to be published in a 'prominent place' on the company's website; burying it in a PDF annual report without a direct link is insufficient and may be challenged.