Modern Slavery statement requirements in the UK: who, what and how

Who must publish a Modern Slavery statement

Section 54 of the Modern Slavery Act 2015 is the transparency in supply chains provision. It applies to a commercial organisation that supplies goods or services and carries on a business, or part of a business, in the UK, with a total turnover at or above the threshold set by regulations^[1]. That threshold is £36m^[2].

An organisation in scope must prepare a slavery and human trafficking statement for each financial year^[1]. The statement sets out the steps taken during that year to ensure slavery and human trafficking is not taking place in any of its supply chains or in any part of its own business^[1]. The law also allows a statement that the organisation has taken no such steps^[1], but in practice that is rarely a credible answer for a customer or a tender evaluator.

Turnover includes the turnover of subsidiaries, so group structures need care: a parent may need to report for the group, and a UK subsidiary of a larger group may be in scope in its own right^[2].

What the statement should cover

The Act lists six areas that a statement may include information about, and the Home Office guidance encourages organisations to cover all of them^{[1, 2]}:

• Structure, business and supply chains. What the organisation does, where it operates and how its supply chains are made up.
• Policies. Policies in relation to slavery and human trafficking, such as a supplier code of conduct or recruitment policy.
• Due diligence. The processes used in the business and its supply chains.
• Risk assessment and management. The parts of the business and supply chains where there is a risk, and the steps taken to assess and manage it.
• Effectiveness. How effective the organisation has been, measured against performance indicators it considers appropriate.
• Training. The training about slavery and human trafficking available to staff.

A good statement is specific. It names the categories and countries where risk is highest, says what checks were carried out and what was found, and sets out what will be done next year. Generic wording copied from another organisation tells the reader nothing about your supply chain.

Sign-off and publication

For a company, the statement must be approved by the board of directors and signed by a director^[1]. A limited liability partnership needs approval by the members and signature by a designated member, and other organisations have equivalent rules^[1].

If the organisation has a website, the statement must be published on it, with a link to the statement in a prominent place on the homepage^[1]. If it has no website, it must provide a copy to anyone who makes a written request, within 30 days of the request^[1].

A statement is needed for each financial year, so plan the update into the annual reporting cycle rather than treating it as a one-off.

Suppliers below the threshold

Smaller suppliers are not required by law to publish a statement. Their customers often are, and those customers need evidence about the businesses they buy from. As a result, suppliers below the threshold are often asked for a Modern Slavery statement, or for answers to the same questions, by larger customers and in tenders.

Writing a voluntary statement to the same standard has practical benefits. It answers customer questionnaires consistently, shows evaluators that the business has thought about its supply chain, and is ready when the business grows into scope.

The questions customers ask are usually predictable: whether you have a policy on modern slavery, whether you check your own suppliers, which countries you buy from, whether you use agency or temporary labour, and whether anything has been found and fixed. A supplier that can answer each of these with evidence, rather than a promise, is easier to approve and keeps its place on the customer's approved list when the customer reviews its supply base.

Proportion matters. A business with a short, low-risk supply chain does not need the same programme as one buying textiles or electronics from many countries. The statement should say honestly what the business does and why that is proportionate to its risks.

How to back the statement with supplier checks

A statement is only as good as the work behind it. The steps we would expect to see are:

• map direct suppliers by category and country, and identify where labour risk is highest
• adopt a supplier code of conduct and ask key suppliers to commit to it
• send a short questionnaire to higher-risk suppliers about recruitment, wages and subcontracting
• carry out on-site checks or audits where the risk justifies it
• agree corrective actions where problems are found, and track them
• record what was done, so next year's statement can report progress

On-site checks are where many statements fall short. Our supplier audit and due diligence work uses in-country audit partners to verify what suppliers say about their factories and workforce.

A Modern Slavery statement example structure

There is no prescribed format, but a statement that follows the six areas is easy for a reader to check. A typical structure looks like this:

• Introduction: the organisation, the financial year covered and the group entities included
• Our business and supply chains: what we buy, from which countries and through which types of supplier
• Our policies: the code of conduct, recruitment and whistleblowing policies that apply
• Due diligence: how suppliers are assessed before and after they are appointed
• Risk assessment: where risk is highest and why, and what we did about it this year
• Effectiveness: the indicators we track, such as supplier assessments completed and corrective actions closed
• Training: who was trained, on what, and how often
• Next year: the actions we commit to
• Approval and signature: board approval, director's name, title and date

Keep it readable. A buyer or evaluator should be able to understand in a few minutes what you do, where your risks are and what you have done about them.

Common weaknesses in statements

• Policy without practice. Describing a code of conduct but no checks on whether suppliers follow it.
• No risk prioritisation. Treating every supplier the same instead of focusing on the categories and countries where labour risk is highest.
• The same text every year. A statement that never changes suggests nothing has been done since it was first written.
• No measures. Claiming effectiveness without any indicator to show it.
• Missing formalities. No board approval, no director's signature or no homepage link.

Each of these is easy to spot for a customer's procurement team, and each is easy to fix once the supplier work is in place.

Frequently asked questions

For help writing a statement backed by real supplier checks, see our service for Modern Slavery statements.