Modern Slavery Statements

Section 54 of the Modern Slavery Act 2015 requires commercial organisations that supply goods or services, carry on part of their business in the UK, and have an annual turnover of £36 million or more to publish a slavery and human trafficking statement for each financial year. The obligation extends to parent companies on behalf of subsidiaries that do not individually meet the threshold.

The Home Office maintains a public registry where statements must be submitted. The statement must be published on your company website (with a prominent link in the homepage footer) and submitted to the registry each year. While there is currently no direct financial penalty for non-compliance, the government has indicated its intention to introduce penalties and has publicly named non-compliant companies.

The Act specifies up to six areas a statement may cover — the government's guidance strongly recommends addressing all of them:

1. Organisation structure and supply chains — what you do and who your key suppliers are
2. Policies in relation to slavery and human trafficking
3. Due diligence processes for identifying and addressing risks
4. Risk assessment — identifying higher-risk parts of your supply chain
5. Key performance indicators and how effective your policies have been
6. Training provided to staff

The statement must be approved and signed by a director (or equivalent) and approved by the board. Statements that say "we have found no issues" without any evidence of due diligence are increasingly criticised by investors and NGOs as inadequate.

If your business does not meet the £36 million threshold, you are not legally required to publish a statement. However, you may be asked to provide evidence of your anti-slavery approach by large customers who are required to publish statements about their supply chains — if you cannot demonstrate compliance, you may lose contracts.

Good practice for any business regardless of size includes: having a basic modern slavery policy; conducting proportionate due diligence on high-risk supply chains (e.g. those involving overseas manufacturing, labour-intensive industries, or complex subcontracting); training relevant staff; and having a mechanism for workers or suppliers to report concerns. The Gangmasters and Labour Abuse Authority (GLAA) can provide guidance for higher-risk sectors.