The Modern Slavery Act 2015 is one of the UK’s most significant pieces of social governance legislation. It requires certain businesses to publish an annual statement confirming the steps they have taken to ensure that modern slavery and human trafficking are not taking place in their operations or supply chains. Despite being in force since 2015, compliance remains inconsistent — and the government has signalled its intention to strengthen enforcement significantly.
This guide explains what the Modern Slavery Act requires, which businesses are affected, what a compliant statement must include, and how to approach supply chain due diligence in a way that reflects genuine commitment rather than compliance theatre.
What is modern slavery? |
| Modern slavery encompasses forced labour, debt bondage, human trafficking, domestic servitude, and sexual exploitation. It is present in every country in the world, including the UK. High-risk sectors include agriculture, food processing, construction, cleaning and hospitality services, and garment manufacturing — all sectors where UK businesses commonly have supply chain exposure. |
Who Must Comply With the Modern Slavery Act?
Section 54 of the Modern Slavery Act 2015 requires any commercial organisation that:
- Supplies goods or services in the UK, AND
- Has an annual turnover of £36 million or more (including the turnover of any subsidiary or holding company)
…to publish a transparency statement each financial year, approved by the board of directors (or equivalent), setting out the steps the organisation has taken to ensure modern slavery is not taking place in its operations or supply chains.
Organisations below the £36m threshold are not legally required to publish a statement. However, even smaller businesses may face modern slavery reporting requirements through their supply chain — large customers and procurement bodies increasingly require their suppliers to provide modern slavery statements or complete due diligence questionnaires, regardless of the supplier’s turnover.
What Must a Modern Slavery Statement Include?
The Act specifies six areas that a statement may cover. While none are mandatory individually, the Home Office’s guidance (and emerging best practice) is that a meaningful statement should address all six:
| AREA | WHAT TO COVER |
|---|---|
| 1. Organisation’s structure, business, and supply chains | Describe the nature of your business, the sectors you operate in, the countries where you source goods or services, and the structure of your supply chain. |
| 2. Policies in relation to slavery and human trafficking | Describe your policies relevant to modern slavery — supplier code of conduct, whistleblowing policy, recruitment policy, and any specific modern slavery policy. |
| 3. Due diligence processes | Describe the processes you use to assess and manage modern slavery risk in your operations and supply chain — supplier assessments, audits, questionnaires, and risk mapping. |
| 4. Risk assessment and management | Identify the parts of your business and supply chain that carry higher modern slavery risk and explain how you manage those risks. |
| 5. Key performance indicators | Report on metrics that demonstrate the effectiveness of your modern slavery prevention activity — number of suppliers assessed, audits conducted, issues identified and resolved. |
| 6. Training | Describe the training provided to staff — particularly procurement and supply chain staff — on identifying and responding to modern slavery risks. |
Supply Chain Due Diligence in Practice
The supply chain element of modern slavery compliance is where most businesses face the greatest challenge — and where the greatest risk of genuine modern slavery exposure lies. A credible supply chain due diligence programme typically involves:
Supply Chain Mapping
Before you can assess modern slavery risk, you need to understand your supply chain. For many organisations, this is harder than it sounds — particularly for indirect procurement, where the chain of suppliers can be long and opaque. A basic supply chain map identifies your first-tier suppliers (those you buy from directly) and, for higher-risk categories, second and third-tier suppliers (those your suppliers buy from).
Risk Assessment
Not all suppliers carry equal modern slavery risk. A risk-based approach focuses due diligence effort on higher-risk suppliers — those operating in high-risk sectors (construction, cleaning, food processing, garment manufacturing), those sourcing from high-risk geographies, and those using agency or subcontracted labour. A supplier risk matrix, scoring suppliers against these risk factors, allows you to prioritise your due diligence effort proportionately.
Supplier Assessment
For higher-risk suppliers, a supplier self-assessment questionnaire is the standard starting point — asking suppliers to confirm their own modern slavery policies and controls, and to provide information about their own supply chains. For the highest-risk suppliers, independent audits of supplier facilities may be warranted.
Remediation
If due diligence uncovers a modern slavery risk or incident, the response should focus on remediation — working with the supplier to address the issue, rather than simply terminating the relationship (which may leave workers in a more vulnerable position). Developing a remediation protocol in advance of identifying issues is best practice.
Penalties for Non-Compliance
Currently, the primary enforcement mechanism for non-compliance with Section 54 is reputational — the Home Office publishes a list of companies that have not submitted statements, and non-compliance is increasingly visible to investors, customers, and NGOs. The government has announced its intention to introduce civil penalties for non-compliance, though legislation has not yet been enacted.
For public sector suppliers, non-compliance can result in exclusion from procurement processes — a significant commercial consequence. Several large organisations have also been the subject of public campaigns and litigation in relation to supply chain labour standards.
How Elberra Consulting Supports Modern Slavery Compliance
Elberra Consulting helps UK businesses develop credible, proportionate modern slavery compliance programmes — including policy development, supply chain risk assessment, supplier due diligence processes, and annual statement drafting. Our approach integrates modern slavery compliance into the broader ESG governance framework, ensuring it is embedded in your operations rather than treated as a standalone compliance exercise.
Need support with Modern Slavery Act compliance? |
| Elberra Consulting can help you develop a credible modern slavery statement and supply chain due diligence programme proportionate to your business’s size and risk profile. |
| Book your free ESG consultation → elberraconsulting.co.uk/free-consultation/ |
Frequently Asked Questions
Does the Modern Slavery Act apply to charities?
Yes. The Modern Slavery Act applies to all commercial organisations supplying goods or services in the UK with turnover above £36m — including charities. A charity that meets the turnover threshold and provides services (for example, a large care charity providing regulated care services) must publish a modern slavery statement. Many charities also voluntarily publish statements as part of their broader ESG and governance commitments, even if below the threshold.
How often must a modern slavery statement be published?
A modern slavery statement must be published annually, within six months of the organisation’s financial year end. Each statement should reflect on progress since the previous year and should not simply be a repeat of the previous year’s statement. The Home Office’s modern slavery statement registry allows anyone to search and compare statements — raising the reputational stakes for statements that show no year-on-year improvement.
What is a Tier 1 supplier?
A Tier 1 supplier is a supplier from whom you buy directly — the first link in your supply chain. Tier 2 suppliers are those that your Tier 1 suppliers buy from. In practice, modern slavery risk is often higher in Tier 2 and 3 suppliers than in Tier 1, because more distant parts of the supply chain are typically subject to less oversight and scrutiny.
