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.

The Modern Slavery Act 2015 currently imposes no direct financial penalty on companies that fail to publish a statement. However, the enforcement landscape is shifting. The government has repeatedly announced its intention to introduce civil penalties for non-compliance with section 54, and the Home Office publicly names companies that are required to publish but have not done so. Reputational damage and exclusion from public procurement are the most immediate practical consequences.

On procurement, the Procurement Act 2023 (which came into force in February 2024) strengthened public sector buyer obligations to consider supplier conduct on social value, including modern slavery risks. Contracting authorities now have explicit powers to exclude suppliers from procurements on the basis of grave professional misconduct — which can include persistent failure to address modern slavery risks in supply chains. This is particularly significant for businesses that depend on government contracts.

Beyond statutory compliance, institutional investors, large corporates, and ESG-focused buyers are increasingly using modern slavery statements as a screening tool. Statements published on the Home Office registry are publicly searchable. The quality of your statement — how specific it is about risks found, actions taken, and KPIs — is scrutinised by NGOs such as the Business and Human Rights Resource Centre, which publishes annual rankings of statement quality for major companies. Even below the mandatory threshold, proactively publishing a voluntary statement can demonstrate responsible sourcing to clients and investors.

The Gangmasters and Labour Abuse Authority (GLAA) has investigative and enforcement powers for labour exploitation offences. For higher-risk sectors — agriculture, horticulture, shellfish gathering, food processing, construction, and cleaning — the GLAA can investigate supply chains and prosecute offences under the Modern Slavery Act independently of whether a company has published an adequate statement. Serious cases can result in convictions carrying unlimited fines and up to life imprisonment for perpetrators.