Modern Slavery Law.

Modern Slavery Act and Supply Chain Statements

The Modern Slavery Act 2015 was introduced to help prevent, identify and prosecute modern slavery offences, including slavery, servitude, forced or compulsory labour and human trafficking. The Act also includes transparency rules for large businesses, requiring them to publish an annual statement explaining the steps they have taken to address modern slavery risks within their businesses and supply chains.

Modern slavery can affect many sectors and may involve forced labour, criminal exploitation, sexual exploitation, domestic servitude, child exploitation or human trafficking. Businesses are expected to understand the risks in their operations and supply chains and take proportionate steps to prevent exploitation.

Which Businesses Must Publish a Modern Slavery Statement?

Under section 54 of the Modern Slavery Act 2015, a commercial organisation must publish a slavery and human trafficking statement if it supplies goods or services, carries on business or part of a business in the UK, and has a total annual turnover of at least £36 million.

This requirement can apply to UK businesses and overseas businesses that carry on business in the UK. Parent companies and subsidiaries may also need to consider whether they are individually in scope, depending on their turnover, structure and UK business activity.

What Should the Statement Cover?

A modern slavery statement should explain the steps the organisation has taken during the financial year to ensure that slavery and human trafficking are not taking place in its own business or supply chains. If no steps have been taken, the statement must say so clearly.

Government guidance recommends that statements include information on the organisation's structure, business and supply chains, policies, due diligence processes, risk assessment and management, effectiveness measures, and staff training. The statement should be specific to the organisation and should be reviewed and updated each year.

Approval and Publication

The statement should be approved at a senior level. For a company, this usually means approval by the board of directors and a director's signature. The statement should be published on the organisation's website, with a prominent link from the homepage.

The purpose is not simply to produce a document, but to show what practical steps the organisation is taking to identify and reduce modern slavery risks. A weak or generic statement may technically disclose limited action, but it can still create reputational, commercial and governance risk.

Supply Chain Responsibility

The Act does not automatically make a business legally liable for every Act of modern slavery committed by a supplier. However, businesses are expected to take modern slavery risks seriously and to carry out appropriate due diligence, especially where supply chains involve higher-risk countries, sectors, labour arrangements or subcontracting.

Customers, investors, employees, public bodies and business partners may all expect organisations to show that they have proper systems in place to identify and address exploitation risks.

Failure to Comply

If an organisation fails to publish a required statement, the Secretary of State may seek an injunction requiring compliance. Failure to comply with an injunction can lead to contempt of court and an unlimited fine.

Even where formal enforcement action is not taken, failure to produce a proper statement can damage trust and may affect tenders, contracts, investment, procurement and public reputation.

Getting Legal Advice

Businesses unsure whether they need to publish a modern slavery statement should seek legal advice. Advice may also be needed when preparing supply chain policies, supplier terms, due diligence processes, procurement documents, board approval procedures or annual compliance statements.

Find a Business Law Solicitor

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