Modern Slavery Statement (Hong Kong)

A Modern Slavery Statement in Hong Kong documents the organisation's approach and the obligations placed on those it covers.

The legal framework addressing forced labour and trafficking in Hong Kong comprises several statutes. The Crimes Ordinance (Cap. 200) criminalises trafficking in persons and related offences. Section 129 of Cap. 200 makes it an offence to traffic a person to, from, or through Hong Kong for exploitation, with penalties of up to imprisonment. The Employment Ordinance (Cap. 57) prohibits unlawful deduction of wages, restrictions on freedom of movement, and other conditions associated with forced labour. The Immigration Ordinance (Cap. 115) addresses illegal employment and the exploitation of undocumented workers — a significant modern slavery risk in Hong Kong's construction, domestic helper, and catering sectors. The Personal Data (Privacy) Ordinance (Cap. 486) is relevant to the collection and use of worker data in due diligence programmes.

Hong Kong companies listed on the Main Board or GEM of the Hong Kong Stock Exchange are subject to the HKEX ESG Reporting Guide, which was updated in 2021 with mandatory disclosure requirements on supply chain management under Aspect B8. While the Guide does not use the term 'modern slavery', it requires listed companies to identify and address environmental and social risks in their supply chains, including labour rights risks that encompass modern slavery and forced labour. The Guide also mandates disclosures under Aspect B1 (employment and labour practices) and Aspect B2 (health and safety). A Modern Slavery Statement serves as the primary vehicle through which Hong Kong listed companies address these supply chain disclosure obligations.

Hong Kong is identified by the US Department of State's Trafficking in Persons Report and the Global Slavery Index as a destination and transit territory for human trafficking, particularly affecting foreign domestic helpers from Indonesia, the Philippines, and other Southeast Asian countries — a population of approximately 370,000 workers — and low-wage workers in the construction, catering, and maritime sectors. Companies sourcing goods or services from high-risk regions or sectors should conduct heightened supply chain due diligence.

Forms-legal.com provides this Modern Slavery Statement template for Hong Kong companies seeking to meet their ESG disclosure obligations, satisfy UK and Australian legal requirements, or demonstrate responsible supply chain governance to investors and customers.

Forms-legal.com provides this Modern Slavery Statement template for Hong Kong-listed and multinational companies, covering Cap. 200 obligations, supply chain due diligence frameworks, HKEX ESG reporting requirements, remediation policy disclosures, and annual publication commitments aligned with international reporting standards.

A Modern Slavery Statement in Hong Kong is needed in several distinct situations, driven by legal obligations in other jurisdictions, HKEX listing requirements, or commercial expectations from international partners.

Hong Kong companies with annual revenue above GBP 36 million that supply goods or services in the United Kingdom are legally required to publish an annual modern slavery statement under Section 54 of the UK Modern Slavery Act 2015. A statement that is inadequate — failing to cover the six recommended areas of the Home Office guidance — exposes the company to reputational and commercial risk and may result in the Home Office publishing the company's name as non-compliant. Hong Kong exporters of clothing, electronics, food products, and manufactured goods that sell into the UK market commonly fall within this threshold.

Hong Kong companies with an annual consolidated revenue of AUD 100 million or more that operate in Australia or have Australian entities must comply with Australia's Modern Slavery Act 2018, which requires an annual modern slavery statement approved by the board and submitted to the Australian Border Force online register. Hong Kong holding companies with Australian subsidiaries are within scope.

HKEX-listed companies in Hong Kong must comply with the HKEX ESG Reporting Guide's mandatory disclosure requirements on supply chain management (Aspect B8) for financial years commencing on or after 1 July 2020. A Modern Slavery Statement is the most effective way for listed companies to document their supply chain due diligence processes, risk assessments, and remediation actions in a form that satisfies investor and analyst expectations.

Hong Kong companies seeking financing from international banks, development finance institutions, or ESG-linked bond markets are increasingly required to demonstrate modern slavery due diligence as a condition of financing. The Equator Principles, IFC Performance Standards, and ESG-linked loan frameworks used by major international banks all require borrowers to address human rights risks in their supply chains.

Garment, electronics, and consumer goods companies sourcing from manufacturers in South and Southeast Asia with substantial Hong Kong operations publish voluntary modern slavery statements to satisfy the expectations of international retail customers — particularly major UK, European, and North American retailers — who require supplier attestations as part of their own compliance programmes.

A Modern Slavery Statement published by a Hong Kong company must address the following key elements to meet the standards expected by regulators, investors, and international business partners. Section 129 of the Crimes Ordinance (Cap. 200) criminalises trafficking in persons to, from, or through Hong Kong. Section 32 of the Employment Ordinance (Cap. 57) prohibits unlawful wage deductions linked to debt bondage. Section 17D of the Immigration Ordinance (Cap. 115) creates criminal liability for employing persons without valid work authorisation — a key modern slavery risk vector. The Companies Registry, Labour Department, Immigration Department, and Office of the Privacy Commissioner for Personal Data (PCPD) each play enforcement roles relevant to modern slavery risk management in Hong Kong supply chains.

Organisation Structure and Supply Chains: The statement must describe the organisation's structure, including its principal business activities, the countries in which it operates, and the nature of its supply chains. For Hong Kong companies, this typically includes supply chains extending into mainland China, Southeast Asia, South Asia, and Africa — regions that carry higher modern slavery risk in certain industries. The statement should identify which tiers of the supply chain have been mapped and the methodology used for supply chain mapping.

Policies on Modern Slavery and Forced Labour: The statement must describe the company's policies addressing modern slavery, including: a supplier code of conduct prohibiting forced labour, debt bondage, document confiscation, and restriction of movement; a recruitment policy prohibiting the charging of recruitment fees to workers (a primary driver of debt bondage); a whistleblowing or grievance policy allowing workers to report concerns without fear of retaliation; and the company's commitment to the UN Guiding Principles on Business and Human Rights (UNGPs).

Risk Assessment and Due Diligence: The statement must explain how the company identifies and assesses modern slavery risks in its operations and supply chains. Risk assessment tools include the Global Slavery Index, sector-specific risk assessments, supplier questionnaires and self-assessments, third-party audits (such as SMETA, SA8000, or BSCI audits), and desktop reviews of country-level risk data. The statement should be specific about which geographies and supply chain tiers are assessed as higher risk and why.

Training and Capacity Building: The statement should describe the training provided to employees — particularly procurement, sourcing, and HR staff — on identifying indicators of forced labour and modern slavery. Indicators include workers who appear fearful, do not hold their own identity documents, show signs of physical abuse, live in employer-provided accommodation, or cannot speak freely. Training records and the number of employees trained in the reporting period should be disclosed.

Key Performance Indicators: Effective statements include measurable KPIs tracking progress, such as: the percentage of first-tier suppliers assessed against the supplier code of conduct; the number of supplier audits conducted; the number of grievances received and remediated; and the percentage of high-risk suppliers covered by enhanced due diligence.

Remediation: The statement must address what the company does when modern slavery is found in its supply chains — whether it exits the supplier relationship immediately, works with the supplier to remediate, or provides direct remediation to affected workers. The ILO's guidance and the Dhaka Principles for migrant worker recruitment provide frameworks for remediation.

Board Approval and Annual Review: For statements required under the UK Modern Slavery Act 2015 or Australia's Modern Slavery Act 2018, board-level approval by a director is mandatory. For HKEX-listed companies, ESG disclosures including supply chain risk disclosures must be reviewed and approved at board level. The statement should confirm the date and authority of approval and commit to annual review and update.

Forms-legal.com provides this Modern Slavery Statement template covering the full disclosure requirements expected of Hong Kong-listed companies under HKEX ESG reporting and by international investors and regulators. The template addresses supply chain mapping, risk assessment methodology, due diligence processes, remediation actions, KPI tracking against the United Nations Sustainable Development Goals, and board-level sign-off procedures under Cap. 200 and Cap. 622.