Modern Slavery Statement (Singapore)

A Modern Slavery Statement in Singapore sets out the standards and procedures the organisation expects its people to follow.

Singapore's legal framework addresses modern slavery through the Prevention of Human Trafficking Act 2014 (PHTA, Act No. 45 of 2014), which criminalises trafficking in persons for the purposes of exploitation — including forced labour, sexual exploitation, and servitude — with penalties of up to 15 years' imprisonment and fines of up to S$150,000 under Section 3 of the PHTA. The Employment of Foreign Manpower Act (EFMA, Cap. 91A) protects foreign workers in Singapore from exploitative employment practices, and the Ministry of Manpower (MOM) enforces work pass conditions prohibiting employers from retaining workers' passports, charging excessive recruitment fees, or imposing unlawful salary deductions. The Penal Code (Cap. 224) criminalises forced labour, servitude, and debt bondage under Sections 370 and 370A.

Companies listed on the Singapore Exchange (SGX) are subject to sustainability reporting requirements under SGX Listing Rules Practice Note 7.6 (Sustainability Reporting Guide), which requires listed companies to report on material environmental, social, and governance (ESG) factors — including labour practices and human rights — using recognised reporting frameworks such as the Global Reporting Initiative (GRI) Standards, the Task Force on Climate-related Financial Disclosures (TCFD), and the Sustainability Accounting Standards Board (SASB) standards. The SGX Sustainability Reporting Advisory Committee recommends disclosure on supply chain labour practices as a material social factor for companies with global supply chains.

The Companies Act 1967 (Cap. 50) requires Singapore-incorporated companies to maintain proper records and make disclosures in their annual reports — Modern Slavery Statements prepared voluntarily may be included as part of the company's ESG reporting. Related documents include the company's corporate governance policies, supply chain due diligence frameworks, and whistleblowing policies addressing the reporting of modern slavery concerns.

The Prevention of Human Trafficking Act 2014 (PHTA), the Employment of Foreign Manpower Act (EFMA, Cap. 91A), and the Penal Code (Cap. 224) form the statutory framework against forced labour applicable to this document in Singapore, while disclosure obligations may also arise under the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, and SGX Listing Rules Practice Note 7.6. The Personal Data Protection Act 2012 (PDPA, No. 26 of 2012) applies to any personal data collected, used, or disclosed in connection with this document, and the Personal Data Protection Commission (PDPC) oversees compliance with the PDPA's consent, purpose limitation, and data protection obligations.

A Modern Slavery Statement is needed by companies operating in or from Singapore whenever legal obligations under foreign legislation, stock exchange listing requirements, or voluntary corporate responsibility commitments require disclosure of anti-modern-slavery efforts within the company's operations and supply chains.

Singapore-headquartered companies with annual turnover exceeding GBP 36 million and carrying on business in the United Kingdom must publish a Modern Slavery Statement under Section 54 of the UK Modern Slavery Act 2015. The statement must be published on the company's website within 6 months of the end of the financial year, and must describe the steps taken to identify and address modern slavery risks — or state that no such steps have been taken. Non-compliance may result in enforcement action by the UK Home Office and reputational damage.

Singapore companies with consolidated revenue of AUD 100 million or more and carrying on business in Australia must comply with the Australian Modern Slavery Act 2018 (Cth), which requires annual Modern Slavery Statements to be submitted to the Australian Border Force and published on the Australian Government's Modern Slavery Register. The Australian Act prescribes mandatory reporting criteria including the reporting entity's structure, operations, and supply chains; the risks of modern slavery practices; and the actions taken to assess and address those risks.

SGX-listed companies subject to the sustainability reporting requirements under SGX Listing Rules Practice Note 7.6 should prepare Modern Slavery Statements as part of their ESG disclosure on material social factors — particularly companies operating in industries with recognised forced labour risks, including construction, manufacturing, agriculture, electronics assembly, and domestic work sectors prevalent in Singapore and the ASEAN region.

Multinational companies headquartered in Singapore with supply chains extending to countries identified by the International Labour Organization (ILO) or the US Department of State's Trafficking in Persons Report as having high prevalence of forced labour — including parts of Southeast Asia, South Asia, and sub-Saharan Africa — should publish Modern Slavery Statements as part of their corporate responsibility and supply chain governance frameworks, consistent with the UNGPs and the OECD Guidelines for Multinational Enterprises.

Companies participating in industry certification programmes — such as the Responsible Business Alliance (RBA) for electronics, the Roundtable on Sustainable Palm Oil (RSPO) for palm oil, or the Fair Labor Association (FLA) for apparel — are typically required to disclose their modern slavery prevention efforts as a condition of membership or certification.

A Modern Slavery Statement prepared by a Singapore company — whether under mandatory foreign legislation or voluntary established procedures — should include the following elements consistent with the UK Modern Slavery Act 2015 Section 54, the Australian Modern Slavery Act 2018 mandatory reporting criteria, and the United Nations Guiding Principles on Business and Human Rights.

Organisation details must specify the company's full legal name, Unique Entity Number (UEN) as registered with ACRA, registered office address, principal business activities, and the reporting period covered by the statement. For corporate groups, the statement should identify the parent company, material subsidiaries, and the geographic scope of operations covered — specifying whether the statement covers Singapore operations only or global operations including overseas subsidiaries and joint ventures.

Business structure and supply chains must describe the company's organisational structure, operational footprint (number of employees, facilities, and countries of operation), and supply chain architecture — including the tiers of suppliers engaged, the geographic distribution of suppliers, the industries and sectors represented in the supply chain, and the categories of goods and services procured. Singapore companies operating in sectors with recognised modern slavery risks — construction (where foreign workers on Work Permits and S Passes are employed), manufacturing, domestic work, and food services — should provide detailed descriptions of their workforce composition and supplier engagement.

Risk assessment and due diligence must describe the processes used to identify, assess, and prioritise modern slavery risks within the company's operations and supply chains — including supplier audits, worker interviews, risk mapping tools, grievance mechanisms, and third-party assessments. The Prevention of Human Trafficking Act 2014 (PHTA) and the Employment of Foreign Manpower Act (EFMA) provide the statutory framework for identifying trafficking and forced labour indicators in Singapore. The Ministry of Manpower (MOM) publishes indicators of forced labour, including retention of identity documents, non-payment or underpayment of wages, excessive working hours, restriction of movement, and debt bondage.

Policies and procedures must summarise the company's policies addressing modern slavery — including the company's human rights policy, supplier code of conduct, recruitment policy (particularly for foreign workers engaged through recruitment agencies), whistleblowing policy, and grievance mechanisms accessible to workers and third parties. The forms-legal.com Modern Slavery Statement template includes model policy provisions aligned with the International Labour Organization (ILO) indicators of forced labour and the Dhaka Principles for Migration with Dignity.

Training and awareness must describe the training programmes provided to employees, managers, procurement staff, and supply chain partners on identifying and responding to modern slavery indicators — including the company's escalation procedures and reporting channels. The Inter-Agency Taskforce on Trafficking in Persons (IATIP), co-chaired by MOM and the Ministry of Home Affairs (MHA), provides resources and training materials on trafficking indicators in Singapore.

Effectiveness measurement must describe how the company assesses the effectiveness of its anti-modern-slavery measures — including key performance indicators (KPIs), audit findings, grievance statistics, remediation actions taken, and year-on-year progress. The Australian Modern Slavery Act 2018 specifically requires reporting entities to describe how they assess the effectiveness of their actions.

Approval and signature must include the statement's approval by the company's board of directors and signature by a director or senior officer — the UK Modern Slavery Act 2015 Section 54(6) requires the statement to be approved and signed. Publication on the company's website homepage with a prominent link is required under both the UK and Australian Acts.