Modern Slavery Statement (England & Wales)

A Modern Slavery Statement in the United Kingdom sets out the standards, responsibilities, and procedures the organisation expects everyone to follow, and takes its legal force from the Modern Slavery Act 2015.

The Modern Slavery Act 2015 is landmark legislation that consolidated and strengthened the law on slavery, servitude, forced labour, and human trafficking in England and Wales. Section 1 of the Act creates offences of holding a person in slavery or servitude or requiring a person to perform forced or compulsory labour. Section 2 creates offences of human trafficking, defined broadly to include arranging or facilitating the travel of another person with a view to their exploitation through means including deception, coercion, or abuse of a position of vulnerability. These offences carry a maximum sentence of life imprisonment.

Section 54 introduces the supply chain transparency obligation — a civil rather than criminal mechanism designed to encourage large businesses to take responsibility for addressing modern slavery risks throughout their operations and supply chains. The statement requirement was inspired by the California Transparency in Supply Chains Act 2010 and similar legislation adopted in other jurisdictions, and the UK provision goes further by requiring board-level approval and director signature.

The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 set the annual turnover threshold at £36 million, capturing tens of thousands of commercial organisations operating in the UK. These organisations are required to produce a statement for each financial year, publish it on their website, and approve it at board level.

The Home Office updated its statutory guidance on section 54 in May 2021, strengthening expectations around the content and quality of statements. The updated guidance introduced a free government registry for modern slavery statements, enabling civil society, investors, and the public to compare and assess the quality of disclosures. The government also consulted on introducing financial penalties for non-compliance and for publishing poor-quality statements, reflecting the increasing seriousness with which this obligation is treated.

The legal framework governing the Modern Slavery Statement (England & Wales) in United Kingdom draws on several key statutes and regulatory bodies. Under the Companies Act 2006, Companies House maintains the register of UK companies. Section 386 of the Companies Act 2006 sets accounting record obligations. The Competition and Markets Authority (CMA) enforces the Consumer Rights Act 2015. The Financial Conduct Authority (FCA) regulates financial services under the Financial Services and Markets Act 2000. The High Court of Justice has jurisdiction under the Senior Courts Act 1981. Parties executing a Modern Slavery Statement (England & Wales) in United Kingdom should confirm the document reflects current law, including any amendments enacted since the original drafting date. The Modern Slavery Act 2015 sets the foundational requirements.

A Modern Slavery Statement is legally required under section 54 of the Modern Slavery Act 2015 for any commercial organisation that: (a) supplies goods or services in any sector; (b) carries on a business, or part of a business, in the United Kingdom; and (c) has an annual turnover (calculated on a group basis, including subsidiaries) of £36 million or more.

The obligation applies broadly. An organisation "carries on business in the United Kingdom" if it has a fixed place of business in the UK, or if it otherwise carries on activities with a sufficient connection to the UK. An overseas parent company with UK subsidiaries may be caught if those subsidiaries' turnover is included in the group total and the group supplies goods or services in the UK. Many overseas organisations with UK business operations have chosen to publish statements on a precautionary basis.

The statement must cover the financial year of the organisation. For most UK companies, this is a twelve-month period ending on a date specified in their articles of association. The Home Office guidance recommends publishing the statement within six months of the financial year end, though the Act itself does not specify a deadline. The statement must remain available on the company's website for as long as it is the most recent statement for that financial year.

Section 54(6) requires that, for a company, the statement is approved by the board of directors and signed by a director. For a limited liability partnership, it must be approved by the members and signed by a designated member. For any other type of partnership, it must be signed by a partner. These requirements mean that the statement cannot be delegated to a junior member of staff — it requires formal governance involvement.

Beyond the statutory threshold, many organisations publish modern slavery statements voluntarily. This includes smaller companies that are suppliers to large businesses and wish to demonstrate compliance, non-profit organisations and charities that operate supply chains, and public sector bodies that wish to demonstrate good practice. Additionally, organisations that operate in high-risk sectors (garment manufacturing, construction, agriculture, hospitality, cleaning and security services, and domestic services) should engage with modern slavery due diligence regardless of size, as the risk of modern slavery in their supply chains may be significant.

Section 54(5) of the Modern Slavery Act 2015 identifies six areas that a transparency statement may cover. The Home Office statutory guidance, updated in 2021, makes clear that a credible and thorough statement should address all six areas substantively rather than merely acknowledging that they exist.

Organisational structure and supply chains provides the context for the statement. It should describe the organisation's structure, including any subsidiaries and affiliated entities, its business activities and the sector in which it operates, and the nature and geographic scope of its supply chains. A statement that identifies supply chain countries and categories of supplier provides a more useful basis for risk assessment than a generic description. The Home Office guidance notes that understanding who is in the supply chain is a prerequisite for all other steps.

Policies relevant to modern slavery and human trafficking should be identified and briefly described. These may include a standalone modern slavery policy, a supplier code of conduct, a whistleblowing or speak-up policy, a responsible recruitment policy, a code of business conduct, and a human rights policy. The statement should confirm that these policies are implemented and reviewed regularly, and how they are communicated to employees and supply chain partners.

Due diligence processes describe what the organisation does in practice to identify and address modern slavery risk. This may include supplier audits (including unannounced visits), self-assessment questionnaires, membership of industry platforms such as Sedex or the Ethical Trading Initiative, contractual anti-slavery obligations, checks on labour providers against the GLAA licensing register, and worker grievance and speak-up mechanisms accessible to supply chain workers.

Risk assessment should identify the parts of the organisation's business and supply chains where modern slavery risk is greatest. Risk factors include country risk (using indices such as the Global Slavery Index), sector risk (garment manufacturing, construction, domestic services, and agriculture carry elevated risk), relationship risk (direct employment versus supply chain), and vulnerability risk (migrant workers, seasonal workers, and workers recruited through agencies are at elevated risk). The statement should explain the methodology used to assess risk and the findings of that assessment.

Key performance indicators and effectiveness measures demonstrate that the organisation is not merely describing activities but is measuring and improving outcomes. KPIs may include the percentage of high-risk suppliers audited annually, the number of corrective action plans issued and closed, training completion rates, the number of worker concerns raised through grievance mechanisms, and the number of supplier relationships terminated due to non-remediation of modern slavery issues.

Training provision should describe what training is given to which categories of staff, how frequently, and whether it is mandatory. The Home Office guidance recommends targeted training for those in procurement, HR, and supply chain management roles, as well as awareness training for all staff. Training records should be maintained and reported against as a KPI. The forms-legal.com Modern Slavery Statement (England & Wales) template covers the mandatory elements under Modern Slavery Act 2015.