Written by Joanne Hughes, Policy & Compliance Specialist at Policy Pros
Last reviewed:
Modern Slavery Policy Writers
Why UK Businesses Need a Modern Slavery Policy
In the UK, addressing modern slavery within business operations and supply chains is not only a legal obligation but also a moral imperative. The Modern Slavery Act 2015 requires certain businesses to publish annual statements detailing actions taken to combat slavery and human trafficking.
Modern slavery encompasses slavery, servitude, forced or compulsory labour and human trafficking. It is a global issue that affects every country and every sector. UK businesses have a critical role to play in identifying and eradicating modern slavery from their operations and supply chains, and a clear, well-drafted policy is the foundation for doing so.
The Legal Framework: The Modern Slavery Act 2015
The Modern Slavery Act 2015 is a landmark piece of UK legislation aimed at combating modern slavery and human trafficking. The Act consolidated and strengthened earlier legislation, creating a comprehensive legal framework for the prosecution of offenders, the protection of victims, and the prevention of modern slavery in business supply chains.
The Act applies to all organisations with an annual turnover of 36 million pounds or more, requiring them to produce a yearly transparency statement under Section 54. This statement must detail the steps taken to identify and address any instances of modern slavery in their operations and supply chains. The statement must be approved by the board of directors and signed by a director, and it must be published on the organisation's website with a prominent link from the homepage.
The Companies Act 2006 further supports these obligations by requiring directors to have regard to the impact of the company's operations on the community and the environment when exercising their duties under Section 172. This includes considering the ethical dimensions of the company's supply chain and operational practices.
Section 54 Transparency Statements
The Section 54 transparency statement is the most visible component of an organisation's modern slavery compliance. While the legislation does not prescribe the exact content of the statement, the Home Office guidance suggests that it should cover:
The organisation's structure, business and supply chains
Its policies in relation to slavery and human trafficking
Its due diligence processes in relation to slavery and human trafficking in its business and supply chains
The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps taken to assess and manage that risk
Its effectiveness in ensuring that slavery and human trafficking is not taking place, measured against performance indicators it considers appropriate
The training available to its staff about slavery and human trafficking
Organisations that fail to produce a statement may face civil proceedings brought by the Secretary of State, including an injunction requiring compliance. While there is currently no direct financial penalty for non-compliance with Section 54, the reputational consequences of failing to publish a statement can be significant. The UK Government's Modern Slavery Statement Registry allows the public and other stakeholders to search for and review the statements published by organisations.
Due Diligence and Supply Chain Requirements
A critical step in policy implementation is conducting thorough due diligence across the organisation's supply chain. This is particularly important for organisations with complex, multi-tier supply chains that extend into higher-risk countries or sectors. Key due diligence measures include:
Mapping the supply chain to identify where goods and services originate and where the greatest risks of modern slavery exist
Vetting suppliers and requiring them to confirm their own compliance with modern slavery legislation
Conducting audits of supplier premises, including unannounced visits where appropriate
Ensuring recruitment and labour practices are transparent, particularly where agencies or labour providers are used
Incorporating modern slavery clauses into supplier contracts, with clear provisions for termination in the event of non-compliance
Higher-risk sectors include agriculture, construction, manufacturing, hospitality, care and domestic work. Organisations operating in or sourcing from these sectors should apply particularly rigorous due diligence procedures. The supply chain management policies we develop at Policy Pros are designed to integrate modern slavery due diligence into your existing procurement and supplier management processes.
Reporting Thresholds and Practical Compliance
While the Section 54 reporting obligation applies to organisations with an annual turnover of 36 million pounds or more, best practice guidance from the Home Office encourages all organisations, regardless of size, to take steps to address modern slavery risks. Many smaller organisations are also required by their clients or contracting partners to demonstrate compliance as a condition of doing business.
Organisations should establish clear internal reporting mechanisms to enable employees, contractors and agency workers to raise concerns about suspected modern slavery. These mechanisms should be linked to the organisation's whistleblowing policy and should provide assurance that reports will be handled confidentially and without fear of retaliation.
Training, Awareness and Continuous Improvement
Educating and training employees about modern slavery is vital. This includes understanding the signs of slavery and human trafficking, knowing how to report concerns, and ensuring that all levels of the business are committed to the policy. Training should be regular and tailored to different roles within the company, especially those involved in procurement and supply chain management.
Continuous monitoring and evaluation of the policy's effectiveness are crucial. This includes keeping records of due diligence activities, supplier audits, and training sessions. The annual transparency statement should reflect these efforts, detailing progress and plans for improvement. Businesses should be transparent about the challenges faced and how they are addressing them.
Implementing a robust modern slavery policy has far-reaching benefits. It helps protect vulnerable individuals, enhances the company's reputation, and builds trust with customers and stakeholders. It also encourages ethical business practices, which can lead to sustainable, long-term relationships with suppliers and partners.
How We Can Help
We write and review modern slavery policies for all company and organisation types, from non-profits to government and blue chips. Our policies are tailored to your sector, your supply chain complexity and your reporting obligations under the Modern Slavery Act 2015. We also assist with the preparation of Section 54 transparency statements and can support your organisation in developing the due diligence frameworks needed to demonstrate genuine compliance. View our full range of policy and procedure services to see how we can help.
