Modern Slavery Statements for Public Sector Tenders
Public sector buyers increasingly ask bidders for a modern slavery statement or policy, even when the supplier sits below the legal threshold for publishing one. Understanding the difference between the legal duty and what buyers actually expect helps you answer these questions without either over-committing or falling short.
The legal duty comes from section 54 of the Modern Slavery Act 2015. The tender expectation is broader, because buyers want assurance that the suppliers in their chain are managing the risk of forced labour and human trafficking.
This guide explains the section 54 threshold, why smaller suppliers are still asked, and what a tender-ready statement should contain.
The Section 54 Threshold
Under section 54 of the Modern Slavery Act 2015, a commercial organisation must publish an annual modern slavery statement if it supplies goods or services, carries on business in the UK, and has an annual turnover of 36 million pounds or more. The statement must be approved at board level, signed by a director, and published on the organisation's website with a link in a prominent place on the homepage.
Below 36 million pounds turnover there is no legal duty to publish. Many organisations choose to publish voluntarily, but it is not required by the Act.
Why Buyers Ask Smaller Suppliers Anyway
A public sector buyer is responsible for the integrity of its own supply chain, so it pushes due diligence down to the suppliers it appoints. Even where a supplier is below the section 54 threshold, the buyer may ask for a modern slavery policy, evidence of supplier checks, or a short statement of approach.
This is proportionate due diligence, not a demand for a full published statement. A smaller supplier answers it with a policy and a description of the practical steps it takes, rather than a board-approved annual statement.
What a Tender-Ready Statement Should Contain
The Home Office guidance sets out the areas a statement should cover. Even a voluntary or proportionate version is stronger when it addresses these:
| Area | What to cover |
|---|---|
| Organisation structure and supply chains | What you do and where your risks sit |
| Policies on modern slavery | The policy and how it is communicated |
| Due diligence processes | Checks on suppliers and how risks are managed |
| Risk assessment and management | How you identify and prioritise higher-risk areas |
| Training | Awareness for staff and those managing suppliers |
| Effectiveness and KPIs | How you measure whether the steps are working |
Common Mistakes
- Assuming no statement is needed because the business is below £36m, when the buyer asked for a policy or approach.
- Publishing a statement with no director sign-off where section 54 applies.
- A statement that lists policies but describes no actual due diligence.
- No link to the statement from the homepage where it is legally required.
- Copying a template that names another organisation's supply chain.
How Policy Pros Can Help
We write modern slavery policies and statements that match your size and risk, whether you need a full section 54 statement or a proportionate policy for a tender. Our modern slavery policies service produces the document and the due diligence framework behind it.
For bids specifically, our tender and proposal support service writes the statement as part of a complete bid library, so it sits alongside your social value and carbon responses.
To see where it fits in the wider picture, read our guide to documents needed for public sector tenders.
Frequently Asked Questions
Do I need a modern slavery statement to bid for public contracts?
Legally, you only have to publish an annual modern slavery statement under section 54 of the Modern Slavery Act 2015 if your turnover is £36 million or more. Below that there is no legal duty, but public sector buyers often still ask for a modern slavery policy or a short statement of approach as part of supply chain due diligence.
What is the modern slavery turnover threshold?
The threshold is £36 million in annual turnover. At or above it, a commercial organisation carrying on business in the UK must publish an annual statement, approved at board level, signed by a director and linked prominently from its homepage. Below it, publication is voluntary.
Why do buyers ask smaller suppliers for a modern slavery statement?
Buyers are responsible for their own supply chains, so they push due diligence down to the suppliers they appoint. For a smaller supplier this usually means a modern slavery policy and a description of the checks you carry out, rather than a full board-approved annual statement.
What should a modern slavery statement include?
Home Office guidance suggests covering your organisation structure and supply chains, your modern slavery policies, your due diligence processes, your risk assessment and management, relevant training, and how you measure effectiveness. A statement that lists policies but describes no actual due diligence is weak in a tender.
