Modern Slavery Statement Explained 

What it is, who needs one, and how to write a credible UK statement

A modern slavery statement (sometimes called a Transparency in Supply Chains statement) can feel like a compliance document you publish once a year and then forget about. In reality, it sits at the intersection of law, procurement, reputation and operational risk. When written well, it becomes a useful map of where exploitation could occur in your business and supply chain, and what you are doing to prevent it. When written badly, it can have the opposite effect. Stakeholders may read it as a signal that senior leaders do not understand their risks or do not take them seriously.

That matters because modern slavery risks often hide inside ordinary-looking business activity. They can sit within labour supply chains, subcontracting, recruitment practices, seasonal peaks, or pressure to deliver at the lowest possible cost. As your organisation scales, those risk factors tend to increase. At the same time, customer expectations frequently outpace legal obligations. Many SMEs are asked to provide modern slavery evidence long before they reach the legal reporting threshold, because larger clients want assurance throughout their supply base.

This guide is designed for UK SMEs scaling towards the £36m threshold, in-scope organisations that must comply with Section 54 of the Modern Slavery Act 2015, and suppliers that are regularly asked for evidence by clients. It explains what a modern slavery statement is, what it must include, how to approve and publish it correctly, and how to move from ‘tick-box’ wording to credible actions and measurable progress. Along the way you will find practical checklists, examples of what good looks like, and realistic next steps you can take without turning the statement into a never-ending project.

What Is a Modern Slavery Statement?

A modern slavery statement is a public, annual statement that explains what your organisation has done during the financial year to prevent modern slavery in your operations and supply chains – or, if you have taken no steps, the statement must say so clearly. The duty comes from Section 54 of the Modern Slavery Act 2015, which aims to increase transparency and drive better practice through public scrutiny and leadership accountability. (GOV.UK)

In plain terms, the statement is not meant to be a glossy values page. It should describe your real work. That includes how you identify and prioritise risk, how you check suppliers and labour providers, how you respond when you find issues, and how you track whether your approach is working.

It also helps to be clear about what the statement is not:

• It is not a guarantee that slavery does not exist in your supply chain.
• It is not a legal contract with your customers.
• It is not a marketing brochure.

Instead, it is a structured explanation of governance, risk and actions. Many procurement teams treat it as a screening document. Meanwhile, investors, auditors and NGOs may use it to assess whether you understand the risks you face, and whether senior leaders truly own the work.

If you want the official overview in plain English, see the government guidance on publishing an annual modern slavery statement.

Who Must Publish a Statement in the UK?

The legal requirement applies to ‘commercial organisations’ that meet specific tests. Organisations are generally in scope if they supply goods or services, carry on a business, or part of a business, in the UK, and have a total annual turnover of £36 million or more. The requirement can apply to ‘bodies corporate’ and partnerships, regardless of where they are incorporated or formed. (GOV.UK)

This means the obligation is not limited to UK-incorporated companies. An overseas company can fall within scope if it has a demonstrable business presence in the UK and meets the other tests. Equally, having a UK subsidiary does not automatically mean the parent company is carrying on business in the UK. The guidance encourages a common-sense assessment of whether an organisation has a demonstrable business presence in the UK. (GOV.UK)

You might also see ‘expected’ statements outside legal scope. Even if you fall below the threshold, you may still get requests because:

• Large customers want assurance from suppliers.
• Procurement teams want consistent evidence across supply chains.
• Investors and lenders increasingly ask how you manage human rights risks.

As a result, legal scope and commercial expectations do not always match. If you are scaling, it often makes sense to build the habit early. That way, when you reach the threshold, you already have a process, a risk view and a set of actions to report.

Section 54 Turnover Threshold (£36 million)

The turnover threshold for Section 54 is currently set at £36 million. The relevant regulations state that commercial organisations with a total turnover of £36 million or more must publish a modern slavery statement, and they set out how turnover is calculated. (Legislation.gov.uk)

A few practical points often catch growing businesses out:

• The test looks at total turnover, not profit.
• Turnover is not limited to UK-generated revenue.
• You should plan ahead, because governance steps (board approval, sign-off, publication, upload) can take time even when the drafting itself feels straightforward.

If turnover calculations or group structures are complex, involve finance teams early. Do not wait until year end. A short conversation now can prevent last-minute uncertainty later, especially if you sit close to the threshold.

For the legal text on the threshold and calculation, you can review the Transparency in Supply Chains Regulations 2015.

What Must the Statement Include?

The law sets out the minimum requirements for a modern slavery statement. It must be a slavery and human trafficking statement covering the financial year. It must be approved at the right level, signed by the correct person, and, if you have a website, published with a prominent link on the homepage. (GOV.UK)

Beyond this, Section 54 provides a list of areas that organisations may choose to include. The updated government guidance treats these six areas as recommended coverage and encourages year-on-year improvement. (GOV.UK)

A strong statement usually includes:

• Clear scope: which entities, brands and geographies the statement covers.
• Honest risk discussion: where risk exists and why.
• Specific actions: what you did this year, not what you ‘commit to’ in abstract.
• Evidence of governance: who owns the work, and how leaders oversee it.
• Effectiveness: what you measure, what you learned and what you will improve next.

You do not need to write thousands of words but you do need to write enough to be credible. A short statement can work if it is specific. A long statement can fail if it is vague.

A helpful quality test is this: can a knowledgeable reader understand your key risks and your response without guessing? If they cannot, add clarity before you add length.

The Six Areas to Cover

The government guidance and Section 54(5) highlight six areas that a modern slavery statement may include. These areas provide a useful structure that makes your statement easier to read, and easier to improve year on year. (GOV.UK)

1) Organisational structure, business and supply chains

Explain what you do, where you operate, and how your supply chains are structured. Keep it practical. Describe the categories that matter for risk, such as labour-intensive services, raw materials, subcontracting, logistics and recruitment. You can include a simple supply chain description even if you cannot trace every tier yet.

2) Policies

List the policies you use to prevent exploitation, such as supplier codes of conduct, ethical sourcing policies, whistleblowing policies, recruitment standards and safeguarding routes. Do not simply list them. Explain how you apply them in practice. For example, how do you communicate your code to suppliers, and what happens if someone breaches it?

3) Assessing and managing risk

Describe your risk assessment approach. This could include country risk, sector risk, labour model risk and supplier behaviour signals. Also explain how you prioritise risk. It is better to say “we focused on these two high-risk categories” than to claim you treat everything equally.

4) Due diligence and remediation

Due diligence should explain how you check suppliers and labour providers, and how you respond when you identify issues. The guidance encourages transparency about cases and lessons learned, as well as practical signposting to support mechanisms. (GOV.UK)

If you want a recognised due diligence structure, the OECD Due Diligence Guidance for Responsible Business Conduct offers a practical framework many organisations align to.

5) Training

Explain who receives training, what it covers, and how you refresh it. Training often fails when it stays generic. Aim it at the people who influence risk most, such as procurement, HR, site managers, compliance, and anyone who manages labour providers.

6) Monitoring and evaluation

This is your effectiveness section. Explain what you track and what you learned. Even if your measures are simple at first, show movement and improvement.

Statement Approval and Director Sign-Off

A modern slavery statement needs senior-level approval. For companies, Section 54 requires the board of directors to approve the statement and a director to sign it. Explanatory notes also highlight that the requirement is designed to ensure senior support and accountability. (Legislation.gov.uk)

For LLPs, the statement should be approved by the members and signed by a designated member. For partnerships, it should be signed by a partner. The guidance also notes best practice to include the approval date and to ensure the signer sits on the board that approved it. (GOV.UK)

In practice, approval and sign-off go smoothly when you treat the statement like a governance document, not a last-minute communications exercise. A sensible internal process often looks like this:

• Draft created by the responsible owner (often compliance, legal, procurement or sustainability).
• Review by key functions: procurement, HR, operations, risk, and internal audit where relevant.
• Senior sponsor review (e.g. CFO, COO or a board committee).
• Board approval scheduled as an agenda item with sufficient time to review.
• Director signature and publication.

If you are a growing SME, you might not have a formal board structure. Even so, you should still document who approved the statement at the highest level in your governance.

Where to Publish the Statement on Your Website

If your organisation has a website, you must publish the statement on that website and include a prominent link to it from the homepage. (Legislation.gov.uk)

Many organisations fall short on this basic requirement. Statements are often hidden in archived PDF folders or they are buried several clicks deep within the site. To reduce risk and make life easier for procurement teams, aim for:

• A clear ‘Modern slavery statement’ link on your homepage and in the website footer.
• A stable URL that does not change each year.
• A page that lists statements by financial year, with the newest at the top.
• An accessible format (avoid scanned image PDFs).

If your website runs on a content management system (CMS), set a reminder to check the link after each site update. Broken links create avoidable compliance risk and frustrate customers who want to verify your approach quickly.

For practical accessibility basics, the GOV.UK guidance on accessible documents can help you avoid the common ‘PDF that nobody can read’ problem.

Modern Slavery Statement Registry

In addition to publishing a modern slavery statement on your own website, the government encourages organisations to upload statements to the voluntary Modern Slavery Statement Registry. The registry brings statements together in one place so the public can view them and compare progress. The guidance also notes reputational benefits for organisations that upload statements.

You can browse the registry, search for statements and add your own statement through the official services:

• Modern Slavery Statement Registry
• Add your statement to the registry

Uploading a statement to the registry does not replace your duty to publish on your own website. Instead, it improves visibility and makes it easier for customers and stakeholders to verify that you have published a statement.

A practical benefit for suppliers is speed. When a client asks you for evidence, you can point them to your website page and the registry listing. That reduces back-and-forth and can help shorten procurement cycles.

Group Statements and Subsidiary Rules

Group structures create confusion, especially when finance, legal and procurement each hold a different mental model of ‘the group’. The guidance is clear: if any organisation within a group meets the Section 54 tests, it must produce a statement. Where a parent company and one or more subsidiaries are required to produce statements, the parent may produce a single group statement, provided it fully covers the steps taken by each in-scope organisation during the relevant financial year. (GOV.UK)

If you choose a group statement, the guidance sets out some clear expectations:

• It must cover the steps taken across all in-scope organisations and their supply chains.
• It should clearly name the parent company and the subsidiaries it covers.
• It should be published on the UK websites of all organisations covered by the statement. (GOV.UK)

Group statements can work well when group entities share supply chains, policies and governance. However, they can become vague when different entities operate in different sectors. In those cases, separate statements often make more sense, because risk profiles differ.

Subsidiaries outside the UK create another challenge. Even if a foreign subsidiary is not legally required to publish a statement, the parent organisation’s statement may need to cover steps taken in relation to that subsidiary if its activities form part of the parent’s business or supply chain. The guidance encourages coverage of non-UK subsidiaries, especially in high-risk industries or locations, because stakeholders will still hold the group accountable for what happens across the footprint. (GOV.UK)

Best Modern Slavery Statement Examples

People often ask for examples of the ‘best’ modern slavery statements because they want to see what good looks like in practice. The catch is that the best statement for a clothing retailer will not look like the best statement for a construction contractor, a tech firm, a wholesaler or a professional services provider. Your statement should reflect your actual risk model, not a generic industry template.

That said, strong statements usually share a few traits:

• They explain the business model and labour model clearly.
• They name the highest-risk categories and explain why they matter.
• They describe what they did this year in concrete terms.
• They avoid empty claims like ‘zero tolerance’ without evidence.
• They include real measures and explain what they will improve next.

A practical way to find relevant examples is to search the government registry for organisations in your sector or with a similar supply chain footprint. Start with statements from companies that have similar labour models (e.g. high subcontracting, heavy agency use, seasonal peaks or international sourcing), then extract ideas for structure and clarity rather than copying specific wording.

You can also use an evaluation framework to pressure test your draft. The Ethical Trading Initiative Modern Slavery Statement Evaluation Framework provides a structured way to assess whether a statement goes beyond tick-box disclosure.

When you review examples, avoid lifting phrases or using language that does not reflect your organisation’s reality. Instead, copy the underlying thinking: clear scope, honest risk, specific action and measurable progress.

Due Diligence Steps to Include

Many statements become generic because organisations treat due diligence as a list of intentions rather than a set of repeatable steps. A credible statement describes your due diligence system like a workflow.

Below is a practical set of due diligence steps you can adapt. You do not need to implement all of it in year one. However, you do need to be honest about what you do now and what you plan to add.

1) Supplier onboarding

Explain how you screen new suppliers and labour providers. Include checks such as:

• Supplier code of conduct acceptance.
• Modern slavery and labour standards questionnaires.
• Recruitment practice checks where relevant.
• Contract clauses covering forced labour, worker protection and audit rights.

2) Risk-based supplier segmentation

Describe how you categorise suppliers based on risk. Common risk drivers include:

• Country risk.
• Sector risk.
• Use of temporary, seasonal or migrant labour.
• Subcontracting layers.
• Past issues or weak governance signals.

3) Ongoing monitoring

Explain how you monitor suppliers between audits. Examples include:

• Annual re-attestation of standards.
• Targeted re-screening for high-risk categories.
• Reviewing grievance data and whistleblowing reports.
• Checking for late payments that can drive exploitative subcontracting.

4) Audits and assessments

Audits can help, but they are not a magic shield. If you use them, explain:

• When you audit and why.
• How you choose auditors.
• Whether you include worker interviews.
• How you respond to findings.

5) Worker voice and grievance channels

Due diligence improves when you can hear from workers safely. Consider:

• Anonymous reporting routes.
• Supplier grievance mechanism expectations.
• How you handle and escalate concerns.

The Modern Slavery Helpline offers guidance and a reporting route, and the guidance also references mechanisms such as the National Referral Mechanism for victim identification and support.

6) Remediation and response

Your statement should explain what you do when you identify suspected or actual exploitation. Include:

• Immediate safeguarding steps.
• How you engage suppliers.
• How you protect the worker from retaliation.
• How you decide whether to exit or improve the relationship.

Walk Free’s Modern Slavery Response and Remedy Framework can help you think through response planning in a worker-centred way.

7) Internal governance and escalation

Describe who owns the process, who approves high-risk decisions and how you escalate serious concerns. For UK labour exploitation intelligence and reporting context, the Gangmasters and Labour Abuse Authority is a useful reference point.

Risk Assessment and High-Risk Suppliers

Risk assessment is at the heart of a credible statement. It is also where growing organisations can make the biggest jump from generic compliance to real action.

Start with a simple principle: you do not need perfect visibility to take meaningful steps. You need a reasonable, evidence-informed view of where risk is most likely, and then you need to prioritise.

A practical risk assessment approach often combines:

• Country risk indicators.
• Sector risk indicators (e.g. agriculture, construction, cleaning, manufacturing, logistics).
• Labour model risk (e.g. agency labour, recruitment fees, subcontracting).
• Supplier behaviour indicators (e.g. unusually low prices, high turnover, opaque ownership, frequent subcontract changes).

Then score or categorise suppliers. Keep the system simple. Over-complicated scoring often creates fake precision and slows action. Meanwhile, a simple system makes it easier to explain your thinking in the statement.

Once you identify high-risk suppliers, your statement should show what changes. For example:

• You require more detailed onboarding evidence.
• You carry out deeper assessments or audits.
• You agree improvement plans and time-bound corrective actions.
• You increase monitoring frequency.
• You introduce worker voice mechanisms.
• You raise internal approval levels for certain labour providers.

Also, define what ‘high risk’ means for your business. A tech company may face low risk in direct operations but higher risk in facilities management, construction projects, hardware supply chains and outsourced services. Meanwhile, a manufacturer may face risk across raw materials, labour agencies and subcontracting. Your risk story should match your footprint.

The updated government guidance encourages targeted action based on prioritised risk. That is the mindset you want to show in your statement. (GOV.UK)

KPIs and Effectiveness Reporting

Effectiveness reporting is where many statements fall down. Organisations list activities but do not explain whether those activities reduced risk or improved outcomes. You can fix this without building a huge measurement programme.

Think in layers:

1) Activity KPIs (what you did)

These are easiest to measure and help show that your system exists.

• Percentage of high-risk suppliers assessed this year.
• Number of staff trained in procurement and operations.
• Percentage of contracts updated with modern slavery clauses.

2) Output KPIs (what changed)

These show tangible changes in controls and supplier behaviour.

• Percentage of high-risk suppliers with improvement plans.
• Number of supplier corrective actions closed on time.
• Percentage of labour providers that meet your standards.

3) Outcome indicators (what improved for workers)

These are harder, but they are the goal. Even a few outcome indicators can raise credibility.

• Worker feedback indicators where you have worker voice tools.
• Reduction in recruitment fee risk in high-risk categories.
• Number of remediation cases supported and resolved, with lessons learned.

Avoid KPIs that encourage the wrong behaviour. For example, ‘zero incidents’ can discourage reporting and learning. Instead, track response speed, remediation quality and control improvements. You want measures that encourage transparency, not silence.

The six-area structure includes monitoring and evaluation for effectiveness. If you can show year-on-year progress in a few meaningful measures, your statement will stand out. (GOV.UK)

Common Statement Mistakes to Avoid

Most statement mistakes are fixable. They tend to come from rushing, copying or trying to sound perfect. In this area, credibility matters more than polish.

Here are some common pitfalls and how to avoid them:

1) Vague commitments with no evidence

Avoid: “We take modern slavery seriously.”
Use: “This year we assessed X suppliers in our highest-risk category and introduced Y controls.”

2) Over-claiming

Avoid: “We ensure no modern slavery occurs in our supply chain.”
Use: “We recognise risk can exist and we focus on identifying and mitigating it through these steps.”

3) No clear scope

If you operate through multiple brands, sites or subsidiaries, name them. If you cover only part of the group, say so.

4) No risk prioritisation

If you list every risk under the sun, you signal you have not prioritised. Name the top risks and show focused action.

5) No mention of remediation

Stakeholders expect a plan for what happens when you find risk. A statement that never mentions remediation can look unrealistic.

6) Not updating year on year

A copied statement signals low engagement. Even small improvements in detail, data and outcomes help.

7) Publishing and linking errors

A missing homepage link or a broken URL creates avoidable compliance risk.

8) Training that is too generic

If training does not reach the people who make supplier and labour decisions, it will not change risk.

9) Forgetting your own operations

Many statements focus on supply chain only. Yet risk can exist in your own recruitment practices, contractors, and outsourced services.

10) Treating the statement as the work

The statement should reflect real action. It cannot replace it.

If you need a sanity check for language and claims, you can compare your approach against principles in the UN Guiding Principles on Business and Human Rights, which encourage clear communication about how organisations address human rights impacts.

Penalties and Enforcement for Non-Compliance

Section 54 uses an enforcement mechanism based on civil proceedings. If an in-scope organisation fails to comply, the Secretary of State may bring proceedings in the High Court for an injunction, or in Scotland for specific performance of a statutory duty. If the organisation then fails to comply with the injunction, it will be in contempt of court, which can lead to an unlimited fine. (GOV.UK)

In practice, many organisations experience the greatest pressure through reputational and commercial routes. Procurement teams can reject suppliers, customers can escalate concerns, and NGOs can spotlight weak statements. The registry also increases visibility, which raises scrutiny.

The government has also discussed future changes to reporting requirements, although the GOV.UK guidance notes these changes have not yet come into effect and organisations should continue to report under current requirements. (GOV.UK)

So, the smart approach is to treat compliance as the baseline, then build credibility through risk-based action and measurable progress. That reduces legal exposure, improves procurement outcomes and supports long-term trust.

Conclusion

A modern slavery statement is more than an annual disclosure. It is a public demonstration of how your organisation identifies and addresses forced labour and human trafficking risks in the places you operate and the supply chains you rely on. If you are nearing the £36m threshold, act early. If you are already in scope, treat the statement as a governance document that reflects real action. If you are a supplier being asked for evidence, use the statement to show customers you understand your risks and manage them responsibly.

Start simple, but stay specific. Use the six areas as your structure, focus on the highest-risk parts of your model, and report what you actually did this year. Then measure what changed and what you will improve next year. Finally, publish the statement correctly with the right approval and sign-off, and consider adding it to the government registry so stakeholders can find and assess it easily.

When you do that, your statement becomes more than a compliance exercise. It becomes a practical tool that strengthens procurement, reduces risk and supports better outcomes for workers.