What should be included in a modern slavery statement?
We describe below the key parts of a modern slavery statement and give guidance to help make sure what you publish both complies with the MSA and is meaningful.
Part 1: introduce your statement
The statement should make clear that it is published to meet your company’s obligations under section 54 of the Modern Slavery Act. If it is also intended to support compliance with other laws, such as the
Australian Modern Slavery Act and/ or the
California Transparency in Supply Chains Act, this fact should be stated.
Your statement should include a commitment to ensuring no slavery is present in your own operations or supply chain. These commitments should be endorsed by the board or senior management. Report supporting commitments if you have the processes in place to deliver them and can demonstrate this.
State the date of publication and the financial year which the statement covers.
Part 2: set out details about your company’s structure, business and supply chain
Introduce your company and any subsidiaries covered by the modern slavery statement.
Summarise your supply chain. Your supply chain will include your direct suppliers (‘tier 1’), their suppliers (‘tier 2’), their suppliers’ suppliers (‘tier 3’), and so on. Complexity and opaqueness will increase as you assess operations beyond your direct suppliers. However as modern slavery risk is often higher in the lower tiers of your supply chain, you should try and cover as many levels as practicable. You should be very familiar with the risk profile of the supply chain supporting your business activities.
A good statement will identify a fair estimate of the number of suppliers, provide a summary of the goods and services procured and state where (geographically) your supply chain extends. Remember that your supply chain includes goods and services core to your business as well as ‘auxiliary’ goods and services (office supplies, security and cleaning services, for example).
Undertaking proper due diligence (see below) will allow you to better understand the full extent of your supply chain. If you are planning due diligence in the year ahead acknowledge this in your statement and consider providing a sensible number of goals (for example; “in 2025/26 we will conduct due diligence and aim to identify all our tier 2 suppliers”).
Part 3: describe your policies in relation to slavery and human trafficking
List policies which contain processes to address modern slavery, summarise how they achieve this and detail which groups (employees, suppliers etc) are subject to them (if it’s not apparent from the policy title).
Consider reviewing the following policies to establish whether they adequately address modern slavery risk and support your organisation’s approach:
- employee code of conduct
- recruitment and employment policies
- supplier code of conduct
- Industry
- procurement due diligence process (see below).
Work with your human resources, procurement and legal departments to make sure your policy set is consistent.
Key policies should always be sponsored and approved by senior management and/or directors and this should be acknowledged in the statement.
Undertaking proper due diligence (see below) will allow you to better understand the full extent of your supply chain. If you are planning due diligence in the year ahead acknowledge this in your statement and consider providing a sensible number of goals (for example; “in 2025/26 we will conduct due diligence and aim to identify all our tier 2 suppliers”).
Remember, commitments are meaningless without processes to implement them. It is, for example, meaningless to state that “we do not tolerate modern slavery in our supply chains” unless you have a reasonable due diligence process in place to enforce this claim. A process, in turn, is ineffective unless implemented.
Part 4: describe your due diligence processes in relation to slavery and human trafficking risk in your business and supply chains
You cannot address modern slavery risk properly without conducting due diligence. Below we provide an overview of the four stage process, for more comprehensive guidance see our
guide to modern slavery due diligence of supply chains:
Stage 1: Assess your supply chain
You need to start by assessing the likelihood that the goods and services your company buys are made by slave labour. Map out your supply chain to identify relevant suppliers. This information can often be found in your company’s accounts system. Next identify, and gather data on, relevant risk indicators. There is no prescriptive list of risk indicators. Rather you should select those that are most relevant to you supply chain. Once you have identified the relevant risk indicators and gathered the data, you need to conduct the assessment itself. We typically build a risk assessment matrix with each risk indicator appropriately weighted and prioritised.
Stage 2: Act to address risk
Once you have identified your supply chain risks, you will need to determine which ones to address first. We advise allocating issues between two groups, actual impacts and potential impacts.
Actual impacts are incidents where your business activity is resulting in people being forced into modern slavery. Clearly, addressing any identified actual impacts should be prioritised.
Where an actual impact has occurred or is ongoing, you should use what leverage you have over the supplier to try to end the abuse. If this is not possible then you need to have plans in place to end your relationship with the supplier and follow any necessary reporting requirements to end the slavery and meet any legal reporting requirements.
Potential impacts can be defined as policies or practices that create an opportunity for people to be forced into slavery.
In cases of potential impact, you need to revise the policies or practices that have given rise to the risk.
Stage 3: Monitor suppliers
Supply chains are in a constant state of flux, with most companies taking on new suppliers and expanding the range of goods they buy from existing ones on a regular basis. You should have a maintainable process in place to assess new suppliers as they are onboarded and make sure all new suppliers are aware of your modern slavery compliance requirements.
As the risk landscape of your supply chain evolves over time, it’s important to continue to monitor your active suppliers and address new risks as they emerge.
Stage 3: Monitor suppliers
Engage with important stakeholders throughout the process. This will help you assess risk better and determine mitigations sooner. Publishing a comprehensive modern slavery statement will help communicate your progress and strengthen your ESG profile.
Part 5: explain the parts of the business and supply chain where there is a higher risk of modern slavery taking place, and the steps taken to assess and manage that risk
Your due diligence should help you identify the parts of your business and supply chain that carry the highest risk of modern slavery. Risk may be higher because of geography or industry sector, or because of the mode of employment; for example, there could be higher risk in part of the business where there is a reliance on foreign migrant workers as these people can be particularly exposed to modern slavery risk. Explain all higher risk areas in this section.
Be mindful of privacy and defamation laws when identifying specific modern slavery risk areas or incidents.
Set out clearly how your company has addressed your risks and describe the controls in place to provide continual monitoring and management of them.
If you have not implemented due diligence and are unsure of the level of modern slavery risk in your organisation, it is better to state this together with a commitment to undertake due diligence in the year ahead.
One last but important reminder. Be careful not to make assertions relating to low modern slavery risk that are not based on the results of reasonable and independent due diligence.
The statement is a public document that investors, lenders, clients and other counterparties may take into account when doing business with your company. Don’t make claims relating to the risk profile of your operations or supply chain unless these can be substantiated by due diligence.
Part 6: Assess your effectiveness in ensuring that modern slavery is not taking place in your business or supply chain, measured against appropriate performance indicators
Providing meaningful indicators that support any assurance you provide can be challenging. You should identify ‘key performance indicators’ (KPIs) that are relevant to modern slavery risk prevention and can track this over time.
Examples of modern slavery key performance indicators include:
- percentage of tier 1 (and tier 2, tier 3 etc) suppliers assessed for modern slavery risk
- percentage of direct (tier 1) suppliers subject to enhanced risk assessment
- percentage of total supplier spend identified as higher risk relative to total supplier spend for year
- number of incidents related to modern slavery identified
- number of speak-up incidents related to modern slavery reported
- number of external audits related to modern slavery carried out in year
Part 7: describe the training resources available to staff, suppliers and other relevant third parties, to address modern slavery
Staff training in identifying and preventing slavery in supply chains is essential. It not only reduces the risk to your organization of modern slavery incidents being missed, but also makes clear to every employee that you take this issue seriously. 97% of the 9,259 companies which submitted statements to the UK Government’s Modern Slavery Registry in 2023 assert that they train their staff on modern slavery.
Confirm if your staff are being trained on modern slavery or if you plan to train them in the coming year. If training is restricted to specific departments, state this; for example, in procurement and audit functions. Provide a brief summary of the format of the training (in-person or online) and say when and how often it is delivered (at staff induction, following promotion etc).
Staff should be re-trained on a regular basis and this fact, and the frequency of retraining, should be noted in your modern slavery statement.
You should also keep a record of the individuals trained. Consider reporting on the number and/or percentage of staff trained as a KPI. If staff are tested, consider tracking and reporting on any improvement in the results.
If you expand your training programme to suppliers on modern slavery, include this fact in the statement.
It is important that you have confidence that all training has been created by experts in the field. You are welcome to use our
free modern slavery training course to train your team.
Who should approve and sign our modern slavery statement?
Section 54 of the UK Modern Slavery Act requires that, for body corporates, modern slavery statements be approved by the reporting company’s board of directors and signed by a director of the reporting company.
Statements published by partnerships should be approved by the members and signed by a designated member.
Where should our modern slavery statement be published?
You must publish your modern slavery statement on your company’s website. A link to the statement must be published in a prominent place on the homepage.
We also recommend that you file your statement on the
Government’s Modern Slavery Statement Registry. At present, filing the statement is voluntary, but doing so improves transparency. The Government has committed to a set of reforms to the MSA, including making it obligatory for companies to file their statements on the registry.
A summary of how to comply with the Modern Slavery Act.
In summary, section 54 of the UK Modern Slavery Act mandates that:
- All companies doing business in the UK that have global revenue of £36m or more need to publish a modern slavery statement every year.
- The statement should lay out the steps taken by your company to eradicate modern slavery and human trafficking from its operations and supply chains.
- The modern slavery statement should be published on your website with a link on the home page. Legally, it must be authorised by the company’s board and signed by a director or equivalent.
- The modern slavery statement is a public confirmation of your company’s commitment to ensuring that there is no modern slavery in its operations and supply chain.
- Don’t make claims in your statement that can’t be substantiated. Don’t assert that the company’s supply chain is low risk unless you have undertaken sufficient due diligence to substantiate this claim.
- You should describe your planned objectives and tasks to address modern slavery risks in your statement as well as provide an update on any progress you have made in the last year.
