Employment compliance

Modern Slavery Act compliance for businesses

How to comply with Section 54 Modern Slavery Act 2015. Covers the £36 million turnover threshold, statement content requirements, publication deadlines, government registry, due diligence expectations, and enforcement.

UK-wide
Guide summary

If your business has a turnover of £36 million or more, you must publish an annual modern slavery statement. This statement must explain what steps you’ve taken to prevent slavery in your business and supply chains. Publish it on your website and submit it to the government registry.

  • Check if your turnover is £36 million or more
  • Publish an annual modern slavery statement
  • Include steps taken to prevent slavery
  • Submit to the government registry
  • Publish on your website within 6 months of financial year end
  • Cover organisation structure and supply chains
  • Describe policies and risk assessments
  • Explain due diligence and training
  • Show progress year-on-year
  • Consider voluntary publication if near threshold
On this page
UK-wide

Related guides in International Trade

Use simplified customs procedures

Speed up border clearance with Simplified Declaration Procedure (SDP), Entry in Declarant's Records (EIDR), Authorised Economic Operator (AEO) …

The Modern Slavery Act 2015 requires large commercial organisations to publish an annual statement detailing the steps they have taken to prevent modern slavery in their operations and supply chains.

What is modern slavery:

  • Slavery: Owning another person as property
  • Servitude: Severe exploitation without being able to leave
  • Forced or compulsory labour: Work under threat of penalty, without consent
  • Human trafficking: Arranging travel of another person for exploitation

Modern slavery exists in the UK and in global supply chains. Businesses have a legal and ethical responsibility to identify and address modern slavery risks.

Key compliance questions:

  • Does your organisation meet the £36 million turnover threshold?
  • What should your annual statement contain?
  • When and where must you publish it?
  • How should you conduct due diligence on your supply chain?

Who must publish a modern slavery statement

Section 54 applies to certain large commercial organisations based on turnover and UK presence. Understanding whether you are in scope is the first step.

Calculating turnover

What counts towards the £36 million threshold:

  • Your organisation's own annual turnover
  • PLUS turnover of all subsidiary undertakings (including those operating wholly outside the UK)
  • Deduct trade discounts, VAT, and other taxes levied after the calculation

Group structures: Each legal entity is assessed separately. A parent company with £20 million turnover and a subsidiary with £20 million turnover would each be below the threshold individually - but if consolidated turnover exceeds £36 million, the parent company must publish.

If you're close to the threshold: Even if you're just under £36 million, consider publishing voluntarily. Demonstrating commitment to tackling modern slavery can strengthen stakeholder relationships and prepare you for future compliance if your turnover grows.

What your statement should contain

Section 54(5) sets out six recommended areas for disclosure. While you can legally publish a statement saying you have taken no steps, this would invite significant criticism and reputational damage.

Moving from Level 1 to Level 2 disclosures

The March 2025 updated statutory guidance introduces a two-tiered approach encouraging organisations to progress over time:

Level 1 (Foundational):

  • Describe organisation structure and supply chains
  • Outline relevant policies
  • Explain general risk assessment approach
  • Describe basic due diligence processes
  • Note what training is available
  • Set out how effectiveness will be monitored

Level 2 (Enhanced):

  • Provide detailed supply chain mapping including beyond Tier 1 suppliers
  • Identify specific modern slavery risks and how they are prioritised
  • Demonstrate year-on-year progress with measurable KPIs
  • Show engagement with workers, trade unions, and civil society
  • Align with international frameworks (UN Guiding Principles, OECD Due Diligence Guidance)
  • Disclose when modern slavery has been identified and what remediation occurred

Best practice: Even if starting at Level 1, set a clear roadmap to reach Level 2 within 2-3 years. Stakeholders, investors, and civil society increasingly expect substantive action, not just policies on paper.

Publication deadline and approval

Getting the timing and approval process right is essential for compliance.

Where to publish

If your organisation has a website:

  • Publish the statement in a prominent place on your homepage
  • A link must appear on the homepage itself - not buried in footer links or multiple clicks away
  • Best practice: Use clear link text such as "Modern Slavery Statement" rather than generic "Legal" or "Policies"

If your organisation has NO website:

  • Provide a written copy of the statement to anyone who requests it
  • Respond within 30 days of request
  • Provide free of charge

Format: The statement should be in a format that allows it to be downloaded and saved (PDF is common). It should be clearly dated and show the financial year it covers.

Government Modern Slavery Statement Registry

The UK government operates a central registry to improve transparency and enable comparison across organisations.

Why submit to the registry

Currently voluntary - but:

  • Government has committed to making submission mandatory "as soon as parliamentary time allows"
  • Early submission demonstrates leadership and commitment
  • Increases visibility to investors, customers, and civil society
  • Registry sends helpful email reminders before your deadline

What you'll need to submit:

  • Organisation name and company number
  • Financial year-end date
  • Turnover band (£36m-£60m, £60m-£100m, etc.)
  • Industry sectors and countries of operation
  • Link to your published statement OR upload the statement directly
  • Answers to structured questions about your statement content

Benefits of registry data: The registry allows benchmarking against sector peers and tracking of improvement over time. This data is publicly accessible and used by researchers, investors, and NGOs.

Supply chain due diligence

Effective modern slavery compliance requires proactive risk identification and mitigation across your supply chain - not just your direct operations.

Retail & Consumer Goods Requirement

High-risk supply chains in retail

Retail businesses face particular modern slavery risks in their supply chains:

  • Garment manufacturing: High risk in countries like Bangladesh, India, Pakistan, China, Turkey. Look for excessive overtime, debt bondage, child labour.
  • Agriculture and food: Seasonal workers, migrant labour, gang-master exploitation. UK agriculture also carries risks.
  • Electronics: Complex multi-tier supply chains with raw material extraction (cobalt, rare earths) and component assembly risks.
  • Logistics and warehousing: Agency workers, zero-hours contracts, excessive working hours in UK distribution centres.

Due diligence priorities:

  • Map supply chains beyond Tier 1 (direct suppliers) to Tier 2 and 3
  • Conduct risk assessments by country, sector, and product category
  • Require suppliers to provide their own modern slavery statements
  • Include modern slavery clauses in supplier contracts with audit rights
  • Use third-party audit programmes (SEDEX, SA8000, BSCI) for high-risk suppliers
  • Establish confidential worker grievance mechanisms
Modern slavery statement guidance (opens in a new tab)
Construction & Property Requirement

Modern slavery risks in construction

The construction sector has significant modern slavery risks, particularly in subcontracting and agency labour:

  • Subcontracting chains: Complex layers of subcontractors make visibility difficult. Main contractors may be unaware of conditions at Tier 3 or 4 subcontractors.
  • Agency labour: Workers supplied by labour agencies may face fee-charging, document retention, or exploitation.
  • Migrant workers: Non-UK workers may be vulnerable to debt bondage (owing money to recruiters), document confiscation, or language barriers preventing them raising concerns.
  • Accommodation tied to work: Workers housed by employers may face substandard conditions or deductions that create dependency.

Due diligence priorities:

  • Limit subcontracting depth and require visibility of the supply chain
  • Vet labour providers - check for GLAA (Gangmasters and Labour Abuse Authority) licensing where required
  • Conduct unannounced site visits and worker interviews
  • Ensure workers are paid directly (not via intermediaries who may take deductions)
  • Provide accessible worker grievance mechanisms on site
  • Include modern slavery requirements in tender criteria and contracts
Gangmasters and Labour Abuse Authority (opens in a new tab)
Food, Drink & Hospitality Requirement

Modern slavery risks in hospitality

Hotels, restaurants, and catering businesses face modern slavery risks in their operations and supply chains:

  • Direct employment: Housekeeping, kitchen, and cleaning roles may employ vulnerable workers at risk of exploitation, particularly through agency arrangements.
  • Food supply chains: Agricultural workers harvesting produce, fishing crews, and food processing workers face known risks.
  • Linen and uniform supply: Textiles may be manufactured in high-risk countries.
  • Franchise and supply relationships: Limited visibility into franchisee employment practices or supplier conditions.

Due diligence priorities:

  • Know your workforce - verify identity documents are genuine and held by workers (not employers)
  • Pay at least minimum wage with proper records - wage theft is an indicator of exploitation
  • Train managers to spot signs of modern slavery (withdrawn behaviour, poor living conditions, someone else controlling documents or wages)
  • Conduct supplier audits on food, textiles, and agency labour providers
  • Display information for workers on how to report concerns or seek help
Modern slavery training resources (opens in a new tab)

Enforcement and penalties

Understanding the enforcement landscape helps prioritise compliance efforts and communicate risks to leadership.

Why compliance matters despite weak enforcement

Although direct financial penalties don't currently exist for non-publication, the consequences of poor compliance are significant:

Reputational risk:

  • Civil society organisations actively monitor and "name and shame" non-compliant companies
  • Media investigations into supply chain abuses cause severe brand damage
  • Consumer awareness of modern slavery is growing - boycotts and social media campaigns can affect sales

Business risk:

  • Public sector contracts increasingly require modern slavery compliance
  • Major retailers and brands require suppliers to demonstrate modern slavery due diligence
  • Investors and ESG rating agencies assess modern slavery practices
  • Insurance and financing may be affected by poor compliance

Legal risk:

  • Civil penalties are proposed and may be introduced
  • Directors could face personal accountability under proposed reforms
  • Criminal liability for actual modern slavery offences (separate from reporting failures)
  • Potential HMRC or Home Office enforcement for labour exploitation

Ethical imperative: Beyond legal and business considerations, tackling modern slavery is simply the right thing to do. An estimated 50 million people globally are in modern slavery - businesses have power and responsibility to address this.

  1. 1

    Determine if you meet the £36 million threshold

    Calculate your annual turnover including all subsidiaries. If you're above £36 million, have a UK presence, and supply goods or services, you must publish a statement.

  2. 2

    Appoint board-level responsibility

    Designate a board member or equivalent senior leader to oversee modern slavery compliance. Ensure the board formally approves the annual statement.

  3. 3

    Map your supply chains

    Identify your key suppliers, where they operate, and what sectors they're in. Extend mapping beyond Tier 1 to higher-risk areas.

  4. 4

    Conduct risk assessment

    Assess modern slavery risk by country, sector, and business relationship. Use resources like the Global Slavery Index to identify high-risk geographies.

  5. 5

    Develop policies and procedures

    Create or update your modern slavery policy, supplier code of conduct, and procurement procedures. Include contract clauses and audit rights.

  6. 6

    Train relevant staff

    Provide modern slavery awareness training to procurement, HR, and operations staff. Train managers to spot warning signs and report concerns.

  7. 7

    Draft and approve your statement

    Address all six recommended areas. Have the board formally approve the statement and ensure it's signed by a director (or equivalent).

  8. 8

    Publish within 6 months of year-end

    Upload to your website homepage with prominent link. If no website, be ready to provide written copies on request within 30 days.

  9. 9

    Submit to the government registry

    While currently voluntary, submit to the Modern Slavery Statement Registry to demonstrate leadership and prepare for mandatory submission.

  10. 10

    Monitor and improve year-on-year

    Track progress against KPIs. Update your statement annually showing improvement. Aim to progress from Level 1 to Level 2 disclosures over time.