Modern slavery (forced labour) is well and alive today, and often hidden in plain sight.
Organisations must take steps to avoid perpetrating it in their supply chains, and if your organisation turns over £36 million or more in the UK, you’re legally required under the Modern Slavery Act 2015 to publish an annual modern slavery statement.
A surprising number of organisations treat this as a box-ticking exercise and produce statements that are vague, undated, and effectively useless.
This guide is for technical leaders and compliance owners who want to understand what a substantive, credible statement actually looks like—including the formal requirements, the six content areas you need to cover, and what separates the organisations doing this properly from the ones who aren’t.
What you’re actually being asked to do
A commercial organisation needs to publish an annual statement if it’s a body corporate or partnership (wherever incorporated or formed), carries on a business or part of a business in the UK, supplies goods or services, and has annual turnover of £36m or more.
All four conditions need to be met—and if you’re unsure whether your organisation qualifies, the gov.uk guidance explicitly recommends seeking legal advice, so treat this article as orientation, not a legal opinion.
Incorporation outside the UK doesn’t exempt you, but simply having UK customers isn’t necessarily enough either. The guidance says that if your organisation has a demonstrable business presence in the UK and meets the other criteria, you should publish a statement, and offers a non-exhaustive list of indicators:
- Whether you’re registered at Companies House
- Have UK offices
- Provide service or support functions here
- Receive UK income, or
- Have other visible UK presence such as a website
If you’re an overseas organisation trying to determine whether you’re included, that’s a question worth putting to a lawyer.
Total turnover here means the turnover of the organisation and any of its subsidiary undertakings, including those operating wholly outside the UK, which is why you’ll see group statements covering dozens of entities. For instance, Lloyds Banking Group’s 2026 filing covers 64. Subsidiary organisations can publish separate statements, or the group can publish one covering all entities that meet the criteria.
To be clear, you’re not being asked to certify or guarantee that your supply chains are slavery-free. What you must do is describe the steps taken during the financial year to deal with modern slavery risks in your supply chains and your own business—and if you’ve taken no steps, you still need to publish a statement saying so.
The standard sign-off is board approval plus a director’s signature, but your organisational structure affects who specifically needs to sign. For an LLP it’s a designated member; for a limited partnership, a general partner; for any other partnership, a partner. Whatever the structure, the signatory’s name, job title, and date must be explicit in the statement. A physical signature isn’t required as of writing.
The six areas you need to cover in your modern slavery statement
Government guidance identifies six content areas that a modern slavery statement should address with substance:
- Organisation structure and supply chains
- Policies in relation to slavery and human trafficking
- Risk assessment and management
- Due diligence processes
- Key performance indicators to measure effectiveness of steps being taken
- Training on modern slavery and trafficking
1. Business structure and supply chains
This section needs to give readers a genuine picture of how your organisation is structured and where goods, services, and labour come from.
That means describing your main products and services, your organisational structure and any group relationships, a mapped overview of your supply chain—including which suppliers provide goods, services, labour, or contracting—and the nature of your workforce, including your use of temporary workers, migrant workers, labour agencies, and seasonal workers.
Geography comes into play here. If your supply chain runs through Malaysia, China, Bangladesh, or any other region with elevated risk profiles in sources like the US State Department’s Annual TIP Report or the Global Slavery Index, you may need to flag that and outline the risk.
2. Policies in relation to modern slavery and human trafficking
Your statement needs to detail the policies you have in place that relate to modern slavery—policies that actually address it rather than just pay lip service.
Relevant policies include your supplier code of conduct, HR policies on recruitment and pay, procurement policies, and any sector-specific policies on things like migrant workers, home workers, or child labour.
Policies only mean something if they’re enforced, so your statement should also describe the enforcement mechanisms and consequences for non-compliance, and explain how employees and supply chain workers can actually access those policies—including whether they’re available in languages other than English where relevant.
Rightacres Property’s 2026 statement, for example, covers all ten specific policy provisions the government registry asks about, including freedom of workers to terminate employment, prohibitions on recruitment fees, and access to remedy for victims.
3. Risk assessment, prevention, and mitigation
Most statements fall flat here. You need to identify specific risks (not generic ones), and disaggregate them by country, sector, type of relationship, and the category of goods or services involved. A vague statement like “we recognise there are risks in global supply chains” says nothing useful and satisfies nobody.
The risks you flag should be tractable, meaning your organisation is in a position to do something about them, and proportionate to your size and the nature of your supply chain.
A small logistics company sourcing domestically faces different risk vectors than a healthcare products group sourcing from factories in Malaysia and China, and your risk assessment should reflect that rather than copying boilerplate from a sector peer.
ONE-Dyas UK, the North Sea oil and gas operator, gives a reasonable example in their 2026 statement: they identify three specific risk areas—service and maintenance suppliers potentially using non-compliant labour, contractors in their own operations, and goods/equipment suppliers in lower-cost manufacturing regions—and they explain exactly what due diligence they carry out against each one.
4. Due diligence to mitigate modern slavery
Due diligence is the operational layer: what you’re actually doing to discover and address modern slavery, not just what your policies say.
This includes any changes to procurement or supplier management practices, specific instances where risks were discovered and what you did, grievance mechanisms that give workers a genuine route to raise concerns, and whether you engage with workers directly beyond the contractual level.
Contractual compliance and direct engagement are handled separately here, because audits and supplier questionnaires are a starting point, not an endpoint.
For example, Lloyds Banking Group commissioned worker wellbeing visits across construction sites through the NGO Unseen UK, using ILO indicators and the ETI Base Code as the evaluation framework, and separately used their Financial Intelligence Unit to identify modern slavery-related financial crime in their lending book.
That’s due diligence operating at multiple levels simultaneously.
Polyco Healthline’s 2026 statement is similarly instructive for organisations with complex global supply chains. They found and disclosed specific instances of agency fee exploitation and excessive working hours affecting migrant workers in Malaysia and China, named the remediation steps they took, and used a proprietary supply chain management system (BRAND integrity) to track compliance. Naming countries, affected worker categories, and concrete responses is what lends credibility.
5. Effectiveness measures and KPIs
This was consistently the weakest area we spotted in the Government registry data. When you look at the statements from certain media groups, district councils, and even mining and resource companies with substantial turnover (over £100m), many of whom have been filing for more than five years, their modern slavery statements are usually missing KPIs.
The government’s own guidance is explicit about what’s needed: KPIs that measure outcomes, not just outputs. Training 200 employees on modern slavery is an output; the meaningful question is whether it actually improved their ability to identify and report it.
Your KPIs should tie directly to the specific actions you’ve committed to, and your statement should demonstrate how findings from monitoring and review have fed back into business practice. For example, KPMG’s 2026 statement describes KPIs and year-on-year tracking explicitly, as do Lloyds’ and a few others.
A recommended route is using an external validation measure rather than relying solely on assertions of intent. Examples include the CCLA Modern Slavery UK Benchmark, the Ethical Trading Initiative‘s evaluation framework (ETI), and KnowTheChain’s benchmark (KTC).
6. Training and capacity building
This is another area many organisations fall short on. Your statement needs to specify who received training, who provided it, what the objectives were, and what format it took.
The “who” matters more than the “how many”: procurement staff, senior management, HR, and legal teams all represent meaningful training audiences because they’re the people making decisions that create or mitigate risk. Training your whole organisation on awareness is worthwhile, but it’s not a substitute for deep functional training in the roles that matter most.
Polyco Healthline’s 2026 statement indicated they trained across several key groups: the whole organisation, frontline staff, HR, executives, procurement, and suppliers. This is an appropriate model for an organisation sourcing from high-risk regions internationally.
By comparison, Collins Earthworks (construction, £100m–£500m turnover) indicated in their 2026 statement that they trained the whole organisation but didn’t specify any functional groups. KPMG—despite their scale and sophistication in other areas—trained only procurement staff, per their 2026 statement.
What real-world modern slavery statement examples show
Pulling the data from the numerous modern slavery statements we reviewed for this article, a few patterns emerge that might help anyone producing or improving their own.
The organisations that cover all six areas credibly tend to have two things in common: they’ve been producing statements for more than five years (experience matters), and they operate in sectors with visible supply chain complexity where the risks are hard to avoid, like manufacturing, construction, and financial services.
The weaker statements tend to reveal a cluster of the same issues. KPIs are the most consistently missing element across turnover bands, sectors, and years of filing. Training shows a similar pattern, with a lot of ‘No’ statements against the functional groups that matter most, like procurement leads, HR teams, and executives.
Remedy is another recurring absence, with a distinct lack of policies providing workers with a genuine route to compensation or justice. This is important because without it, your grievance mechanism is a channel to nowhere.
Lastly, running through all the statements was a tendency toward forward-looking language like “we will” or “we intend to”, both assertions of intent dressed up as evidence of action.
That may be understandable for organisations early in the process, but it’s worth tightening up your monitoring and measurement now, while the regulatory environment is still relatively permissive.
Getting your house in order before a whistleblowing scandal—or before enforcement teeth arrive—is considerably less painful than doing it later.
Your checklist before publishing a modern slavery statement
Mandatory (formal requirements):
- [ ] The statement explicitly covers the previous financial year
- [ ] It’s prominently accessible on your website—homepage or obvious navigation, not a buried PDF
- [ ] It’s been approved by your board (or equivalent), with the date of approval included
- [ ] It’s signed by a director or equivalent senior figure
Non-mandatory but substantive:
- [ ] Published within 6 months of financial year end
- [ ] Provides a genuine picture of your business structure and supply chains
- [ ] Includes policies with a direct and enforced relationship to modern slavery
- [ ] Identifies specific, named risks in your supply chains—not generic assertions
- [ ] Explains the steps taken to prioritise and address higher risks, including supplier engagement
- [ ] Delivers training to key functional staff: procurement, HR, legal, senior management
- [ ] Includes forward-looking actions with measurable commitments for the coming year
What happens if you get it wrong?
Under current law, the formal consequences for not publishing a modern slavery statement are limited. The Secretary of State has the power to seek a court injunction, though that power has never been used. A 2019 review estimated that 40% of eligible companies weren’t complying with Section 54, and found no attempts at enforcement.
Whether that remains the case is less certain. The Home Office has committed to considering how to strengthen Section 54, including the reporting requirements, the turnover threshold, and penalties for non-compliance.
The UK is also watching developments internationally: Canada, the EU, and Australia have all moved toward more prescriptive, enforceable supply chain transparency regimes in recent years, and there’s pressure for the UK to follow.
In practice, the main risks are reputational and commercial, and they’re tightly connected. Poor or absent statements attract scrutiny from NGOs, investors, and procurement teams, and the Government’s public registry makes it straightforward to identify organisations filing weak statements or nothing at all.
For listed companies, that reputational signal feeds into stock price, and a depressed market cap makes fundraising more expensive.
The same visibility that puts off investors tends to put off senior candidates too. Governance records and online searches are increasingly part of how high-value hires assess employers, and a poor one narrows your talent pool in ways that compound over time.
Three in four candidates consider an employer’s brand before applying, 6 in 10 employees choose a workplace based on shared values, and 40% of workers would quit their job if they didn’t agree with their employer’s stance on key issues (source). All of that makes recruiting and retention costlier.
The financial risks are also more direct than they might appear. An organisation without functioning grievance and whistleblowing mechanisms isn’t just exposed to modern slavery risk—it’s structurally blind to graft, embezzlement, and procurement irregularities that create accounting holes and distort capital allocation. Those holes don’t stay hidden indefinitely.
The governance failure that enables exploitation in a supply chain is often the same failure that enables financial misconduct closer to home. They’re the same risk approached from different angles.
None of the above is a prediction, and we’re not lawyers, so if you need advice on your specific obligations, seek it. What it does suggest is that getting your statement right today, while the bar is still low, is considerably easier than retrofitting it when it rises.
Prevention is better than cure.
Column helps design and produce compliance documentation, technical content, and policy communications for organisations across sectors. If you need help writing, editing, or structuring your modern slavery statement, get in touch.
Mo is the founder of Column, a technical research and content agency. Connect with him on LinkedIn.
