Modern Slavery Act statements: what UK SMEs must include
If your UK business has an annual turnover of £36m or more, you are legally required to publish a Modern Slavery Act statement every year. Here is exactly what it must contain — and how to make it credible to buyers and auditors.
The Modern Slavery Act 2015 requires commercial organisations supplying goods or services in the UK with an annual turnover of £36m or more to produce a transparency statement each financial year. The statement must be approved by the board of directors (or equivalent) and signed by a director.
Even if your turnover falls below the threshold, many large buyers — particularly those subject to the Act themselves — now require their entire supply chain to produce a statement as a condition of doing business. Treating this as a tick-box exercise is increasingly risky: buyers, investors, and the Home Office are scrutinising statements for substance, not just existence.
The six areas your statement must address
Section 54 of the Modern Slavery Act sets out six areas a statement should cover. While only the first is strictly mandatory, omitting the others signals to buyers that your approach is superficial.
1. Organisation structure and supply chains
RequiredDescribe your business model, the sectors you operate in, the countries you source from, and the structure of your supply chains. Be specific — vague descriptions undermine credibility.
2. Policies in relation to slavery and human trafficking
List your relevant policies: supplier code of conduct, whistleblowing policy, recruitment policy, and any specific anti-slavery policy. State whether they apply to your own operations and your supply chain.
3. Due diligence processes
Explain how you assess and manage modern slavery risk in your supply chain. This includes supplier questionnaires, audits, risk assessments, and how you respond when issues are identified.
4. Risk assessment and management
Identify which parts of your business and supply chain carry the highest risk — by geography, sector, or product type. Explain how you prioritise your due diligence efforts accordingly.
5. Key performance indicators
Describe how you measure the effectiveness of your actions. Examples: number of suppliers assessed, percentage of high-risk suppliers audited, number of staff trained, incidents identified and resolved.
6. Training
Explain what training you provide to staff — particularly those involved in procurement, HR, and supply chain management — to help them identify and respond to modern slavery risks.
Common mistakes that undermine your statement
✗ Generic boilerplate
Buyers and auditors can spot copy-paste statements immediately. Your statement must reflect your actual business, your actual supply chains, and your actual actions.
✗ No mention of risk
Claiming you have found no modern slavery risk in your supply chain is almost never credible. Acknowledge where risk exists and explain how you manage it.
✗ Policies without evidence of implementation
Listing policies is not enough. Explain how they are communicated, how compliance is monitored, and what happens when they are breached.
✗ No KPIs or metrics
Statements without measurable outcomes cannot demonstrate progress. Even simple metrics — number of suppliers assessed, training completion rates — add credibility.
✗ Not signed by a director
The statement must be approved by the board and signed by a director or equivalent. An unsigned or improperly approved statement is non-compliant.
Step-by-step: writing a credible statement
Map your supply chain
Before you can assess risk, you need to know who your suppliers are — and who their suppliers are. Start with tier-one suppliers and work outward. Identify which countries and sectors carry the highest inherent risk.
Conduct a risk assessment
Use your supply chain map to identify where modern slavery risk is highest. High-risk indicators include: sourcing from high-risk countries, use of agency labour, complex multi-tier supply chains, and sectors with known vulnerability (agriculture, construction, hospitality, manufacturing).
Review and update your policies
Ensure you have a supplier code of conduct, a whistleblowing policy, and a recruitment policy that prohibits the use of unlawful labour. Make sure they are communicated to relevant staff and suppliers.
Implement due diligence processes
Send supplier questionnaires to high-risk suppliers. Conduct audits where appropriate. Establish a clear process for investigating and responding to concerns raised by workers or suppliers.
Train relevant staff
Ensure procurement, HR, and supply chain staff can recognise the signs of modern slavery and know how to report concerns. Record training completion so you can report it as a KPI.
Draft, approve, and publish
Write the statement, have it approved by your board, and have it signed by a director. Publish it on your website in a prominent location — ideally linked from the footer. Submit it to the government's Modern Slavery Statement Registry.
What happens if you do not comply?
The Home Office can seek a court injunction to compel non-compliant organisations to publish a statement. More immediately, large buyers are increasingly checking whether their suppliers have published statements — and removing those who have not from approved supplier lists. Reputational and commercial consequences are the primary enforcement mechanism in practice.
The government's Modern Slavery Statement Registry (modern slavery registry at gov.uk) allows anyone to search for and read your statement. Buyers, investors, journalists, and NGOs use it routinely.
Build your Modern Slavery Act evidence with ESG Stress Free
ESG Stress Free's Modern Slavery Act readiness assessment guides you through all six statement areas, helps you map supply chain risk, and produces a structured compliance record you can use to draft your annual statement — without a legal team.
Start your Modern Slavery Act readiness assessment →Further reading
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Free Modern Slavery Act checklist
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