Most Modern Slavery statements do not go far enough. Here is what the Act actually requires from your supply chain and how to assess whether your suppliers are meeting it.
The Modern Slavery Act 2015 requires commercial organisations with a turnover of 36 million pounds or more to publish an annual statement setting out the steps they take to prevent modern slavery and human trafficking in their business and supply chains. The statement must be approved by the board, signed by a director, and published on the organisation's website.
On paper, that sounds clear. In practice, the quality of Modern Slavery statements across UK businesses varies enormously. A significant number of statements amount to little more than a declaration that the organisation is aware of the Act and takes it seriously, with no detail on what steps are actually being taken, what risks have been identified, or how the supply chain is being assessed.
What the Act Actually Requires
Section 54 of the Modern Slavery Act 2015 sets out what a statement may include. The word “may” is important because the Act does not mandate specific content, but the government guidance makes clear that certain areas are expected to be covered:
The organisation's structure, business, and supply chains. Its policies in relation to slavery and human trafficking. Its due diligence processes. The parts of its business and supply chains where there is a risk of slavery and human trafficking, and the steps taken to assess and manage that risk. Training available to staff. The effectiveness of the steps taken, as measured by key performance indicators.
This last point is the section that separates a serious statement from a tick-box exercise. If an organisation cannot point to any metrics or outcomes from its anti-slavery work, it is difficult to argue that the steps are effective.
The Problem with Tick-Box Compliance
Many organisations treat the Modern Slavery statement as a legal obligation to be discharged rather than a genuine assessment of supply chain risk. Common signs of a tick-box approach include statements that are identical year on year with no update on progress, statements that contain no reference to the organisation's actual supply chain, statements that describe policies but not actions, and statements that report no findings of risk.
For procurement teams assessing suppliers, a weak Modern Slavery statement is not necessarily evidence that the supplier is involved in exploitation. It is evidence that the supplier has not invested in understanding its supply chain risk, which is a governance concern in its own right.
What Good Practice Looks Like
A supplier that is genuinely addressing modern slavery risk will be able to demonstrate several things.
They will have mapped their supply chain to at least the first tier, identifying the countries, sectors, and labour types where risk is highest. High-risk areas typically include construction labour, cleaning and security services, agriculture and food processing, garment manufacturing, and any supply chain that relies on agency or temporary labour.
They will have a process for assessing suppliers against modern slavery indicators. This goes beyond asking a yes/no question on a form. It involves specific questions about labour practices, subcontracting, worker recruitment, and wage payment methods.
They will have taken action on findings. If their due diligence identifies a risk, there should be evidence of what was done about it: further investigation, corrective action plans with the supplier, alternative sourcing arrangements, or referral to the relevant authorities.
They will report on outcomes, not just activities. The difference between “we conducted 50 supplier audits” and “our supplier audits identified 3 suppliers with labour practice concerns, and we implemented corrective action plans with each one” is the difference between activity and outcome.
Assessing Your Supply Chain
For procurement and compliance teams, the practical step is to build modern slavery risk assessment into your existing supplier due diligence process rather than treating it as a standalone exercise.
Compliance questionnaires should include specific questions about labour practices, recruitment processes, and supply chain transparency. Document collection should include the supplier's published Modern Slavery statement, which you can then assess against the criteria described above.
Risk scoring should factor in the sector and geographic profile of the supplier's own supply chain. A supplier in professional services with a domestic supply chain carries different modern slavery risk than a supplier in construction with labour sourced through agencies.
The goal is not to catch suppliers out. It is to understand where the risk sits and to have evidence that you are taking reasonable steps to address it.
See how compliance packs in My Supplier List handle Modern Slavery risk assessment or request a demo.
