ESG & supply chain
UK Modern Slavery Act 2015
Published Reviewed
What is Modern Slavery Act?
The UK Modern Slavery Act requires qualifying organisations to publish an annual, board-approved statement describing steps taken against slavery in operations and supply chains.
| Jurisdiction | United Kingdom |
|---|---|
| Authority | Modern Slavery Act 2015 |
| Current status | Section 54 commenced in 2015 |
| Reviewed |
Why it matters operationally
Section 54 requires every commercial organisation carrying on business in the UK with £36 million or more in global turnover to publish an annual slavery and human trafficking statement — approved by the board, signed by a director, and linked prominently from the website homepage. The duty catches non-UK companies with UK business, and turnover counts group-wide. The statement itself is the exposure: it is public, compared year-on-year by NGOs and procurement teams, and a thin or recycled one reads as an admission that nothing is actually being done.
Are you aware?
The dates that bind
The turnover trigger is global, not UK-only
The threshold is total worldwide turnover including subsidiaries, for any commercial organisation carrying on a business, or part of a business, in the UK — a modest UK presence can pull a large foreign group into scope.
The statement follows your financial year
Government guidance expects publication within six months of financial year end, board-approved and director-signed, with a prominent homepage link. The voluntary government registry has become the de-facto place buyers check.
Reform points one direction: stricter
Reform proposals — mandating specific statement topics, central registration and penalties — have repeatedly advanced and stalled. The direction of travel is stricter; statements built to the current minimum will not survive it.
Where to start
- 1
Confirm scope: group turnover against the £36 million threshold and any entity carrying on business in the UK.
- 2
Ground the statement in real due diligence — risk-ranked supply-chain mapping, not a policy recitation.
- 3
Put the governance chain on the record: board approval, director signature, homepage link, and registry submission.
Authority links
Read the official sources
The official text is the authority. This guide is only a short orientation for operational planning.
Common questions
Frequently asked questions
We are not a UK company — does it apply?
It can: any commercial organisation, wherever incorporated, that carries on business or part of a business in the UK and meets the turnover test must publish a statement. A UK branch or subsidiary is usually enough.
What must the statement actually contain?
Formally, either the steps taken during the year or a statement that no steps were taken. Guidance — and buyer expectation — covers structure and supply chains, policies, due diligence, risk assessment, effectiveness indicators and training. "No steps" is lawful and reputationally radioactive.
How does it compare to CSDDD?
The Act requires transparency; CSDDD requires action with liability. UK-scoped groups heading into CSDDD scope can treat the statement as the public tip of a due-diligence system the EU regime will demand in substance.
Key terms in this guide
A quick self-check
Are you ready?
- Is this year’s statement board-approved, director-signed and one click from your homepage?
- Would your statement survive a line-by-line comparison with last year’s — or is it the same document with new dates?
- Could you show the risk-ranked supply-chain assessment behind the claims it makes?
Every question above has a written, evidence-backed answer in a well-run compliance record. If one made you pause, that pause is the gap.