Modern Slavery Act: what UK businesses must do in their supply chains

The UK Modern Slavery Act 2015 requires commercial organisations with an annual turnover of £36 million or more to publish an annual Modern Slavery Statement. The statement must describe the steps the organisation has taken to ensure that slavery and human trafficking are not taking place in its business or supply chains.

What does this mean for SME suppliers?

A large company producing a Modern Slavery Statement must demonstrate that it has assessed its supply chain. This means asking suppliers — including SMEs — to confirm their own labour practices, provide relevant policies (e.g. an anti-slavery policy, a supplier code of conduct), and disclose any risks in their own supply chains.

While an SME with under £36m turnover is not legally required to publish its own statement, it will increasingly be asked to provide evidence of its labour standards by customers who are. Refusing or being unable to provide this evidence puts the relationship at risk.

What evidence do buyers typically ask for?

• An anti-slavery and human trafficking policy
• Evidence of due diligence on your own suppliers (particularly those in higher-risk geographies)
• Training records showing staff awareness of modern slavery risks
• A whistleblowing or grievance mechanism

Getting started

The first step is to draft a simple anti-slavery policy and upload it to your ESGSimple document library. ESGSimple's SA8000-mapped questionnaire covers the key labour standards questions that buyers ask, so you can demonstrate compliance systematically rather than responding ad hoc to each customer request.