Modern Slavery Act Requirements in the UK

If you sell products, outsource services or rely on a supply chain, modern slavery risk touches your business - even if you’re a small team. The Modern Slavery Act 2015 was designed to drive transparency through UK supply chains, and while the headline duty to publish a statement formally applies to larger organisations, smaller businesses are increasingly expected to show they’re managing these risks too.

Don’t stress - you don’t need a big compliance department to get this right. With a clear, proportionate plan, you can meet expectations, protect your brand and win work with larger customers who now vet suppliers for modern slavery risk as standard.

Below, we break down what the Modern Slavery Act requires, how those requirements impact SMEs in practice, and the simple steps you can take to build a fit‑for‑purpose program.

What Is The Modern Slavery Act And Why It Matters To Small Businesses

The Modern Slavery Act 2015 (MSA) targets serious exploitation such as forced labour, servitude, human trafficking and child labour. Section 54 of the Act focuses on transparency in supply chains: qualifying organisations must publish an annual slavery and human trafficking statement describing the steps they have taken to ensure modern slavery is not taking place in their business or supply chains.

Even if your business is below the formal reporting threshold, the MSA still matters because:

• Larger customers (who must report) now cascade supplier due diligence and contract requirements down the chain.
• Tender processes and public sector buyers commonly ask all bidders - regardless of size - to confirm their approach to modern slavery risk.
• Consumers, investors and employees increasingly expect ethical sourcing and transparent practices.
• Police and regulators target organised labour exploitation in UK sectors such as construction, cleaning, hospitality, agriculture and logistics - common industries for SMEs.

In short, small businesses are part of the same ecosystem. Having proportionate controls in place isn’t just good governance - it’s often a commercial necessity.

Do Modern Slavery Act Requirements Apply To SMEs?

Section 54 applies to “commercial organisations” that do all of the following:

• Carry on business in the UK, and
• Supply goods or services, and
• Have a total annual turnover of at least £36 million (including subsidiaries).

If you meet that threshold, you must publish a modern slavery statement for each financial year. If you’re under the threshold, you are not legally required to publish a statement. However, you should still expect practical obligations to arise via:

• Customer procurement requirements (e.g., code of conduct acceptance, audits, questionnaires).
• Contract clauses on modern slavery, audit rights and termination for ethical breaches.
• Industry certifications or membership standards that require risk assessments and training.

Many SMEs choose to publish a voluntary statement or summary policy. It signals your commitment, helps you respond to tenders quickly and creates a single source you can share with customers and staff.

There is also a government-run online registry where organisations can publish their statements. While publication on the registry has been encouraged, not all features around mandated content or penalties have been brought into force. The direction of travel is clear though: expectations are rising, and having a clear approach is fast becoming a baseline.

What A Compliant Modern Slavery Statement Should Cover

If you are required to publish a statement (or choose to publish one voluntarily), Section 54 expects a concise, accessible document written in plain English. Best practice is to cover the following areas in a way that is proportionate to your size and risk profile:

• Organisation structure and supply chains - who you are, what you do, and where you operate and source.
• Policies - your stance on modern slavery and related policies (e.g., supplier code, recruitment, whistleblowing).
• Risk assessment - where the higher risks are in your business and supply chains (by sector, geography, product or service).
• Due diligence - how you vet and onboard suppliers and labour providers, including checks and questionnaires.
• Action taken - what controls you’ve put in place (contract clauses, audits, training, KPIs).
• Effectiveness - how you monitor performance and measure progress over time.
• Training - who you train, how often, and on what topics.
• Next steps - your improvement plan for the coming year.

Approval and publication rules are important:

• Approval - for companies, the board should approve the statement and a director should sign it.
• Timing - publish as soon as reasonably practicable after your financial year end (best practice is within six months).
• Accessibility - place it on your website with a clear link on the homepage.

Keep the document specific to your business. A short, tailored statement beats a generic template because it shows you understand your unique risks and controls.

Practical Steps To Meet Modern Slavery Act Requirements

You don’t need gold‑plated processes. Start with sensible, proportionate steps that match your size and risk profile and build from there.

1) Map Your Supply Chain

List your suppliers and labour providers, what they do, and where they operate. Flag higher‑risk areas (e.g., outsourced manufacturing in higher‑risk countries, seasonal labour, cleaning, security, packaging, logistics).

2) Assess Your Risks

Consider indicators such as country risk, sector risk (e.g., agriculture, construction, textiles), type of work (low‑skilled, cash‑paid, night shifts), and use of third‑party labour providers. This helps you prioritise where to focus due diligence and contract controls.

3) Put The Right Policies In Place

Adopt a short modern slavery policy or supplier code of conduct and make sure it aligns with how you actually operate. Include expectations around recruitment practices, wage payment, freedom of movement, and right to audit. Strengthen your governance with clear roles and escalation routes for red flags. Many SMEs also benefit from a simple Conflict of Interest Policy so decision‑making around suppliers remains transparent.

4) Build Modern Slavery Into Contracts

Update your standard contracts to include practical obligations on suppliers: compliance with your policy, audit and information rights, sub‑contracting controls, and termination for serious breaches. Your templates, such as a Supply Agreement or Distribution Agreement, should reflect these expectations and be clear about consequences for non‑compliance.

5) Vet New Suppliers And Labour Providers

Introduce proportionate onboarding checks. For higher‑risk suppliers, use questionnaires, request policies and evidence of worker protections, and verify licences or labour provider registrations. For lower‑risk suppliers, lighter checks may be enough. Document your rationale either way.

6) Train Your Team

Provide short, role‑specific training for those who buy from or manage suppliers, and for anyone recruiting workers. Cover red flags (e.g., workers not holding their own passports, cramped tied accommodation, withheld wages) and how to escalate concerns.

7) Set KPIs And Keep Records

Track the number of suppliers assessed, contracts updated, issues raised and resolved, and training completion rates. Store onboarding records, risk assessments and remediation outcomes. These will support your annual statement and show continuous improvement.

8) Plan For Remediation

If you identify exploitation, your response should prioritise the safety and wellbeing of workers. Have an escalation plan, identify support organisations you can contact, and be ready to cooperate with authorities if needed. Where possible, remediate rather than simply terminate, but be prepared to exit where suppliers won’t cooperate.

Working With Staff And Suppliers: Policies, Contracts And Training

Modern slavery risk management cuts across your people and procurement processes. A few practical building blocks go a long way.

Employment And Labour

Clear, fair terms for your own workers reduce the risk of exploitation in your business. Make sure your Employment Contract sets out hours, pay, deductions and holiday in plain English. Build your expectations and procedures into a user‑friendly Staff Handbook - for example, covering recruitment, agency worker controls and how to report concerns.

If you engage freelancers or outsourced specialists, use a proper Contractor Agreement that defines the relationship and prohibits sub‑contracting without consent. This helps you retain visibility of who is doing the work and under what conditions.

Whistleblowing

Workers and suppliers are often the first to spot issues. A simple, confidential reporting channel makes it far more likely you’ll hear about concerns early. A tailored Whistleblower Policy can set out how to raise concerns, protections for reporters and how you’ll respond.

Supplier Terms And Onboarding

As noted above, build modern slavery clauses into your standard order terms and supplier templates. If you sell online or offer customer‑facing services, ensure your core terms don’t contradict your ethical commitments - the same goes for your website notices like a Privacy Policy if you’re hosting your statement on your site. Consistency across your documents shows you mean what you say.

Training And Awareness

Keep training short and practical. New starters in procurement or operations should receive a simple induction: what the risks look like in your sector, the checks you expect them to do, and how to escalate any red flags. Annual refreshers can be bite‑sized and focused on updates or lessons learned.

Enforcement, Public Expectations And What’s Changing

Under Section 54, if a qualifying organisation fails to publish a statement, the Secretary of State can seek an injunction (or specific performance) to require publication. Monetary penalties haven’t historically been part of Section 54 enforcement, but non‑compliance carries real commercial risks:

• Procurement exclusion - public buyers and big corporates may disqualify non‑compliant bidders.
• Contract risk - many customer contracts make publication and ongoing compliance a condition; breaches can trigger termination.
• Reputational damage - NGOs, the media and customers scrutinise companies that lag behind.

The UK Government has consulted on strengthening the regime, including mandating specific content, setting a single reporting deadline, requiring publication on the government registry and introducing civil penalties for failures. Some measures have been implemented through policy and procurement rules, and further legislative change has been discussed. The practical takeaway for SMEs is simple: expectations are tightening, and customers will continue to push modern slavery requirements down the supply chain.

If you’re below the threshold, you won’t suddenly need a 30‑page report. But having a compact, proportionate program - and, if helpful, a short public statement - will put you in a strong position with customers and regulators as the landscape evolves.

Key Takeaways

• Section 54 of the Modern Slavery Act requires organisations with turnover of £36m+ to publish an annual statement approved by the board and signed by a director.
• SMEs below the threshold still face practical requirements via customer contracts, tenders and market expectations - a proportionate approach is essential.
• Your statement (mandatory or voluntary) should cover structure, policies, risks, due diligence, actions, effectiveness, training and next steps, and be easy to find on your website.
• Focus on basics: map suppliers, assess risks, embed policy and contract clauses, vet higher‑risk suppliers, train staff, and keep simple records to show progress.
• Strengthen your documents: align your Supply Agreement, Employment Contract and Whistleblower Policy with your modern slavery stance.
• Expect ongoing change - public scrutiny and buyer requirements are increasing, so building a simple, credible program now will save headaches later.

If you’d like help drafting a modern slavery statement or updating your supplier and employment documents to reflect your ethical sourcing commitments, you can reach us at 08081347754 or team@sprintlaw.co.uk for a free, no‑obligations chat.