Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
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If you run a small business, “modern slavery” can feel like something that only affects huge global brands with complex overseas supply chains.
But the reality is that modern slavery risks can show up in plenty of everyday business scenarios - from outsourcing labour and using recruitment agencies, to buying stock from wholesalers, to relying on cleaning, security, warehousing, construction, hospitality or manufacturing services.
That’s why having a clear modern slavery policy for UK businesses is a smart move, even if you’re not strictly required to publish a Modern Slavery Statement under the law.
Below, we break down what a modern slavery policy is, who needs one, what to include, and practical compliance steps that make sense for growing businesses.
What Is A Modern Slavery Policy (And Who Needs One In The UK)?
A modern slavery policy is an internal document that sets out your business’s commitment to preventing modern slavery and human trafficking in:
- your operations (how you run the business day-to-day), and
- your supply chains (the people and businesses you buy from, contract with, or outsource work to).
In the UK, modern slavery is primarily addressed under the Modern Slavery Act 2015. One key part of that Act is the requirement for certain organisations to publish an annual Modern Slavery Statement (sometimes called a “slavery and human trafficking statement”).
Do You Legally Need A Modern Slavery Policy UK Businesses Use?
Strictly speaking, the Modern Slavery Act 2015 does not say “you must have a modern slavery policy”.
However, if you are required to publish a Modern Slavery Statement, you’ll usually need a policy (or equivalent internal framework) to support what you’re saying publicly. Otherwise, it can be hard to demonstrate that you take the issue seriously and have practical steps in place.
Even if you’re below the reporting threshold, many smaller businesses still adopt a modern slavery policy because:
- larger customers may ask for it during onboarding or tendering
- it helps you run a cleaner, lower-risk supply chain
- it supports ESG commitments and responsible business practices
- it helps you train staff and set expectations internally
When Do You Need To Publish A Modern Slavery Statement?
Generally, you must publish an annual Modern Slavery Statement if your organisation:
- is a commercial organisation (company or partnership),
- supplies goods or services,
- carries on a business (or part of a business) in the UK, and
- has a total annual turnover of £36 million or more.
In practice, whether you meet the threshold can depend on how “total turnover” is calculated, including (in many cases) group structures and consolidated turnover. If you’re close to the threshold, it’s worth getting advice on how the test applies to your specific setup.
That said, even if you don’t meet the turnover threshold, you may be “pulled into” modern slavery compliance because a larger business you supply to requires you to confirm what safeguards you have in place.
As a general starting point, it also helps to understand what laws businesses have to follow as you scale - because modern slavery risk tends to sit across multiple areas (employment, procurement, regulatory compliance, reputational risk, and governance).
What Should A Modern Slavery Policy UK Businesses Put In Writing?
A strong modern slavery policy should be practical, specific to your operations, and easy for your team (and suppliers) to follow.
For small businesses, it’s usually best to keep it clear and actionable rather than overly long or legalistic.
1. A Clear Policy Statement And Scope
Start by setting out:
- your commitment to preventing modern slavery and human trafficking
- the parts of your business the policy applies to (employees, contractors, suppliers, subsidiaries, etc.)
- where the risk might arise (supply chains, labour providers, subcontracting, etc.)
This is also the right place to define key terms in plain English (modern slavery, forced labour, debt bondage, human trafficking, child labour).
2. Roles And Responsibilities
Spell out who is responsible for what. For example:
- Directors/senior leadership: overall accountability and annual review
- Procurement/operations: supplier checks, onboarding and monitoring
- HR/people team: recruitment checks, worker protections, training
- Managers: spotting red flags and escalating concerns
If you’re a micro business and don’t have departments, you can keep this simple (e.g. “The Director is responsible for oversight; the Operations Manager is responsible for supplier onboarding checks”).
3. Recruitment And Labour Practices
This section should explain how you reduce the risk of exploitation in your workforce. For example:
- right to work checks and lawful employment practices
- no recruitment fees charged to workers (directly or indirectly)
- clear written terms for workers
- fair pay, lawful working hours, and safe working conditions
If you engage staff directly, it’s important your Employment Contract and onboarding processes match what you say in your policy (for example, around pay practices, grievance processes and working conditions).
4. Supplier Due Diligence And Risk Assessment
This is often the “meat” of a modern slavery policy.
It should cover how you:
- identify which suppliers/services are higher risk (e.g. labour-intensive industries, overseas manufacturing, complex subcontracting chains)
- screen suppliers before onboarding (questionnaires, certifications, references, site audits where appropriate)
- monitor suppliers over time (periodic reviews, contractual reporting obligations, spot checks)
For many SMEs, risk-based due diligence is the most realistic approach - you don’t need to treat every supplier the same, but you do need a defensible process.
5. Reporting, Whistleblowing And Non-Retaliation
Your policy should make it easy for people to raise concerns safely, including:
- how staff can report suspected modern slavery risks
- how external parties (suppliers, workers, customers) can report concerns
- a commitment to investigate reports and take action
- protection from retaliation for raising concerns in good faith
Many businesses choose to include (or align this with) a Whistleblower Policy, so there’s one consistent pathway for reporting serious issues.
6. Training And Awareness
Training doesn’t need to be complicated, but it should be purposeful. Your policy can cover:
- who will be trained (e.g. managers, procurement, HR, site supervisors)
- what training covers (red flags, reporting steps, supplier onboarding checks)
- how often training happens (e.g. at onboarding + annual refresh)
7. Consequences And Remedies
It’s important to explain what happens if:
- a staff member breaches the policy (disciplinary steps), and/or
- a supplier is found to be non-compliant (remediation plan, suspension, termination).
This is where your policy connects to your contracts and supplier management (more on this below).
How Do You Comply With Modern Slavery Requirements In The UK? (A Step-By-Step Approach)
If you’re building (or upgrading) a modern slavery policy UK compliance program, think of it as a cycle: assess → implement → monitor → improve.
Step 1: Map Your Supply Chain (At Least The Key Parts)
You don’t need to map every single purchase down to the last stationery supplier. Start with the suppliers that:
- provide labour (directly or indirectly)
- operate in higher-risk industries (construction, cleaning, hospitality, manufacturing, logistics)
- source goods from higher-risk regions
- use subcontractors
- provide critical goods/services for your operations
This gives you a realistic “risk map” you can actually manage.
Step 2: Carry Out A Risk Assessment
Assess risk by looking at:
- Country risk (governance, labour standards, enforcement)
- Industry risk (known exploitation hotspots)
- Business model risk (subcontracting, temporary labour, high turnover workforces)
- Supplier behaviour (unusual payment arrangements, refusal to share information, extremely low pricing)
Your policy should reflect this risk-based approach - it’s one of the most defensible ways to show you’re taking “reasonable steps”.
Step 3: Update Supplier Onboarding
Make modern slavery checks part of onboarding, for example:
- a supplier questionnaire
- requiring suppliers to confirm compliance with applicable laws
- asking whether they use subcontractors and how they manage them
- collecting evidence of policies and training (where appropriate)
If you share data with suppliers during onboarding (like contact details for staff, site access lists, or worker information), make sure your data sharing and privacy position is also consistent - many businesses cover this via a Data Processing Agreement where suppliers process personal data on your behalf.
Step 4: Put The Right Contract Terms In Place
A modern slavery policy is much more effective when it’s backed up by contract rights, such as:
- warranties that suppliers comply with modern slavery laws
- obligations to maintain policies and training
- audit/inspection rights (even if you rarely use them)
- notification obligations if an issue is identified
- termination rights for serious breaches
This can often be built into your Supply Agreement or supplier terms and conditions so it’s not a separate “extra” document that gets forgotten.
Step 5: Train Your Team And Make Reporting Easy
Even the best policy won’t help if nobody knows it exists.
Make sure:
- new starters know where to find the policy
- managers know what red flags to look for
- procurement/operations know what checks are required
- reporting is simple (a dedicated email address or form)
Step 6: If You Publish A Modern Slavery Statement, Get The Governance Right
If your business is required to publish a statement (or chooses to voluntarily), you should plan for:
- annual review (it’s updated every financial year)
- board or director approval
- clear sign-off by a director (or equivalent)
- publishing it in the right place (typically your website, with a prominent link)
The statement should accurately reflect what you’re actually doing. Overstating your processes can create reputational and legal risk (especially if a customer relies on your statement during procurement).
How Does A Modern Slavery Policy Affect Your Contracts, Hiring And Day-To-Day Operations?
One of the biggest mistakes we see is businesses treating modern slavery compliance like a “PDF exercise” - something they publish and then never think about again.
In practice, your modern slavery policy should connect to how you run the business day-to-day.
Supplier Relationships And Subcontracting
If you regularly outsource work (for example, events, construction, installation, cleaning or IT services), the risk can increase where suppliers:
- use subcontractors without telling you
- recruit workers through labour agencies
- operate in cash-heavy environments
Practically, that means you may want to:
- require written approval before subcontracting
- ask suppliers to maintain worker records and wage compliance
- have a right to request information and investigate concerns
If you’re not sure whether your current documents do enough, a targeted Contract Review can help you spot gaps quickly (without rebuilding everything from scratch).
Hiring, Agencies And Labour Providers
If you use recruitment agencies or labour providers, your modern slavery policy should align with:
- how you vet agencies
- how you ensure workers are paid correctly
- how workers can raise concerns
- how you handle accommodation or transport arrangements (where relevant)
Even small businesses should be careful about “informal” arrangements that can inadvertently increase risk - for example, unclear pay arrangements, no written terms, or workers being dependent on a single intermediary for hours and wages.
Your Website And Public-Facing Policies
Modern slavery compliance often overlaps with reputational and stakeholder expectations. If you collect personal data as part of supplier onboarding, recruitment, or whistleblowing reports, it’s worth checking your public Privacy Policy is consistent with how you actually handle that information.
This isn’t just about best practice - it’s also part of building trust with suppliers, customers and workers.
What Happens If You Don’t Have A Modern Slavery Policy (Or You Get It Wrong)?
For small businesses, the risks of not having a modern slavery policy (or having a weak one) are often commercial and operational - but the legal and reputational consequences can also be significant.
1. Lost Deals And Procurement Issues
It’s increasingly common for larger organisations (and public sector bodies) to ask suppliers about modern slavery controls. If you can’t provide:
- a modern slavery policy,
- evidence of supplier checks, or
- a coherent statement of your approach,
you may lose contracts even if you’re a great supplier operationally.
2. Reputational Damage
Modern slavery allegations can seriously harm your brand - especially if you’re customer-facing or values-driven. Even where issues sit “down the chain”, businesses are often judged on what they did (or didn’t do) to prevent and respond to them.
3. Contractual And Misrepresentation Risk
If you commit to certain standards in a contract, tender response or published statement, and it later turns out your business didn’t follow through, you could face disputes. This can become particularly sensitive where customers say they relied on your representations to choose you.
4. Internal Risk: Lack Of Reporting And Escalation
If staff don’t know how to report concerns, issues can go unaddressed for longer than they should - which usually makes outcomes worse (for affected people and for your business).
A good policy gives you a clear pathway: identify → report → investigate → remedy → prevent recurrence.
Key Takeaways
- A modern slavery policy for UK businesses should be a practical document that sets expectations for your workforce and supply chain, not just a box-ticking exercise.
- If you meet the criteria under the Modern Slavery Act 2015 (including the £36m turnover threshold, which can involve group/consolidated turnover), you’ll likely need to publish an annual Modern Slavery Statement - and a policy helps support it.
- Your policy should cover scope, responsibilities, recruitment practices, supplier due diligence, reporting/whistleblowing, training, and consequences for breaches.
- Compliance is much easier when your policy is backed by supplier onboarding processes and contract terms (including audit and termination rights).
- Even if you’re a smaller business, modern slavery compliance can be required by customers, investors, or tender processes - so having a sensible policy can directly protect your revenue.
- If you’re unsure what’s proportionate for your business, getting legal advice early can save time and reduce risk as you grow.
Important: This article is general information only and not legal advice. Modern slavery compliance can be fact-specific, especially for group structures and cross-border supply chains.
If you’d like help putting together a modern slavery policy, updating your supplier terms, or sense-checking your compliance approach, you can reach us at 08081347754 or team@sprintlaw.co.uk for a free, no-obligation chat.
