UK Modern Slavery Act Compliance Requirements for Businesses

If you run a small business, it’s easy to assume the Modern Slavery Act 2015 is only a “big corporate” issue.

But the truth is, modern slavery risks can show up anywhere there’s a supply chain, subcontracting, labour providers, overseas manufacturing, or even rushed procurement. And if your business meets certain thresholds, there are specific Modern Slavery Act requirements you must follow.

Even if the legal reporting duty doesn’t technically apply to you yet, your customers, investors, and commercial partners may still expect you to have policies and checks in place.

Below, we’ll break down what the Modern Slavery Act requires (in plain English), who it applies to, what your statement needs to include, and practical steps you can take to stay compliant without drowning in red tape.

What Are The Modern Slavery Act Requirements (And Why Do They Matter)?

The Modern Slavery Act 2015 is the UK’s key law aimed at combating modern slavery, forced labour, and human trafficking. For businesses, the most well-known part is the transparency in supply chains obligation in section 54.

In short, section 54 requires certain organisations to publish an annual modern slavery statement explaining what they have done (or are doing) to identify and address modern slavery risks in:

• their own operations; and
• their supply chains.

This matters for small businesses because:

• You may be legally required to publish a statement if you meet the threshold.
• Even if you’re below the threshold, your clients may ask for your statement anyway as part of their own compliance checks.
• Modern slavery compliance is increasingly tied to tendering and procurement (especially with public sector work and larger corporate supply chains).
• The biggest risk is often reputational damage-but poor controls can also create commercial disputes, operational disruption, and serious governance issues.

Think of it like this: you’re not expected to magically “guarantee” there is zero risk. But you are expected to take sensible steps to understand your risk exposure and manage it responsibly.

Does The Modern Slavery Act Apply To Your Business?

The headline legal reporting duty under section 54 applies if your organisation:

• is a commercial organisation (which includes companies and partnerships);
• 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 (including certain group turnover considerations).

If you tick those boxes, the Modern Slavery Act requirements aren’t optional-you’ll need to publish a statement for each financial year, as soon as reasonably practicable after your financial year-end.

What If You’re Under £36m Turnover?

If you’re below the threshold, you may not have a legal duty to publish a statement under section 54. But you still might be expected (commercially) to engage with modern slavery compliance because:

• Large customers might contractually require it (or require you to answer a due diligence questionnaire).
• You may need to show you have appropriate policies and controls for ESG, investment, or partnership reasons.
• You might be in a higher-risk sector (for example: construction, manufacturing, hospitality, cleaning, logistics, recruitment/labour supply, textiles).

Also, if you scale quickly, you don’t want to scramble later. Setting up decent processes now is usually faster and cheaper than trying to retrofit compliance under pressure.

Quick Reality Check: “Supply Chains” Includes Services

Many businesses hear “supply chain” and only think “factories overseas”. But supply chain risk can also arise with:

• contract labour and agency workers;
• subcontractors (including multi-tier subcontracting);
• cleaning, security, catering, and facilities management providers;
• IT and hardware procurement;
• shipping and logistics partners; and
• raw materials and packaging suppliers.

If your business is buying services or goods from others to deliver your product, you have a supply chain.

What Must A Modern Slavery Statement Include?

The Modern Slavery Act doesn’t force you into a single rigid template, but it does set expectations around what your statement should cover.

In practice, your statement should explain the steps your business has taken during the financial year to ensure modern slavery is not taking place in:

• your business; and
• your supply chains.

Common areas a statement typically addresses include:

• Your business structure, operations, and supply chains (so readers understand where your risks might be).
• Your policies on modern slavery and human trafficking.
• Due diligence processes (how you screen suppliers, labour providers, subcontractors, and key partners).
• Risk assessment and risk management (what you see as the biggest risk areas and what you’re doing about them).
• Key performance indicators (KPIs) (how you measure progress, even if it’s basic at first).
• Training (what training you provide staff who manage procurement, recruitment, onboarding, and supplier relationships).

Approval And Signing: Don’t Miss The Governance Step

A common compliance slip-up is publishing a statement that isn’t properly approved.

For companies, the statement should typically be approved by the board and signed by a director (or equivalent senior person). For LLPs/partnerships, the approval/signing rules differ slightly, but the core idea is the same: the statement needs proper sign-off at the top.

This is one reason it’s worth treating modern slavery compliance as a governance item, not just a “website update”. Keeping good meeting notes and decision records is also a smart move-especially if you’re ever challenged on what you did and when.

Publication: Where Does It Need To Go?

If your organisation has a website, the statement should be published online and be easy to find, with a prominent link on your homepage (many businesses place it in a footer link).

If you don’t have a website, you still need to make the statement available on request (but in reality, most organisations will publish it online for simplicity and transparency).

A Practical Compliance Checklist For Small Businesses (Step-By-Step)

Even if your business is lean, you can build a sensible modern slavery compliance process without turning it into a full-time job. The goal is to take reasonable, proportionate steps and keep improving year on year.

1) Work Out Your Risk Profile

Start by identifying where risk might show up in your operations and supply chain. Ask:

• Do we use subcontractors or labour providers?
• Do we source goods from overseas or high-risk sectors?
• Are we buying from suppliers with complex, multi-tier supply chains?
• Do we have seasonal spikes that create pressure to recruit quickly?
• Do we operate in sectors known for low pay, insecure work, or cash-in-hand arrangements?

You don’t need to boil the ocean. Focus on the biggest and most obvious risk areas first.

2) Map Your Key Suppliers And Labour Channels

Make a list of your:

• top suppliers by spend;
• suppliers who are operationally critical (even if spend is low);
• labour providers and recruitment channels;
• subcontractors and outsourced service providers.

For many small businesses, your initial “map” can be a simple spreadsheet. The important thing is to know who you rely on and where they operate.

3) Put The Right Contract Terms In Place

This is where small businesses can make a big difference quickly.

Your supplier and subcontractor contracts can include practical obligations such as:

• compliance with modern slavery and labour laws;
• requirements to maintain their own policies and training;
• rights for you to request information or conduct audits (proportionate to the relationship);
• flow-down obligations to their own subcontractors; and
• termination rights if serious breaches are identified.

If you’re engaging suppliers to deliver core goods or ongoing services, having a properly drafted Supply Agreement or Goods & Services Agreement can help you document these expectations clearly from day one.

4) Create (Or Update) Your Internal Policies

Policies matter because they tell your team what “good” looks like and what to do if something feels off.

Depending on your business model, you might consider:

• a modern slavery policy (or a broader ethical sourcing policy);
• supplier onboarding and screening procedures;
• an internal reporting process for concerns; and
• staff guidance on procurement and onboarding risks.

A reporting channel is especially important. If someone spots a red flag (for example, suspicious recruitment practices, withheld passports, unusually high recruitment fees, or threats), they need a safe way to raise it. A Whistleblower Policy can help set expectations and protect the integrity of your process.

5) Train The People Who Need To Spot Red Flags

You usually don’t need to train everyone at the same intensity. Start with roles that influence purchasing and workforce engagement, such as:

• directors and senior managers;
• procurement and operations;
• HR and recruitment (if you hire staff);
• site managers (for labour-heavy sectors); and
• anyone approving suppliers or subcontractors.

Training doesn’t have to be complicated. The key is that people understand what modern slavery can look like in real business settings and what steps to take if they’re concerned.

If you’re hiring, it’s also worth checking that your onboarding and standards are clear in your Employment Contract and related workplace policies.

6) Put A Simple Due Diligence Process In Place

Due diligence doesn’t have to mean a 40-page questionnaire for every supplier. The best approach is usually tiered:

• Low-risk, low-spend suppliers: basic screening (company checks, basic confirmation of compliance).
• Higher-risk suppliers: written questionnaires, requesting policies, and clarifying labour practices.
• Critical/high-risk suppliers: deeper diligence, possibly including audit rights and ongoing monitoring.

The point is to be able to show you’ve taken reasonable steps to understand your risks and address them.

7) Keep Records So You Can Prove What You Did

Compliance isn’t just about doing the work-it’s also about being able to evidence it. Keep:

• supplier screening records;
• modern slavery questionnaires and responses;
• training logs;
• incidents/concerns raised and actions taken; and
• board approval records for your statement.

If you ever need to defend your approach (to a customer, investor, regulator, or journalist), a clear paper trail makes a huge difference.

Common Mistakes Small Businesses Make (And How To Avoid Them)

Most modern slavery compliance problems aren’t caused by bad intentions-they happen because a growing business is busy and the legal/admin side gets left behind.

Here are some common pitfalls we see, and how you can avoid them.

Publishing A “Generic” Statement With No Real Actions

A statement that says “we take modern slavery seriously” but doesn’t explain your actual steps can create risk.

It’s usually better to be honest and specific about what you’ve implemented this year (even if it’s a modest start), and what you plan to improve next year.

Not Aligning The Statement With What You Actually Do

Your statement is a public document. If it claims you audit suppliers, but you don’t, you’re creating a credibility gap.

A safer approach is to describe your real process accurately, including the level of due diligence you apply depending on supplier risk.

Forgetting About Data Protection When You Collect Information

Modern slavery due diligence can involve collecting personal data (for example, names of directors, worker information, certifications, incident reports, whistleblowing complaints, or audit findings).

That means you need to think about privacy and data handling too, particularly under the UK GDPR and the Data Protection Act 2018.

If you’re collecting or processing personal information as part of your compliance processes, having a clear Privacy Policy and appropriate contractual protections such as a Data Processing Agreement can help reduce legal risk and keep your processes tidy.

Not Building Modern Slavery Checks Into Procurement “From Day One”

When you’re moving fast, it’s tempting to onboard a supplier first and “do the paperwork later”. But that’s how risk sneaks in-especially where there are subcontracting layers.

Try to build a simple gate into your procurement process: no new supplier becomes “approved” without at least basic checks and contract terms.

Treating It As A One-Off Task

Modern slavery compliance is ongoing. Your supply chain changes, your hiring patterns change, and your risk profile evolves as you grow.

Set a recurring annual review date aligned with your financial year so you can update your processes and publish your statement on time (as soon as reasonably practicable after year-end).

What Happens If You Don’t Comply?

For businesses that are legally required to publish a statement, non-compliance can create several layers of risk.

• Legal enforcement: the Secretary of State can seek an injunction (or, in Scotland, an order for specific performance) requiring compliance.
• Commercial consequences: customers may remove you from preferred supplier lists or treat it as a breach of contract.
• Procurement and tender risk: you may lose out on public sector or large corporate work if you can’t demonstrate compliance.
• Reputational harm: failure to report (or publishing a weak statement) can trigger negative attention.

Even for businesses below the turnover threshold, ignoring modern slavery risk can still cause serious commercial issues if a supply chain incident hits and you can’t show you took reasonable steps.

Key Takeaways

• The core Modern Slavery Act requirements for many businesses come from section 54 of the Modern Slavery Act 2015, which requires certain organisations to publish an annual modern slavery statement.
• The statement obligation generally applies if you supply goods or services, carry on business in the UK, and have £36m+ turnover (including relevant group turnover considerations).
• Even if you’re under the threshold, you may still need modern slavery controls because customers and partners often require them contractually.
• A practical compliance approach includes risk assessment, supply chain mapping, contract protections, policies and reporting channels, training, and record keeping.
• Make sure your statement is properly approved and signed, is easy to find on your website (with a prominent homepage link), is published as soon as reasonably practicable after your financial year-end, and accurately reflects what you actually do.
• Getting the legal foundations right early (including your supplier contracts, internal policies, and data protection compliance) puts you in a stronger position as your business grows.

If you’d like help putting the right policies and contract terms in place, or you’re not sure whether the Modern Slavery Act reporting duty applies to your business, you can reach us at 08081347754 or team@sprintlaw.co.uk for a free, no-obligations chat.