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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Looking for a modern slavery policy template you can copy straight into Word? You’re in the right place.
Even if your business doesn’t meet the legal threshold to publish a modern slavery statement, having a clear, workable policy is still smart risk management. It sets expectations for staff and suppliers, reduces compliance and reputational risk, and shows customers and partners that you take ethical sourcing seriously.
In this guide, we’ll explain what UK small businesses need to know about modern slavery compliance, what to put in your policy, how to roll it out in practice, and we’ll provide a clean, Word-ready template you can paste into your document and tailor to your business.
What Is A Modern Slavery Policy And Why Does It Matter?
A modern slavery policy is an internal document that sets out how your business prevents, detects and responds to modern slavery risks in your operations and supply chain. “Modern slavery” is an umbrella term covering practices like forced labour, human trafficking, debt bondage, servitude and child labour.
In the UK, the Modern Slavery Act 2015 (MSA) requires certain larger businesses to publish an annual modern slavery statement describing the steps they take to tackle these risks. Even where an annual statement isn’t legally required, a policy helps you:
- Set a consistent, documented approach to supplier due diligence and onboarding
- Train your team and define escalation routes for concerns
- Embed contractual protections and audit rights in your supplier agreements
- Record your risk assessment and remedial actions for future tenders or investor reviews
- Build trust with customers who expect ethical practices as standard
Think of it as part of your broader compliance toolkit alongside your Employment Contract, supplier terms and your Staff Handbook.
Do Small Businesses Legally Need A Modern Slavery Statement?
Under section 54 of the Modern Slavery Act 2015, only commercial organisations that carry on business in the UK and have a global turnover of £36 million or more must publish a modern slavery statement each financial year. The statement must be approved by the board (or equivalent) and signed by a director, and it should be published on your website with a prominent link from the homepage.
Most SMEs sit below the £36m threshold and don’t have to publish a statement. However, many small businesses are still asked for their policy or due diligence process by larger customers, public sector buyers and marketplaces as a condition of doing business. That’s why having a robust policy and consistent processes is important regardless of size.
If you source materials or services from higher-risk regions, work with labour-hire providers or overseas manufacturers, or operate in sectors with known risk indicators (e.g. apparel, hospitality, agriculture, construction, logistics), you should treat modern slavery controls as a priority, even if you’re well below the statutory threshold.
What Should A UK Modern Slavery Policy Include?
Your policy should be practical. Avoid lofty promises you can’t operationalise. At minimum, cover these elements in clear, plain English:
1) Purpose And Scope
Explain why the policy exists, who it applies to (employees, contractors, suppliers) and which parts of your business and supply chain are in scope.
2) Legal Framework
Refer to the Modern Slavery Act 2015 and, if relevant, other standards you align with (e.g. UN Guiding Principles on Business and Human Rights). Keep it simple.
3) Roles And Responsibilities
Specify who owns the policy (e.g. directors, compliance lead) and day-to-day responsibilities (e.g. procurement, HR). If you have a board, note approval and oversight responsibilities.
4) Risk Assessment
Describe how you identify and assess risk: geography, sector, product/service type, supplier size and reliance on migrant or temporary labour. Include how often you review risks.
5) Due Diligence On Suppliers
Set out your onboarding checks: questionnaires, verification of labour practices, right-to-work checks for labour providers, references, and any certifications. Explain how you classify risk and what additional steps you take for higher-risk suppliers (e.g. audits or third-party assessments).
6) Contractual Controls
State that you include anti-slavery warranties, ongoing compliance clauses, audit/inspection rights, and termination rights in your supplier contracts, such as your Supply Agreement or Goods & Services Agreement.
7) Training And Awareness
Outline induction training, refresher cycles, and who receives training (procurement, HR, managers, customer-facing teams).
8) Reporting Concerns And Whistleblowing
Provide clear channels for staff and suppliers to raise concerns, confidentiality assurances, and your commitment to non-retaliation. You might reference or align this with your Whistleblower Policy.
9) Remediation
Explain what you’ll do if you uncover issues: investigate, engage with the supplier, remediate harm where possible, and, if needed, suspend or terminate relationships. Be realistic about steps you can actually take.
10) Monitoring, KPIs And Review
Set out how you’ll measure effectiveness (e.g. % of suppliers risk-assessed, training completion rates), how often you review the policy and who signs off on changes.
How To Implement Your Policy In Practice
A policy is only useful if it’s put to work. Here’s a practical roll-out plan you can follow in your small business.
Step 1: Map Your Supply Chain
List your direct suppliers, labour providers and contractors. Note country of operation, sector, what they provide and contract value. For micro-businesses, a simple spreadsheet is fine.
Step 2: Classify Risk
Use basic risk factors to prioritise attention. Consider geography (higher-risk countries), sector (e.g. apparel manufacturing vs. professional services), and labour type (agency or seasonal labour). Focus early efforts where risk is highest.
Step 3: Update Contracts And Onboarding
Ensure your supplier terms contain anti-slavery warranties, audit rights and a right to terminate for breach. Build due diligence questions into your onboarding, and keep records of responses and follow-ups. Where you engage freelancers or agencies, align your contractor terms with the policy and your Employment Contract framework for in-house staff.
Step 4: Train The Right People
Give short, focused training to anyone who buys from, manages or visits suppliers; HR; and managers. Include how to spot red flags (confiscated documents, wages withheld, restricted movement) and how to escalate concerns.
Step 5: Create Clear Reporting Channels
Offer an email inbox or reporting line independent of procurement, and ensure anonymous reports are possible. Link this to your Whistleblower Policy so staff know they’re protected when speaking up.
Step 6: Monitor And Review
Set simple KPIs for year one (e.g. “100% of new suppliers screened”, “90% training completion”). Review annually, update your risk map and adjust controls as you grow.
Modern Slavery Policy Template (Word‑Ready Text)
Copy the text below straight into Word and tailor the placeholders and sections to reflect your business. Keep it short and actionable. If you don’t use a control in practice, remove it from the template.
Document Name: Modern Slavery Policy
Version: 1.0
Approved By:
Approval Date:
Next Review:
1. Purpose
is committed to preventing modern slavery and human trafficking in our business and supply chains. This policy sets out our approach to identifying, preventing and responding to modern slavery risks in line with the Modern Slavery Act 2015.
2. Scope
This policy applies to all employees, agency workers, contractors and suppliers who provide goods or services to in the UK and overseas.
3. Our Responsibilities
The directors are responsible for approving this policy and overseeing its implementation. Day-to-day responsibility sits with . Managers are responsible for ensuring their teams understand and apply this policy.
4. Risk Assessment
We assess modern slavery risks by considering supplier location, sector, the nature of goods/services, labour profile and spend. We review our risk assessment annually or when circumstances change.
5. Due Diligence
Before onboarding new suppliers, we conduct proportionate checks, which may include questionnaires, references, certification reviews and right-to-work checks for labour providers. Higher-risk suppliers may be subject to additional verification or audits.
6. Contractual Controls
Our contracts include obligations to comply with anti-slavery laws, provide information on request, allow audits or site visits where appropriate, and permit termination for breach of this policy or applicable laws.
7. Training And Awareness
We provide training to employees involved in procurement, HR and supplier management so they can identify risks and follow our procedures.
8. Reporting Concerns
If you have concerns or suspect modern slavery, report it immediately to . Reports can be made anonymously. Retaliation against anyone who raises a concern in good faith is prohibited.
9. Response And Remediation
We will investigate reported concerns promptly. Where issues are identified, we will seek to work with the supplier to remediate and prevent recurrence. We may suspend or terminate relationships where necessary.
10. Monitoring And Review
We monitor effectiveness through KPIs such as supplier screening rates and training completion. This policy is reviewed at least annually by and updated as needed.
11. Communication
This policy is available to all staff and suppliers. It is included in induction materials and supplier onboarding packs.
Approved by: ,
Signature: _____________________________
Date:
Note: If your turnover is at or above £36m, you must also prepare and publish an annual modern slavery statement in line with the Modern Slavery Act 2015 requirements. The statement is separate from this internal policy.
Embedding Your Policy Into Contracts And Everyday Processes
Once you’ve tailored your policy, make it real by aligning your legal documents and workflows. For suppliers, include anti-slavery clauses, audit rights, and cooperation duties in your Supply Agreement or Goods & Services Agreement. For staff, ensure obligations and reporting routes are reflected in your Staff Handbook and supported by your Employment Contract.
If you engage freelancers or off-payroll workers, apply comparable standards through your contractor terms and pay particular attention when overseas contractors form part of your supply chain. Ensure your onboarding questionnaire screens for modern slavery risks and that your team knows when to escalate a red flag.
Finally, keep tidy records of screening, decisions and any remediation steps you take. If a customer or regulator asks for evidence, you’ll want to show a clear paper trail.
Common Pitfalls To Avoid
It’s easy to draft a policy that looks good on paper but doesn’t change day-to-day behaviour. Watch out for these traps:
- Policy–practice gap: Promising audits you never carry out, or oversight roles that don’t exist in a small team. Tailor commitments to what you can actually do.
- One-off launch, no follow‑through: Announcing the policy but not integrating it into supplier onboarding, contract templates or staff training.
- Ignoring low-cost/high-risk suppliers: Focusing only on large vendors and overlooking small labour providers or subcontractors where risk may be higher.
- No reporting channel: Making it hard for staff or suppliers to raise concerns, or failing to protect whistleblowers from retaliation.
- Inconsistent employment practices: Failing to align your policy with wage, holiday and working time obligations under the Employment Rights Act 1996 and related laws.
FAQs: Quick Answers For Busy Owners
Do We Need A Policy If We’re Only Five People?
Yes. A short, practical policy helps you assess suppliers, train staff, and respond to questions from customers and investors. It doesn’t need to be long-start lean and evolve it as you grow.
Is This The Same As A Modern Slavery Statement?
No. Your policy is an internal control document. The modern slavery statement is a public, annual disclosure required only if you meet the £36m turnover threshold. Many SMEs still voluntarily publish a short statement or summary to demonstrate commitment to ethical practices.
Can We Use A Generic Template?
You can use a template as a starting point (like the one above), but avoid copying text that you won’t actually implement. Investors and large buyers increasingly ask for evidence-questionnaires completed, training logs, contract clauses used, site visit photos. Keep your policy aligned to your real processes.
What Clauses Should We Add To Supplier Contracts?
Include warranties that the supplier complies with all applicable anti-slavery laws, obligations to maintain records and cooperate with reasonable information requests, rights to conduct audits or site visits where appropriate, and a clear right to terminate for breach. We recommend weaving these into your master terms, like your Supply Agreement, so they apply across purchases.
How Often Should We Train Staff?
Give targeted training at induction for relevant roles (procurement, HR, site managers), then refresher training annually or when risks change-such as adding a new high-risk supplier category.
We Use A Labour-Hire Agency-Does This Apply?
Yes. Labour providers are a known risk area. Make sure your contracts include anti-slavery commitments, right-to-work checks, and that workers are paid properly and receive their documents. Align your internal policies with your Employment Contract standards to prevent gaps.
Key Takeaways
- Only organisations with turnover of £36m+ must publish an annual modern slavery statement, but SMEs still benefit from a short, practical policy to manage risk and satisfy customer due diligence.
- Cover the essentials: scope, responsibilities, risk assessment, supplier due diligence, contractual controls, training, reporting, remediation, and review.
- Make it real: embed clauses into your Supply Agreement or Goods & Services Agreement, align your Staff Handbook and Employment Contract, set simple KPIs and keep records.
- Use proportionate due diligence-focus on higher-risk suppliers, sectors and geographies, especially where you engage overseas contractors or labour providers.
- Provide safe reporting channels and protect whistleblowers-connect your policy to a clear Whistleblower Policy and a no-retaliation commitment.
- Avoid the policy–practice gap. Commit only to controls you can deliver, then review and improve annually as your business grows.
If you’d like help tailoring a modern slavery policy, building due diligence into your contracts, or sense-checking your rollout plan, you can reach us at 08081347754 or team@sprintlaw.co.uk for a free, no-obligations chat.
