Section 54 of the UK's Modern Slavery Act 2015 only requires a statement from organisations with turnover of £36 million or more. Small suppliers are asked anyway, because their larger customers have to show they looked at their supply chains, and public buyers have to screen out suppliers linked to exploitation.
The good news: a proportionate answer is short, and most of it is describing what you already do. This guide is for UK contractors and suppliers below the threshold, or just above it. It covers what the law actually requires, what buyers ask, how to write a one-page policy built around the six areas the law suggests, how to check your own supply chain without a compliance department, what to do if something looks wrong, and how to answer the tender question so it scores.
It isn't legal advice. If you're near the threshold, part of a group, or dealing with a real concern, check with a competent adviser.
What the law requires, and of whom
The transparency duty in section 54 applies across the UK to a commercial organisation (a company or partnership) that:
- carries on a business, or part of a business, in the UK,
- supplies goods or services, and
- has a total annual turnover of at least £36 million, including the turnover of its subsidiaries.
An organisation in scope must publish a slavery and human trafficking statement for each financial year, setting out the steps it has taken to ensure slavery and human trafficking aren't taking place in its business or supply chains, or saying it has taken no such steps. A company's statement must be approved by the board and signed by a director. If the organisation has a website, the statement goes on it with a link in a prominent place on the homepage.
The Home Office runs an online modern slavery statement registry. Smaller organisations can submit a statement voluntarily, and buyers sometimes check it.
That's the full legal duty. Below £36 million, there's no statutory requirement to publish anything. But the offences themselves apply to everyone: holding someone in slavery or servitude, requiring forced or compulsory labour, and human trafficking are serious crimes regardless of your size.
Why small suppliers are asked anyway
Three pressures push the question down the supply chain:
- Your clients' statements cover you. A main contractor or facilities firm over the threshold has to describe due diligence on its supply chain. Asking you is part of that due diligence.
- Public procurement screens for it. Modern slavery offences are among the grounds on which public buyers must exclude suppliers, under both the old Public Contracts Regulations 2015 and the Procurement Act 2023. Government guidance also asks buyers to assess modern slavery risk in their contracts and include relevant questions and contract terms where the risk is higher.
- Construction and facilities services are seen as higher-risk sectors. Labour-intensive work, agency and labour-only subcontracting, multiple tiers of supply and imported materials all appear in the risk factors buyers are told to look at.
What buyers usually ask
- Do you have a policy on modern slavery and human trafficking?
- Are you required to publish a statement under section 54? If so, are you compliant?
- How do you assess risk in your own operations and supply chain?
- How do you check your suppliers, subcontractors and labour providers?
- Have you trained staff to recognise warning signs?
- What would you do if you found a problem? Have you ever found one?
Statement or policy: which do you need?
| Your situation | What to have | Notes |
|---|---|---|
| Turnover under £36m, no client asking | A short policy | Cheap to write, and you'll need it the first time a PQQ asks |
| Under £36m, clients or tenders asking | Policy, plus a short voluntary statement if clients want one | A voluntary statement is a good place to show your checks |
| £36m or more (including subsidiaries) | An annual statement meeting section 54, plus the policy behind it | Board approval, director signature, website link |
| Near the threshold, or in a group | Take advice on whether you're in scope | Group turnover counts; which entity publishes needs checking |
The policy says what you commit to and how you operate. A statement reports what you did in a particular year. For most small suppliers, a one-to-two page policy, backed by a log of checks, is the proportionate answer. If you publish a voluntary statement, it must be accurate. Overstating your controls is worse than saying little.
The six areas, in small-supplier terms
Section 54 lists six areas a statement may cover, and Home Office guidance encourages organisations to address all six. They're also the most sensible headings for a small supplier's policy, because they're what evaluators recognise.
| Area | What a small supplier writes | Illustrative example |
|---|---|---|
| 1. Organisation structure, business and supply chains | Who you are, what you do, where you work, what you buy and from whom | "A 40-person electrical contractor working in the South East. We buy cable, containment and fittings through UK wholesalers and use three labour agencies and around 15 subcontractors." |
| 2. Policies | The policies that touch on modern slavery | Modern slavery policy, whistleblowing, recruitment, subcontractor management, supplier code of conduct |
| 3. Due diligence | How you check the people you work with | Labour provider checks, subcontractor questionnaire, contract clauses, site induction checks |
| 4. Risk assessment and management | Where your risk is and what you do about it | Agency labour and labour-only subcontractors rated highest; extra checks on both |
| 5. Effectiveness and key performance indicators | How you know it's working | Share of labour providers checked this year, supervisors trained, concerns raised and closed |
| 6. Training | Who gets trained, on what, how often | Annual briefing for supervisors and office staff; warning signs in site inductions |
Keep the policy short, name the director responsible, give a way to raise concerns (including anonymously), sign and date it, and review it at least yearly.
Assess the risk in your own supply chain
You can't check everything with equal depth, and buyers don't expect you to. They expect you to know where your risk sits and to focus there. Start by listing what you buy and who supplies labour, then rate each group.
| Category | Why the risk can be higher | Typical rating for a contractor |
|---|---|---|
| Agency labour | Workers recruited by third parties, sometimes through further intermediaries; risk of fees, debt and controlled wages | High |
| Labour-only subcontractors and gangs | Payment through a gangmaster or gang leader, cash or shared accounts, little visibility of who the workers are | High |
| Cleaning, security, waste and facilities services | Low-margin, labour-intensive, often subcontracted further | Medium to high |
| Imported materials and products | Forced labour risk in raw materials and manufacturing overseas; commonly cited examples include some solar components, natural stone, electronics, timber, workwear and PPE | Medium, depending on product and origin |
| Specialist subcontractors with direct employees | Employed, skilled workforce, clearer employment relationships | Lower |
| Professional services, UK wholesalers of branded goods | Lower labour risk, although the products themselves may still carry upstream risk | Lower |
Two factors raise risk in any category: how many tiers sit between you and the worker, and how much the price depends on cheap labour. A labour quote far below what the work should cost is a warning in itself.
Record the result in a short risk register: category, supplier, rating, checks done, date, next review. That register is your evidence for areas 3, 4 and 5.
Practical due diligence for a small firm
Labour agencies
Before you use an agency, and again every year, check:
- The business is real. Companies House record, VAT number, a trading address, and how long it has traded.
- Workers aren't charged fees. In Great Britain, employment agencies and businesses are generally not allowed to charge work-seekers fees for finding them work. Ask the agency to confirm it in writing, and ask workers at induction.
- Pay is lawful and goes to the worker. At least the National Minimum Wage or National Living Wage for every hour worked, paid into the worker's own account. Ask for sample payslips, and be wary of large deductions for accommodation, transport, tools or training.
- Right to work checks are done. Find out who carries them out and ask to see that they're recorded.
- Accommodation and transport. If the agency provides them, ask how, at what cost, and whether workers can opt out.
- Licensing, where it applies. Labour providers in agriculture, horticulture, shellfish gathering and related food processing and packaging need a licence from the Gangmasters and Labour Abuse Authority. Construction labour providers generally don't, so don't assume "licensed" means anything for your agency; the checks above matter more.
Subcontractors
- Include modern slavery questions in your subcontractor prequalification: policy, how they recruit, whether they use agencies, how workers are paid.
- Put a clause in the subcontract requiring compliance with the Act, flow-down to their own suppliers, cooperation with checks, and notification of any concern.
- For labour-only subcontractors, ask for the names of workers in advance and check them against who actually turns up.
Collecting this at onboarding is far easier than chasing it later; see Subcontractor onboarding: the documents to collect on day one.
Materials and products
You won't trace every component, and evaluators don't expect it. Proportionate steps:
- Ask your main suppliers for their own modern slavery statement or policy. Most large wholesalers and manufacturers publish one.
- Ask about country of origin for higher-risk products you buy in volume or import directly.
- Prefer recognised responsible sourcing schemes where they exist, such as certified timber or construction products certified to a responsible sourcing standard, while being clear they're not a guarantee.
- Record what you asked and what you were told. The record is the evidence.
On site
Site induction is where small contractors have the best view of the workforce. Simple checks that reveal a lot:
- the person on site matches the ID and the name on the agency or subcontractor list,
- several workers giving the same address, phone number or bank account,
- one person answering for others, or holding their documents.
Training: short, regular, practical
Most small firms don't need formal courses. A ten-to-fifteen-minute briefing, repeated annually and added to inductions, covers it:
- Who: supervisors, site managers, office staff who handle payroll and onboarding, and anyone who books agency labour.
- What: what modern slavery and labour exploitation look like, the warning signs below, and exactly what to do if they see them.
- Record it: date, attendees, content. A toolbox talk register is fine.
Free resources from industry bodies, such as the Supply Chain Sustainability School and the Stronger Together programme, can save you writing the material yourself.
Red flags to brief your people on
- Workers who don't hold their own passports or ID, or whose documents are held by someone else.
- Wages paid to someone else, or into a shared account; workers who don't know what they're paid.
- Workers transported together to and from site, early and late, and seemingly unable to leave.
- Workers who seem afraid, are not allowed to speak for themselves, or are always accompanied.
- Signs of debt: owing money for travel, recruitment, accommodation or tools.
- Many workers living at one address, often provided by the person who supplies them.
- Unsuitable clothing or no PPE, injuries left untreated, signs of exhaustion or malnourishment.
- Prices that are only possible if someone isn't being paid properly.
One sign alone doesn't prove exploitation. Several together are a reason to act.
What to do if you find a concern
- If someone is in immediate danger, call 999.
- Don't confront the suspected exploiter or remove workers from site in a way that tips them off. It can put the workers at greater risk.
- Get advice and report. The Modern Slavery and Exploitation Helpline (08000 121 700) takes calls from businesses and the public, and can advise on next steps. Non-urgent concerns can also go to the police on 101.
- Record what you saw, when, and who you told. Keep it factual.
- Tell your client if your contract requires it, and review the supplier relationship. Buyers generally prefer remediation, such as fixing pay practices, over walking away and leaving workers worse off, but take advice where the facts are serious.
Put this procedure in your policy. "What would you do if you found a problem?" is one of the most common tender questions, and a clear, specific procedure scores well.
Answering the tender question
Answer the question asked, attach the policy, and give one concrete example of a check you carried out. Specific beats aspirational every time an evaluator is scoring. A structure you can adapt:
Policy and responsibility. We have a modern slavery and human trafficking policy, approved by [director name, role] and last reviewed on [date] (attached). We are not required to publish a statement under section 54 of the Modern Slavery Act 2015, as our turnover is below £36m.
Where our risk is. Our main risks are [agency labour and labour-only subcontractors], followed by [imported products such as X]. We hold a risk register and review it [annually].
What we check. Before using any labour provider we confirm [no worker fees, pay at or above the National Minimum Wage into workers' own accounts, right to work checks], and repeat this [annually]. Subcontractors complete our prequalification questions and sign a contract clause on modern slavery. At induction we check [ID against booking lists and for shared bank accounts or addresses].
Example. In [year] we reviewed our [three] labour agencies. [One] could not provide sample payslips, and we [stopped using them / required changes before further bookings].
Training. [All supervisors and office staff] received a briefing on warning signs in [month, year], and modern slavery is covered in every site induction.
If we find a concern. [Our procedure, including reporting to the helpline or police and notifying the client.]
Replace every bracket with what's true. If you can't fill one honestly, leave that sentence out.
Common mistakes that lose marks
- Copying a large company's statement. Board committees and global audit programmes that you don't have are obvious to an evaluator.
- "We have a zero-tolerance approach" and nothing else. Commitment without process scores poorly.
- Saying you're "not in scope" as the whole answer. True, but the question is about what you do, not what you're obliged to do.
- Assuming "licensed" covers construction agencies, or that a supplier's policy proves its practice.
- No evidence of checks. A risk register and a log of dated checks are what make an answer credible.
- An undated, unsigned or out-of-date policy, or one naming a director who has left.
Similar laws elsewhere
If you work for clients outside the UK, you may meet similar questions. Australia's Modern Slavery Act 2018 requires entities with annual consolidated revenue of at least AUD 100 million to report. Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act, in force since January 2024, requires annual reports from larger entities and government institutions. Both work like section 54: large organisations report, and their suppliers get the questions. The same policy, risk register and log of checks will answer most of them.
Start here
- This month: write a one-page policy under the six headings, have a director sign it, and file it in your evidence library.
- Next: list your labour providers and subcontractors, rate them, and check the highest-risk ones using the steps above. Log what you found.
- At the next toolbox talk: brief supervisors on the red flags and the reporting procedure, and record attendance.
- Once a year: review the policy, repeat the agency checks and update the register.
You don't need a glossy report. You need to show you know where the risk is and what you do about it.