How to Write a Modern Slavery Statement: The 6 Areas

Knowing how to write a modern slavery statement matters the moment your group turnover reaches 36 million pounds, because section 54 of the Modern Slavery Act 2015 then requires one every financial year. The legal bar is famously low: the Act says you must publish a statement, and it permits a statement that says you have taken no steps at all. The commercial bar is much higher, because your customers' procurement teams read these, compare them, and score them.

This guide covers who is caught, the six areas the Act sets out, the approval and signature requirements, the publishing deadline, the government registry, and a section-by-section outline you can write against.

Who has to publish one

Section 54 catches an organisation that meets all of these tests: it is a body corporate or a partnership; it carries on a business, or part of a business, in the UK; it supplies goods or services; and it has an annual turnover of 36 million pounds or more.

Two points catch people out. Turnover is assessed on a group basis, including the turnover of subsidiaries, so a modest UK entity inside a large international group is usually in scope. And the test is applied afresh each year, so a business that grows past the threshold acquires the duty for that financial year, and one that falls below it can stop.

The six areas

The Act sets out six areas a statement may cover. In practice they have become the expected structure, and a statement that omits several without explaining why reads as a business that has not looked.

Organisation structure and supply chains. What the business does, where it operates, and what its supply chain actually looks like by tier and geography.
Policies on slavery and human trafficking. Which policies exist, who they bind, and how they connect to the supplier contract.
Due diligence processes. How suppliers are screened, audited and re-checked, and what happens when something is found.
Risk assessment and management. Where the risk actually sits, and how you concluded that rather than asserting it.
Key performance indicators. The measures you use to judge whether any of the above is working.
Training. Who receives modern slavery training, how often, and whether it reaches procurement and site management rather than only head office.

The section-by-section outline

1. Opening statement from the board

Short, signed, and specific to the year. Say what changed since the last statement. A paragraph that would read identically in any year of any company is the most common weakness in the whole document.

2. Structure, business and supply chains

Describe the operating model, then the supply chain in real terms: how many tier-one suppliers, in which countries, buying what. If you have no visibility beyond tier one, say so. An honest statement of limited visibility is more credible than an implied claim of full visibility, and it gives you something concrete to improve next year.

3. Policies

List the relevant policies and say what each one does: a modern slavery or human rights policy, a supplier code of conduct, a whistleblowing policy, recruitment and agency labour standards, and the procurement terms that carry them into contracts. If your code of conduct covers labour standards, cross-refer to it rather than repeating it, and make sure your whistleblowing route is genuinely reachable by agency and supplier workers rather than employees only.

4. Risk assessment

Set out the method, not just the conclusion. Which factors did you weigh: country, sector, labour model, use of agencies, seasonal peaks, base-skill work, subcontracting depth? Then name the parts of the business or supply chain you concluded are highest risk. Statements that assess risk as low across the board, with no explanation, are the ones that attract attention.

5. Due diligence

Describe what actually happens: pre-contract screening, self-assessment questionnaires, audits and who conducts them, unannounced visits, worker interviews, corrective action plans, and what triggers termination. Include the numbers you have. A statement that says audits took place is weaker than one that says how many, of whom, and what was found.

6. Effectiveness and KPIs

The area most statements handle worst, because effectiveness is genuinely hard to measure. Usable indicators include supply chain mapped beyond tier one, share of high-risk suppliers audited in the year, issues raised and closed, grievance reports received through channels open to supplier workers, training completion by role, and time to close corrective actions. Report the direction of travel against last year, even where it is bad.

7. Training

Say who is trained, how, and how often. Procurement, HR, site and operations management are the roles that matter, because they are the people who make the decisions that create risk. Board-only awareness sessions are not training.

8. Approval and signature

The statement must be approved by the board and signed by a director, or by a designated member in an LLP. Government guidance asks you to name the signatory, give their job title, and record the date of board approval. Put all three at the end of the document, not in a covering email.

Publishing it

Publish within six months of your financial year end, per government guidance. If your organisation has a website the statement must be on it, with a link in a prominent place on the homepage. That means a visible footer or policy link, not a page reachable only through search.

Also submit it to the government's modern slavery statement registry. Doing so is voluntary but encouraged, and anyone can search the registry to find statements. Because it is public, comparable and easy to search, a business missing from it stands out to exactly the clients and campaigners you would rather not attract.

What separates a strong statement from a compliant one

Four things, consistently. Specificity: named countries, named sectors, real numbers. Honesty about limits: saying where visibility stops. Year-on-year continuity: last year's commitments revisited and marked done or not done. And evidence of consequence: at least one example of something found and what was done about it. A statement that has never found anything, in a supply chain of any depth, is not reassuring.

The wider compliance framework this sits inside is covered in our guide to Modern Slavery Act compliance, and the governance context in what corporate compliance means. Everything else is on the E-Business Ethics homepage.

Frequently asked questions

Who has to publish a modern slavery statement?

Section 54 of the Modern Slavery Act 2015 applies to a body corporate or partnership that carries on a business in the UK, supplies goods or services, and has an annual turnover of 36 million pounds or more. Turnover is measured group-wide, so a small UK subsidiary of a large group is usually caught.

What are the six areas a modern slavery statement should cover?

Organisation structure and supply chains; policies on slavery and human trafficking; due diligence processes; risk assessment and management; key performance indicators measuring effectiveness; and training on modern slavery and trafficking. The Act suggests rather than mandates these six, but a statement that skips several without explanation looks thin.

Who signs a modern slavery statement?

It has to be approved by the board and signed by a director, or by a designated member for an LLP. Government guidance asks you to name the signatory, give their job title, and record the date the board approved it, so the approval is visible rather than implied.

When does a modern slavery statement have to be published?

Government guidance says publish within six months of your financial year end. The duty is annual, so you assess each year whether you still meet the criteria for the preceding financial year, and publish a fresh statement rather than leaving last year's up.

Is the government registry compulsory?

No. Submitting to the modern slavery statement registry is voluntary but encouraged, and anyone can search it. Because it is public and searchable, absence from it is increasingly noticed by clients and campaigners even though it is not a legal failure.

What happens if a business does not publish one?

The Act's enforcement route is a Secretary of State application for an injunction rather than a fine, which is rarely used. The practical consequences bite harder: procurement teams at larger customers routinely ask for the statement, and a missing or empty one costs contracts.

Sources

GOV.UK, publish an annual modern slavery statement, including the 36 million pound threshold, the six areas, signature requirements and the six-month deadline: gov.uk
Modern Slavery Act 2015, section 54, transparency in supply chains: legislation.gov.uk

Requirements checked against GOV.UK guidance on 24 August 2026. General information, not legal advice.