The UK Modern Slavery Act 2015 is a key piece of legislation designed to combat modern slavery, human trafficking, and forced labour in business operations and supply chains. It applies to large businesses operating in the UK, requiring them to assess and report on the measures they take to eliminate modern slavery risks.
Failure to comply with the Modern Slavery Act can result in financial penalties, reputational damage, and legal action. This guide outlines who must comply, what the Act requires, and best practices for ensuring compliance.
What Is the UK Modern Slavery Act?
The Modern Slavery Act 2015 is a UK law aimed at preventing human trafficking, forced labour, and worker exploitation. It applies to businesses operating in the UK and mandates supply chain transparency to eliminate unethical labour practices.
The Act recognizes modern slavery as a serious human rights violation affecting an estimated 25 million people globally. Businesses are required to take proactive measures to ensure that forced labour or exploitative practices do not occur in their operations or supply chains.
For the full text of the legislation, visit the official UK government website:
Modern Slavery Act 2015 – Legislation.gov.uk
Who Must Comply with the UK Modern Slavery Act?
The Modern Slavery Act applies to:
- UK-based companies with an annual turnover of £36 million or more
- International companies that operate in the UK and meet the turnover threshold
Businesses meeting these criteria must publish an annual modern slavery statement outlining the steps taken to prevent modern slavery within their operations and supply chains.
What Are the Legal Requirements Under the Act?
1. Transparency in Supply Chains (TISC) Clause
Businesses must conduct due diligence to assess and eliminate modern slavery risks in their supply chains.
The annual modern slavery statement must include:
- A human trafficking statement confirming steps taken to prevent modern slavery
- A risk assessment of supply chains and operational risks
- Details of due diligence processes used to identify and address slavery-related risks
- Corrective actions implemented for any violations found
- Staff training initiatives on modern slavery prevention
Statements must be published on the company’s website within six months of the financial year-end.
2. Risk Assessments of Human Trafficking and Slavery
Businesses must review their global supply chains to identify high-risk industries and locations.
This includes:
- Conducting supply chain audits
- Identifying high-risk suppliers
- Ensuring ethical recruitment practices
- Monitoring compliance across all levels of the supply chain
3. Corrective Action Systems
If businesses identify modern slavery risks, they must implement corrective actions, including:
- Supplier contracts with zero-tolerance clauses for forced labour
- A whistleblowing policy that allows workers to report unethical practices
- Immediate contract termination for suppliers failing to meet compliance requirements
4. Supplier Audits and Noncompliance Checks
Businesses must conduct regular audits to ensure that suppliers comply with modern slavery regulations.
Audits should include:
- Independent on-site inspections
- Worker interviews and labour rights assessments
- Verification of working conditions and wages
Failure to identify and act on supplier noncompliance can result in legal repercussions and reputational damage.
5. Supplier Code of Conduct
Businesses must enforce a Supplier Code of Conduct, ensuring:
- Workers are employed voluntarily and fairly compensated
- Working conditions are safe and regulated
- Suppliers provide self-assessment reports on modern slavery risks
6. Due Diligence in Supply Chain Risk Management
Businesses must demonstrate proactive due diligence by:
- Implementing monitoring systems to track supply chain risks
- Using third-party verification tools to assess supplier compliance
- Enforcing penalties for suppliers failing to meet ethical labour standards
Proposed amendments to the Act suggest mandatory due diligence reporting, increasing accountability for large corporations.
Penalties for Noncompliance
Failure to meet Modern Slavery Act requirements can result in:
- Financial penalties for businesses failing to submit annual statements
- Reputational damage due to public scrutiny and media exposure
- Contract termination from ethical buyers, suppliers, and investors
- Potential criminal liability if companies are found to be complicit in modern slavery practices
Proposed amendments to the Act may introduce harsher financial penalties and legal consequences for noncompliance.
How Businesses Can Ensure Compliance
1. Publish an Annual Modern Slavery Statement
- Clearly document steps taken to eliminate forced labour
- Report due diligence efforts and risk assessments
- Ensure statements are updated annually and publicly available
2. Conduct Independent Supply Chain Audits
- Work with independent compliance auditors
- Perform random supplier inspections
- Collect worker testimonials to verify fair treatment
3. Train Employees on Modern Slavery Awareness
- Educate HR teams, recruiters, and procurement staff on ethical hiring
- Implement mandatory training on modern slavery indicators
- Provide confidential reporting mechanisms for employees to raise concerns
4. Strengthen Contracts with Suppliers
- Introduce zero-tolerance policies for forced labour
- Require suppliers to provide modern slavery compliance statements
- Implement penalty clauses for breaches of labour standards
5. Engage with Ethical Trade Organizations
- Collaborate with groups such as the Ethical Trading Initiative (ETI)
- Follow international guidelines, including ILO labour standards
- Support initiatives promoting fair wages and safe working conditions
Recent Developments and Proposed Amendments
The Modern Slavery (Amendment) Bill, introduced in 2021, aims to strengthen accountability and increase transparency. Key proposals include:
- Criminal penalties for falsifying modern slavery statements
- Banning suppliers that fail to meet minimum transparency standards
- Mandatory due diligence reporting for businesses operating in the UK
Additionally, the UK government’s 2024 report on modern slavery emphasizes:
- A victim-centred approach, separating immigration control from modern slavery protections
- Increased corporate accountability in supply chain risk management
As global regulatory frameworks evolve, businesses must remain proactive in modern slavery compliance to avoid legal and financial risks.
How Borderless Can Help Businesses Stay Compliant
Navigating modern slavery compliance can be complex. Borderless provides expert guidance to help businesses:
- Develop comprehensive modern slavery statements
- Conduct supply chain risk assessments
- Implement due diligence processes
- Ensure compliance with emerging UK and EU regulations
For expert assistance with modern slavery compliance and supply chain risk management, contact Borderless today.
Conclusion
The UK Modern Slavery Act 2015 is a crucial framework ensuring businesses take responsibility for eliminating forced labour and unethical recruitment practices. Companies must take proactive steps to remain compliant, including supply chain audits, annual reporting, and staff training.
For compliance solutions and supply chain due diligence support, speak to our experts today.
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