Module 2
 

Modern slavery statements for companies in scope of the Modern Slavery Act

 

An introduction to the Modern Slavery Act

The Modern Slavery Act 2015 is a landmark piece of legislation designed to combat slavery, servitude, forced or compulsory labour, and human trafficking in the UK. It consolidates previous offences into a single framework and strengthens the tools available to law enforcement, businesses, and civil society to identify and address modern slavery.

For businesses, the Act introduced a transparency in supply chains provision (Section 54). This requires commercial organisations that supply goods or services, carry on business in the UK, and have a global annual turnover of £36 million or more to publish an annual modern slavery statement.

This statement must outline the steps taken to ensure that slavery and human trafficking are not taking place in the organisation's own operations or supply chains in any part of its business.

In line with Section 54(6) of the Modern Slavery Act, the statement must:

  • Be approved by the board (or equivalent governing body).
  • Be signed by a director (or equivalent, such as a partner or LLP member).
  • Be published on the organisation’s website with a clear and prominent link from the homepage.

Key features of the Act

  • Creation of an Independent Anti-Slavery Commissioner to improve coordination and accountability.
  • Stronger penalties for perpetrators, including life sentences.
  • Powers for law enforcement to intervene in maritime trafficking.
  • Support and protection for victims, including legal aid and child trafficking advocates.

For Suppliers

This legislation highlights the importance of proactively managing modern slavery risks within your own organisation and supply chain.

This includes:

  • conducting appropriate due diligence on your suppliers and labour providers
  • identifying and managing potential risks
  • ensuring your policies and processes reflect responsible business practices
  • being transparent about the steps you are taking.

What should a Modern Slavery Statement include?

Per Section 54(5) of the Modern Slavery Act, a Modern Slavery Statement may include information relating to:

  • The organisation’s structure, business and supply chains.
  • Policies relating to modern slavery and human trafficking.
  • Due diligence processes.
  • Risk assessment and management.
  • Measures used to assess effectiveness (e.g. KPIs).
  • Training provided to staff and relevant stakeholders.

These elements help organisations provide a clear and transparent view of how they are identifying and addressing modern slavery risks.

Statements should be clear, accurate and evidence-based, and should not overstate the actions taken by the organisation.

Understanding and applying the principles of the Modern Slavery Act is essential to protecting vulnerable individuals, maintaining ethical supply chains, and upholding Lloyds Banking Group’s commitment to responsible business.

 

Not in scope of the Modern Slavery Act?

Organisations with a turnover below £36 million are not legally required to publish a modern slavery statement. However, modern slavery risks can still exist in any organisation or supply chain, regardless of size.

Taking steps to understand and manage these risks is considered good practice and helps demonstrate your commitment to responsible business.

This might include:

  • reviewing your supply chain and identifying areas of higher risk
  • putting simple policies or expectations in place
  • being clear on how concerns can be raised and escalated.

For more detail on modern slavery statements and recommended approaches, see Section 5 of the Home Office Transparency in Supply Chains guidance.


Test your knowledge

1. What is the primary purpose of a modern slavery statement under the UK Modern Slavery Act 2015?

 

A) To report financial performance

B) To set out the steps an organisation has taken to prevent modern slavery in its business and supply chains

C) To describe employee benefits

D) To outline marketing strategies


The correct answer is: B) To set out the steps an organisation has taken to prevent modern slavery in its business and supply chains 
 

The Modern Slavery Act 2015 requires certain organisations to publish a statement outlining steps taken to prevent modern slavery in their operations and supply chains. 

The statement is not about financials, marketing, or benefits, but about transparency and anti-slavery measures. 



2. What is the minimum turnover threshold for a commercial organisation to be required to publish a modern slavery statement under the UK Act?

 

A) >£100 million 

B) >£50 million

C) >£36 million


The correct answer is: C) >£36 million
 

The Modern Slavery Act applies to organisations with a turnover of £36 million or more. You might have suppliers who are not in scope of the Modern Slavery Act, but should still ask them about how they manage risk related to modern slavery. 



3. Which of the following is NOT a recommended section to include in a modern slavery statement according to Home Office guidance?

 

A) Policies in relation to slavery and human trafficking 

B) Due diligence processes

C) Shareholder dividend policy

D) Organisation structure and supply chains


The correct answer is: C) Shareholder dividend policy
 

Home Office guidance suggests including sections on structure, policies, due diligence, risk assessment, effectiveness and training. Shareholder dividend policy is unrelated to modern slavery compliance.



4. True or false? A modern slavery statement must be signed by a director and approved by the board (for companies).

 

A) True 

B) False


The correct answer is: A) True 
 

The Modern Slavery Act requires board approval and a director's signature for company statements. This ensures accountability at the highest level. This is one of the four requirements which makes the modern slavery statement legally compliant. 



5. Which of the following is a key area that should be addressed in a modern slavery statement?

 

A) Annual profit forecasts

B) Shareholder meeting minutes

C) Advertising campaigns

D) Risk assessment and management


The correct answer is: D) Risk assessment and management 
 

Risk assessment involves identifying where modern slavery risks are most likely to occur across your operations and supply chain and prioritising action. This may include sector risks, geographic risks, and reliance on third-party labour. Effective management includes ongoing monitoring, supplier engagement, and targeted due diligence.



6. True or false? A modern slavery statement must be published on the organisation’s website with a prominent link on the homepage.

 

A) True

B) False


The correct answer is: A) True 
 

The Act requires statements to be published on the website with a prominent homepage link. This is one of the four requirements which makes the modern slavery statement legally compliant. The requirements are: 

  • Approval by the board of directors
  • Signature by a director
  • Publication on the company’s website
  • A prominent link to the statement on the homepage



7. Which of the following best describes 'due diligence processes' in the context of a modern slavery statement?

 

A) Processes for hiring new employees

B) Procedures to identify, prevent and mitigate modern slavery risks

C) Techniques for product development

D) Methods for increasing sales


The correct answer is: B) Procedures to identify, prevent and mitigate modern slavery risks 
 

Due diligence refers to the practical steps taken to identify, prevent and mitigate modern slavery risks. This can include supplier onboarding checks, audits, reviewing recruitment practices, and ensuring suppliers meet labour standards. It should be an ongoing, risk-based process.



8. True or false? A company only needs to report on its UK operations to comply with the UK Modern Slavery Act.

 

A) True

B) False


The correct answer is: B) False
 

The requirement to publish a modern slavery statement extends to the entire organisation, including its subsidiaries and operations outside the UK. This means that if a business has operations outside of the UK, the company must ensure that all parts of its business, including those operating internationally, comply with the Act.

How did you do? 

In this module, you built your understanding of the Modern Slavery Act and what it means for organisations and their supply chains.

You learned that:

  • organisations meeting the threshold must publish a modern slavery statement each year
  • a strong statement goes beyond compliance and clearly sets out how risks are identified, managed, and monitored
  • transparency, governance, and leadership accountability are key to demonstrating a credible approach.

You also explored how these expectations apply in practice. Even where organisations are not in scope of the Act, taking a structured and proactive approach remains important. As a supplier, your statement reflects not only your processes, but your commitment to protecting people across your operations and supply chain.

In the next module, you'll learn how to construct a strong and legally compliant modern slavery statement by choosing the best content for each section.

 

Move on to module 3


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