Editor’s Note
This article examines the enduring global crisis of modern slavery, which affects an estimated 49.6 million people. It highlights the direct relevance to UK consumers and businesses, as complex international supply chains can obscure forced labour practices. The piece underscores the critical role of legislation, like the Modern Slavery Act, in driving transparency and accountability.
According to estimates by the International Labour Organization, 49.6 million people around the world are in a form of modern slavery, with 27.6 million (including 3.3 million children) in forced labour.
This is not merely of academic interest in the UK. The globalisation of the economy means that goods and services bought here may have a long and tangled supply chain encompassing multiple countries, including countries where bonded or forced labour is common. Modern slavery exists in the UK too and can involve UK citizens, as well as foreign nationals.
Under the Modern Slavery Act 2015 (MSA), the term “modern slavery” is used to cover both offences in the MSA (slavery, servitude and forced or compulsory labour) and human trafficking.
The MSA addresses the issue of modern slavery in a number of ways, including consolidating offences for slavery and human trafficking and establishing an Independent Anti-Slavery Commissioner. But for employers the pertinent requirement is section 54, which requires large businesses to publish an annual slavery and human trafficking statement.
The statement must set out the steps the organisation has taken to ensure slavery and human trafficking is not taking place in its supply chain or its own business (or it must state that it has not taken any steps). The statement must be approved by senior management and published on the organisation’s website.
In March 2025, the government published updated statutory Guidance on transparency in supply chains (Transparency in supply chains (TISC) – statutory guidance) which is designed to provide practical assistance for organisations to comply with their obligations.
Although there is no definition of “supply chain” in the MSA, the updated Guidance clarifies that the term should be interpreted broadly to encompass both the primary value chain (the goods and services an organisation sells or delivers) and the secondary value chain (supporting activities such as HR, catering, and cleaning), as well as the labour supply chain (how and from where workers are recruited at all stages). The Guidance emphasises that organisations should seek to map and understand their supply chains as fully as possible, including both direct (“tier 1”) and indirect (“tier 2”) suppliers, and to improve transparency year-on-year.
The government encourages all organisations to develop an “appropriate and effective response” to modern slavery, to go beyond the minimum legal requirements (including participating in the voluntary government-run modern slavery statement registry), and to be transparent about their actions.
Under section 54, “commercial organisations” (meaning companies and partnerships, wherever formed or incorporated) must publish a statement if they supply goods or services and have an annual turnover over a minimum threshold – currently set at £36 million. The organisation must be carrying on all or part of its business in the UK to be caught, but the relevant turnover is global turnover, and includes the turnover of any subsidiaries as well as the organisation itself. Even if an organisation pursues primarily charitable or educational aims or purely public functions, provided it engages in commercial activities and meets the minimum threshold, it will have to produce a statement.
If any organisation in any part of a group structure meets these requirements, it is legally required to produce a statement.