Guides / Supply chains and worker grievances
Modern slavery statement: what to include
Under section 54 of the UK Modern Slavery Act 2015, larger businesses must publish a statement for each financial year on the steps they have taken against slavery and human trafficking. This guide covers who must publish, the six areas the Act suggests, and how to show that workers can actually raise a concern.
This is general information about UK law, not legal advice. Other countries have their own supply chain reporting rules.
Who must publish a modern slavery statement
Section 54 applies to a commercial organization that supplies goods or services and has a total turnover of at least £36 million. "Commercial organization" means a company or partnership, wherever it was incorporated or formed, that carries on a business or part of a business in any part of the UK.
The organization must prepare a slavery and human trafficking statement for each financial year.
What the statement must be
The Act allows two kinds of statement:
- a statement of the steps the organization took during the financial year to ensure that slavery and human trafficking are not taking place in any of its supply chains or in any part of its own business; or
- a statement that it has taken no such steps.
For a company, the board of directors (or equivalent) must approve it and a director must sign it. Different signing rules apply to partnerships.
If the organization has a website, it must publish the statement there and put a link to it in a prominent place on the homepage. If it has no website, it must provide a copy to anyone who asks in writing, within 30 days of the request.
The government also runs a modern slavery statement registry where organizations can submit their statement.
The six areas section 54 suggests
The Act says a statement may include information about:
- the organization's structure, its business and its supply chains;
- its policies on slavery and human trafficking;
- its due diligence processes in its business and supply chains;
- the parts of its business and supply chains at risk, and the steps taken to assess and manage that risk;
- its effectiveness, measured against performance indicators it considers appropriate;
- the training about slavery and human trafficking available to its staff.
Show that workers can raise a concern
Due diligence and effectiveness are where many statements are thinnest. A policy says what should happen. Evidence that workers at your sites and suppliers can tell you when it doesn't is much stronger. Useful questions to answer in the statement:
- Which sites and supplier sites have a route workers can use, and does it bypass the supplier's management?
- Which languages can workers use?
- How many concerns came in, from where, and on what themes (for example recruitment fees, withheld documents, deductions, accommodation, overtime)?
- How quickly did someone reply, and what was done?
- What changed in your due diligence because of what workers told you?
Numbers like these make the effectiveness section concrete. Our guide to the UN criteria for grievance mechanisms sets out what a route for workers should be able to do.
Common weaknesses
- The same text every year, with only the date changed.
- Policies listed, but no evidence that anything was checked.
- A reporting channel that exists on paper and has never been used.
- Only first-tier suppliers considered, where the risk sits further down.
- Everything in English, for a workforce that mostly isn't.
Where Tellhaven fits
Tellhaven gives each site, including supplier sites, its own link or QR code that does not run through the supplier's management. Workers type or talk in their own language, your team replies in the same thread, and cases and exports give you the counts, themes and response times above. Tellhaven does not write your statement or decide what counts as due diligence. See Tellhaven for supply chains and multilingual worker reporting.