UK Modern Slavery Act

The UK Modern Slavery Act has been in effect since 2015 and was the first legislation of its kind globally. The Act aims to tackle modern slavery and human trafficking, including servitude and forced or compulsory labour. 

Section 54 of the Act – the Transparency in Supply Chains provision – applies to businesses. It mandates that entities meeting specified criteria publish an annual statement outlining the measures they take to prevent and address the risk of modern slavery in their operations and supply chains. 

The UK government has created a modern slavery statement registry where companies are encouraged to upload their statements, allowing the public to easily find and assess them. 

Who must comply? 

All UK-registered businesses must comply if the business meets all of the following criteria: 

• Have an annual turnover over £36 million 
• Are a corporate business or a partnership, wherever incorporated or formed 
• It carries on a business, or part of a business, in the UK 
• Provides goods or services 

What are the requirements? 

Companies in scope must ensure that they meet the following list of requirements: 

Publish an annual modern slavery statement on their website, which: 

• Is easily visible and accessible from their homepage 
• Explains the steps the company has taken during the financial year to ensure that slavery and human trafficking are not taking place in its operations or supply chains 
• Outlines the company and supply chain structure, relevant policies, and due diligence processes in place to prevent or address modern slavery 
• Highlights the areas of highest risk and the steps taken to address them 
• Explains how the effectiveness of actions is measured, and describes training provided to staff on modern slavery 

Ensure the statement is: 

• Approved by the board of directors (or equivalent management body) 
• Signed by a director or a designated member 
• Updated and published annually, within six months of the company’s financial year end 

Consequences for non-compliance

 If companies that are required to comply with the Act fail to do so, the UK government may seek a court injunction to enforce compliance. Failure to comply with such an order could then result in unlimited fines. 

As of April 2025, there are no direct criminal penalties for non-compliance with the Act. However, businesses that fail to comply may face public scrutiny and reputational damage. 

New guidance issued by the UK government 

In March 2025, the UK government issued new guidance for businesses on how to comply with the Act. Developed through consultation with businesses, public bodies, civil society organisations, trade unions, and academics, this guidance builds on a decade of learning since the Act has been in effect. 

The updated guidance replaces all previous versions and focuses on helping organisations produce high-quality modern slavery statements and develop effective approaches to tackling modern slavery in their operations and supply chains. It does this by providing advice on ‘good’ and ‘best’ practice in key areas, to support businesses as they progress and build their knowledge and capacity on the topic.  

Best practice: Be transparent about risks, rather than reporting the absence of them 

The guidance emphasises that, given the global prevalence of modern slavery, statements claiming they found no risks or instances are likely to reflect inadequate assessment. Best practice is to be transparent about the risks identified and how the organisation has addressed them, rather than asserting their absence. 

Importantly, the new guidance shifts the focus from reporting and compliance to meaningful support for victims of modern slavery. For businesses, this means prioritising effective prevention and remediation. Key practices highlighted include: 

• Fair purchasing practices 
• Responsible recruitment 
• Acknowledging the limitations of social audits 

The guidance includes practical and detailed recommendations, case studies, existing industry tools, and detailed expectations for each section of a modern slavery statement. Importantly, it places strong emphasis on remedies for victims and continuous improvement by businesses. 

How Anthesis can help

 Anthesis supports businesses across all areas of human rights and modern slavery due diligence: from the creation of strategy and direction towards human rights due diligence to human rights impact assessments, remedy and reporting.  

Using our in-house experts and tools, we can identify and rank where the key human rights and salient risks are located within your business or value chain, based on geography, industry, and type of product or service. Our team’s diverse background and language capabilities mean we are also able to carry out on-the-ground research and engage directly with rightsholders in many countries around the world.   

For more information on how to identify if your organisation needs to publish a modern slavery statement or guidance on how to mitigate modern slavery risks, contact us. 

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