Modern slavery remains a significant issue both in the UK and worldwide, but it can be difficult to detect because it often sits deep within complex, multi-tier supply chains. Procurement teams are therefore in a particularly important position to identify risks, assess suppliers and build appropriate controls into sourcing and contract management, helping organisations build more resilient and ethical supply chains.
However, tackling modern slavery from a procurement perspective requires more than just a modern slavery statement or supplier questionnaire; organisations need to embed appropriate processes and controls throughout the procurement lifecycle. For businesses looking to strengthen their approach, wider procurement transformation can help integrate governance, processes, data and technology into a more effective procurement function.
Below, we explain precisely what modern slavery is, why it’s a procurement issue, and how to redesign procurement policies and processes to ensure transparency and compliance throughout your supply chain.
What is modern slavery?
Modern slavery is an umbrella term covering severe forms of exploitation where a person is deprived of their freedom and exploited by another person. It includes slavery, servitude, forced or compulsory labour and human trafficking.
In a 2022 report, the International Labour Organization estimated that 50 million people were living in modern slavery in 2021, comprising approximately 28 million people in forced labour and 22 million in forced marriage. Unfortunately, these figures represent a steep rise in modern slavery worldwide, with 10 million more people in modern slavery in 2021 compared to 2016 global estimates.
Modern slavery can occur in almost any sector and across many different industries, geographies and tiers of suppliers. Plus, the nature of modern slavery also means that it can be difficult to identify. Exploitation may occur several tiers away from the organisation purchasing the goods or services, particularly where supply chains involve multiple suppliers, subcontractors, labour providers or informal businesses. For procurement teams, this makes visibility and risk management particularly important.
Why is modern slavery a procurement issue?
Procurement has a direct influence over who organisations buy from, the requirements suppliers must meet and the contractual arrangements governing those relationships. This means procurement professionals can influence modern slavery risk at several stages, including:
- Identifying high-risk categories and supply chains
- Assessing suppliers before entering into agreements
- Incorporating appropriate requirements into tender processes
- Establishing contractual obligations
- Monitoring supplier performance
- Responding to concerns or evidence of exploitation
- Working with suppliers to improve practices and reduce risk
Modern slavery should therefore not be treated as a standalone compliance exercise. Instead, it should be part of wider supply chain risk management and responsible procurement.
In addition, a supplier having a modern slavery policy does not, by itself, demonstrate that exploitation is not taking place. Effective procurement requires organisations to consider the risks associated with particular categories, suppliers and supply chains and apply appropriate due diligence over the entire contract lifecycle, not just the initial agreement.
The key implications of modern slavery for procurement
Modern slavery creates several important considerations for procurement teams, and the appropriate response will depend on an organisation’s sector, supply chain structure, geography and exposure to particular risks:
Supply chain visibility
One of the biggest challenges is understanding what happens beyond an organisation’s immediate suppliers. A business may have a direct contractual relationship with a large, established supplier, whilst also relying on subcontractors, manufacturers, labour providers and raw material suppliers further down the chain. Therefore, modern slavery risks may exist beyond the organisation’s first-tier supplier relationships.
Procurement teams should consider whether they have sufficient visibility of relevant parts of the supply chain to assess risk effectively. For higher-risk categories, this may require more detailed supply chain mapping and information from suppliers and subcontractors.
Supplier due diligence
Supplier due diligence should form an important part of modern slavery risk management. Depending on the circumstances, this may include assessing:
- The supplier’s modern slavery statement or relevant policies
- Recruitment and employment practices
- Use of temporary or migrant labour
- Subcontracting arrangements
- Supply chain transparency
- Previous incidents or concerns
- The supplier’s approach to identifying and managing modern slavery risks
It’s important to remember that a proportionate, risk-based approach is generally more effective than applying exactly the same checks to every supplier. A low-risk office-based service and a complex international manufacturing supply chain may require very different levels of scrutiny, with the latter requiring assessment across many or all of the parameters outlined above.
Contract management
As touched on earlier, modern slavery risk doesn’t disappear when a supplier has been selected and a contract has been signed. Instead, procurement and contract management teams should consider how relevant requirements will be monitored throughout the relationship, including contractual obligations, reporting requirements, supplier reviews and escalation procedures where concerns arise.
For higher-risk relationships (such as with larger suppliers relying on subcontractors and labour providers internationally), organisations may also need to consider whether additional information or enhanced due diligence is appropriate during the contract lifecycle. This makes effective contract management an important part of ongoing supply chain risk management.
Reputational and commercial risk
Modern slavery can have serious consequences beyond the direct harm caused to workers. Organisations may face reputational damage, disruption to supply, contractual issues, legal consequences and loss of stakeholder confidence if serious exploitation is identified within their supply chains and they cannot demonstrate an appropriate response. For procurement leaders, this reinforces the importance of treating modern slavery as part of wider commercial and supply chain risk rather than as a separate social responsibility issue.
What does the Modern Slavery Act mean for procurement?
The Modern Slavery Act 2015 introduced the UK’s Transparency in Supply Chains provisions. Under Section 54, commercial organisations that carry on business in the UK, supply goods or services and have an annual turnover of £36 million or more are required to publish a modern slavery statement for each financial year.
The statement must set out the steps the organisation has taken to prevent modern slavery and address the risk of it occurring in its own operations and supply chains. It doesn’t mean an organisation has to guarantee that its entire supply chain is free from modern slavery, but it must explain the steps it has taken to address this risk.
Although the legal reporting requirement applies to qualifying commercial organisations rather than procurement teams specifically, procurement can play a significant role in supporting an organisation’s approach. This is because procurement teams may hold important information about suppliers and subcontractors, sourcing decisions, supplier due diligence, contractual requirements, risk assessments, remediation activity and more. Therefore, a credible modern slavery approach requires collaboration between procurement, legal, sustainability, operations and other relevant teams across an organisation.
It’s also worth noting that organisations below the £36 million threshold are not required to publish a statement under Section 54, although the government encourages organisations outside the scope of the legislation to take proportionate steps to address modern slavery risks. This is why smaller suppliers may also be asked to provide evidence of their modern slavery approach by larger customers.
Modern slavery and public procurement
Modern slavery is particularly relevant to public procurement because public bodies have significant purchasing power and can use procurement processes to identify and manage supply chain risks.
The Procurement Act 2023 and Procurement Regulations 2024 apply to procurements commenced on or after 24 February 2025. PPN 009, which replaced PPN 02/23 for relevant new procurements, sets out how in-scope central government and NHS organisations should identify and manage modern slavery risks in both new procurement activity and existing contracts.
The current guidance includes several measures relevant to procurement professionals. For new procurements considered to have a high risk of modern slavery, supply chain information must be provided. The guidance also includes enhanced due diligence and explains how existing supplier exclusion grounds can be used more effectively.
The Procurement Act also contains mandatory and discretionary supplier exclusion grounds relating to certain forms of labour market misconduct and modern slavery. In particular, there are mandatory exclusion grounds for certain modern slavery offences where a supplier or connected person has been convicted, while a discretionary exclusion ground can apply where there is sufficient evidence that a supplier or connected person has engaged in conduct that would, if it occurred in the UK, constitute certain modern slavery or human trafficking offences, even without a conviction.
This demonstrates an important shift in the role procurement can play: modern slavery considerations can form part of supplier selection, due diligence, contract management and wider commercial decision-making.
What should a modern slavery procurement policy cover?
A modern slavery procurement policy can help organisations translate broader ESG commitments into practical procurement processes. The exact approach will depend on the organisation and its supply chain, but a policy could establish:
- Who is responsible for managing modern slavery risks
- How suppliers and categories are assessed
- When enhanced due diligence is required
- How modern slavery is considered during sourcing and tendering
- What suppliers are expected to provide
- How requirements are incorporated into contracts
- How supplier performance and risk are monitored
- What happens when concerns are identified
- How potential incidents are escalated
- What training procurement and commercial teams receive
- How the organisation reviews and improves its approach
Ultimately, a modern slavery procurement policy should provide a framework rather than become a box-ticking exercise. Its effectiveness will depend on whether its requirements are embedded into day-to-day sourcing, supplier management and contract processes – or treated as an afterthought.
How can procurement teams tackle modern slavery?
There’s no single procurement process that can address all modern slavery risks within a complex supply chain. However, organisations need to take a structured, risk-based approach to minimise harm and adhere to their ESG goals. Here are the necessary steps towards embedding appropriate measures against modern slavery within an organisation’s supply chain:
1) Identify high-risk categories and suppliers
The first step is understanding where the greatest risks may exist. Factors such as labour intensity, geographical location, recruitment practices, use of temporary or migrant labour, subcontracting and the complexity of the supply chain can all influence risk.
Identifying these categories allows procurement teams to focus resources where they’re likely to have the greatest impact rather than applying disproportionate checks to every supplier.
2) Improve supply chain visibility
Procurement teams should establish what they know about relevant tiers of the supply chain and identify where information is missing. This can be particularly important where suppliers rely heavily on subcontractors or where products pass through multiple stages before reaching the organisation.
Greater visibility doesn’t necessarily mean mapping every supplier in every supply chain. Instead, a proportionate approach can prioritise areas where the potential risk is highest.
3) Build modern slavery into supplier due diligence
Modern slavery should be considered as part of wider supplier assessment rather than as a completely separate exercise. Depending on risk, procurement teams might review supplier policies, statements, recruitment practices, subcontracting arrangements and previous incidents. Suppliers that have been identified as higher risk may then require enhanced due diligence and additional evidence.
Overall, the objective should be to understand how a supplier manages the risk in practice, rather than simply confirming that a policy exists.
4) Include appropriate requirements in tenders and contracts
Modern slavery expectations should be established early in the procurement process. Relevant tender requirements can help organisations assess supplier capability before a contract is awarded, and contractual provisions can then establish ongoing obligations once the relationship begins.
The requirements should be proportionate to the contract and the risks involved. Overly broad or generic requirements can create unnecessary administrative work without necessarily improving risk management.
5) Monitor suppliers throughout the contract
Changes to suppliers, subcontractors, sourcing locations, labour arrangements or wider market conditions can create new risks even after a contract has been awarded. Procurement and contract management teams should therefore consider how relevant risks will be monitored throughout the relationship, rather than just at the beginning.
Regular supplier reviews can provide an opportunity to discuss performance, investigate concerns and identify areas for improvement.
6) Train procurement and commercial teams
Policies and contractual requirements are only effective when the people responsible for applying them understand what they mean. Procurement professionals should know how to recognise potential warning signs, when further investigation may be appropriate and what procedures to follow if concerns are identified. Training can also help teams understand the difference between proportionate due diligence and a purely compliance-driven approach.
7) Focus on remediation, not simply exclusion
Removing a supplier from a supply chain may sometimes be necessary, particularly where serious wrongdoing has been identified. However, exclusion is not always the only or most effective response.
In some circumstances, abruptly ending a relationship can push vulnerable workers or problematic practices further away from view. Organisations should therefore consider whether remediation, supplier engagement or other corrective action can address the underlying issue, where appropriate and safe to do so.
For public procurement, any decision around supplier exclusion must of course follow the relevant legal and regulatory framework. Current government guidance provides specific information on mandatory and discretionary exclusion grounds under the Procurement Act 2023.
How technology can support modern slavery risk management
Technology cannot identify every instance of modern slavery, but it can give procurement teams greater visibility and control over the processes used to manage supply chain risk. For example, digital procurement systems can centralise supplier information, conduct spend analysis, standardise workflows, support risk assessments and supplier performance monitoring, and provide greater visibility of contracts and procurement activity. Data and analytics can also help teams identify areas that warrant further investigation, which can be particularly valuable in larger organisations where procurement information is spread across multiple systems or business units.
Barkers’ Digital Procurement service uses e-procurement platforms, automated workflows and data analytics to improve visibility, supplier management and procurement processes. The objective is not to replace human judgement, but to give procurement teams better information and more consistent processes on which to base decisions.
Building a more effective approach to modern slavery in procurement
Modern slavery is too complex to be addressed through a single policy, annual statement or supplier questionnaire. Effective modern slavery risk management requires procurement teams to consider the issue throughout the procurement lifecycle, from category strategy and supplier selection through to contract management and supplier performance.
The regulatory environment also reinforces the importance of taking a structured approach. The current government guidance for public procurement places emphasis on identifying and managing modern slavery risks in both new procurement activity and existing contracts, with additional requirements for higher-risk procurements. For organisations more broadly, the Modern Slavery Act 2015 continues to require qualifying commercial organisations to report annually on the steps they’ve taken to address modern slavery risks.
Ultimately, procurement has an opportunity to move beyond simply obtaining competitive prices. Procurement teams are increasingly being expected to contribute not just to commercial performance, but also to areas such as modern slavery, sustainability, security of supply and social value. By improving supply chain visibility, strengthening supplier due diligence, embedding appropriate requirements into contracts and using data more effectively, procurement professionals can help organisations manage risk and contribute to more socially responsible supply chains. The challenge is significant, but procurement has the commercial influence and supply chain knowledge needed to make a meaningful contribution.
For more information on how your procurement teams can tackle modern slavery risks within your organisation’s supply chains, contact Barkers today for expert advice on procurement transformation, or discover how our procurement managed services can overcome your procurement capacity challenges.