Few words send a shudder down the spine quite like “slavery.” While often associated with history, modern slavery remains a very real issue affecting millions globally, including in business supply chains. For procurement professionals, understanding the Modern Slavery Act 2015 is crucial to managing supplier risk, maintaining compliance, and protecting an organisation’s reputation.
What Is Modern Slavery and Why It Matters in Procurement?
Modern slavery covers situations where people are exploited for personal or commercial gain and cannot refuse or leave due to threats, coercion, or deception. The UN and the International Labour Organization estimate that tens of millions of people are currently affected worldwide.
For procurement teams, this is particularly important because modern slavery often occurs deep within supply chains, where visibility is limited. Ethical procurement practices are therefore central to tackling this issue.
The Modern Slavery Act 2015 – Section 54
The UK’s Modern Slavery Act 2015 includes Section 54, commonly referred to as Transparency in Supply Chains (TISC). It applies to organisations that:
- Operate, wholly or partially, in the UK
- Supply goods or services
- Have a global annual turnover of £36 million or more
If your organisation meets these criteria, you must publish a Modern Slavery Statement annually, outlining the steps taken to prevent modern slavery in your operations and supply chain.
UK guidance now emphasises that statements should demonstrate meaningful actions, not just describe policies.
Key Components of a Modern Slavery Statement
While the Act does not prescribe a strict format, best practice in procurement includes the following areas:
- Organisational structure and supply chains – mapping suppliers and understanding where risks lie.
- Policies on modern slavery and human trafficking – including internal policies and supplier codes of conduct.
- Due diligence processes – assessing supplier risk, monitoring practices, and ensuring ethical sourcing.
- Risk assessment and mitigation – identifying high-risk sectors, countries, and supply chain activities.
- Measuring effectiveness – using KPIs and reporting frameworks to track progress.
- Training – educating procurement teams, staff, and suppliers about modern slavery awareness.
Recent guidance highlights the importance of showing continuous improvement year-on-year. Procurement consultancies can help clients demonstrate both compliance and proactive risk management.
Approval and Publication Requirements
To comply legally:
- Sign-off must be by the board or equivalent senior management.
- The statement must be published on your website, ideally with a clear link on the homepage.
- Organisations without a website must provide the statement upon request within 30 days.
These steps are relatively straightforward but are critical to avoid reputational and legal risks.
Why Procurement Teams Are Central to Compliance
Procurement professionals play a key role in modern slavery compliance because they:
- Directly manage supplier relationships and supply chain visibility
- Are responsible for ethical sourcing and risk assessment
- Can embed due diligence frameworks across suppliers
- Support clients in producing robust Modern Slavery Statements
For a procurement consultancy, advising clients on Section 54 compliance is a direct service opportunity. This includes helping organisations:
- Map their supply chains for risk
- Implement supplier audits and monitoring
- Develop and maintain policies aligned with the Act
- Report transparently and credibly to stakeholders