Modern Slavery Statement (Procurement)

Modern slavery encompasses forced labour, human trafficking, debt bondage, domestic servitude, and child labour. It exists in supply chains that serve European public and private markets, often in sectors such as construction, food production, cleaning services, garment manufacturing, and electronics. Legislation requiring transparency and due diligence on these risks has spread across Europe, making modern slavery statements an increasingly standard element of public procurement compliance.

What is a Modern Slavery Statement (Procurement)?

A modern slavery statement is a formal disclosure, typically published annually, in which an organisation describes what it has done during the reporting period to assess and address the risk of modern slavery in its operations and supply chains. The statement is a transparency mechanism: it does not certify that no modern slavery exists, but it demonstrates that the organisation has thought seriously about the risk and has taken proportionate action.

The most developed legislative framework for modern slavery statements in European procurement comes from the UK. Section 54 of the Modern Slavery Act 2015 requires commercial organisations supplying goods or services in the UK with an annual turnover at or above 36 million pounds to publish an annual transparency statement. The statement must be approved by the board, signed by a director, and published on the organisation's website. Government guidance identifies six recommended areas to address: the organisation's structure and supply chains; its policies; its due diligence processes; risk assessment and management; effectiveness measures; and training.

For UK public procurement specifically, Procurement Policy Note 02/23 requires central government contracting authorities to assess whether suppliers above the turnover threshold have compliant modern slavery statements and, from a specified date, to exclude those that do not. This made modern slavery compliance a formal selection criterion in central government procurement for the first time.

At the EU level, comparable requirements are arriving through a different legislative route. The EU Corporate Sustainability Reporting Directive (CSRD, Directive 2022/2464) requires large EU companies to report on their social impacts, including forced labour risks, as part of sustainability reporting. The proposed EU Corporate Sustainability Due Diligence Directive goes further, requiring active due diligence and remediation. These developments mean that the UK's statement-based approach is part of a broader European trajectory toward mandatory supply chain transparency, even though the specific mechanisms differ.

Why it matters for bidders

Any supplier seeking to win UK central government contracts must have a compliant modern slavery statement if its turnover meets the threshold. The statement must be substantive: a generic document that restates legal obligations without describing actual due diligence activity will not satisfy an assessing contracting authority. Strong statements describe specific supply chain mapping exercises, supplier risk assessments, audit findings, corrective actions taken, and training delivered to procurement staff.

Suppliers below the turnover threshold are not exempt from scrutiny. Many contracting authorities ask all tendering suppliers (regardless of size) to describe their modern slavery due diligence processes in selection questionnaires. A small supplier with no answer to this question is at a disadvantage against a competitor with a documented approach, even without the formal statement obligation.

For European suppliers outside the UK, monitoring the evolving CSRD and CSDDD obligations is equally important. Suppliers that build human rights due diligence capabilities now will be better positioned to meet these requirements as they come into force.

Example

A catering services company with 45 million pounds annual revenue submits a bid for a National Health Service catering contract. The selection questionnaire requires confirmation that the company has published a compliant section 54 statement and a brief description of how it assesses modern slavery risk in its food supply chain. The company attaches its current transparency statement, which describes its supplier risk tiering methodology, its audit programme for high-risk agricultural supply chains, and its staff training on identifying indicators of exploitation. The evaluators confirm the statement is current, board-approved, and substantive, and the company proceeds to the technical evaluation.

Frequently Asked Questions

What makes a modern slavery statement "compliant" for procurement purposes?

At minimum, the statement must address the six areas identified in UK Home Office guidance, be approved by the board and signed by a director, be published on the company's website, and relate to the most recent financial year. For procurement purposes, the additional question is whether it reflects genuine due diligence activity rather than boilerplate. Assessing authorities look for evidence of supply chain mapping, risk assessment, and concrete steps taken in response to identified risks.

Do non-UK EU suppliers need a modern slavery statement for UK procurement?

If the supplier supplies goods or services in the UK and meets the 36 million pound turnover threshold (calculated on UK turnover), yes. For suppliers below that threshold, no statement is legally required but equivalent due diligence evidence may still be requested. Suppliers uncertain about their threshold calculation should seek legal advice, as the assessment includes subsidiaries and group entities operating in the UK.

How does a modern slavery statement relate to ethical sourcing more broadly?

Modern slavery is one dimension of ethical sourcing. A strong ethical sourcing programme addresses forced labour, child labour, worker safety, fair wages, freedom of association, and environmental impacts. The modern slavery statement focuses specifically on the forced labour and trafficking dimensions of this broader agenda. Suppliers with mature ethical sourcing programmes will find that their modern slavery statement follows naturally from their existing due diligence processes.