Anti-Slavery Policy UK: Modern Slavery Act Compliance

What this document is

An Anti-Slavery and Human Trafficking Policy is an internal document that records how your organisation approaches the risks of forced labour, servitude, trafficking and other forms of modern slavery across its operations and supply chains. It typically sets out the company's position, the responsibilities of directors, managers and staff, the due diligence applied to suppliers, how concerns are reported, and the consequences of breaches.

Unlike the public slavery and human trafficking statement required under section 54 of the Modern Slavery Act 2015, the policy itself is usually aimed at employees, contractors and business partners. It provides the internal foundation that the public statement then summarises. Even organisations that fall below the turnover threshold for publishing a statement often adopt a policy, because clients, tender processes and larger supply chain partners increasingly expect one. A well-drafted policy signals commitment, supports staff training, and helps the business respond consistently if a concern is raised.

How to use this document

1. Map your business and supply chain. Start by understanding where the risks actually sit. Look at the sectors you buy from, the countries involved, the use of agency workers, and any outsourced services such as cleaning, logistics or manufacturing. Without this picture, a policy is generic and difficult to apply in practice.
2. Set a clear organisational position. The policy should state, in plain language, that the business has zero tolerance for slavery and human trafficking in any form. Make clear who owns the policy at board level, who is responsible for day-to-day implementation, and how it links to other policies such as whistleblowing, procurement and recruitment.
3. Build in due diligence and supplier expectations. Set out what you expect from suppliers and contractors, including warranties in contracts where appropriate, supplier questionnaires, and the right to audit or terminate where serious concerns arise. Describe how new suppliers are assessed and how existing ones are reviewed over time.
4. Create reporting and training routes. Staff need to know how to raise a concern and feel confident doing so. The policy should explain the reporting channel, confirm that whistleblowers will be protected, and describe the training given to employees, particularly those in procurement, HR and operational roles where risks are more likely to be spotted.
5. Review, publish and keep it current. Agree a review cycle, typically annually, and align it with the timing of your section 54 statement if one is required. Where a statement is published, make sure it is approved by the board, signed by a director, and placed prominently on the company's website so it can be found easily.

Common questions