Updated August 2025
Modern slavery remains a hidden yet widely spread risk across the global supply chain, and businesses are under increasing pressure to show how they’re addressing it. While many organisations publish a modern slavery statement or policy to meet basic compliance requirements, the reality is that too few of these documents translate into real action.
In this guide, we explore what a modern slavery policy should include, how it differs from a legal statement and why robust, transparent practices are essential to building a socially sustainable business.
What Is A Modern Slavery Policy?
A modern slavery policy is a formal document that outlines how an organisation prevents, identifies and addresses risks related to modern slavery and human trafficking within its operations and supply chain.
While often seen as a compliance document, an effective modern slavery policy goes far beyond legal minimums. It should form a cornerstone of your business’s social sustainability strategy.
Related Reading: How to Avoid Modern Slavery in the Workplace
Is A Modern Slavery Policy A Legal Requirement?
Yes, under the UK Modern Slavery Act 2015, commercial organisations with a turnover of £36 million or more are legally required to publish a modern slavery statement every financial year. This statement must set out the steps the organisation is taking to ensure modern slavery is not taking place in its supply chains or business operations.
However, the problem is that there is no legal requirement to have a dedicated “modern slavery policy.” Without stronger regulation or enforcement, many businesses stop at simply producing the statement with little evidence or implementation.
Modern Slavery Statement Vs Policy: What’s The Difference?
| Modern Slavery Statement | Modern Slavery Policy |
| Legal requirement under the UK Modern Slavery Act (for companies above the £36m threshold) | Voluntary internal document outlining how an organisation prevents modern slavery |
| Typically updated annually | May be reviewed annually or less frequently |
| Must be publicly available | May be internal or shared on request |
| Often describes what the company intends to do | Outlines specific policies, responsibilities, training and reporting structures |
In practice, a good modern slavery policy underpins the annual statement and demonstrates the company’s seriousness about tackling exploitation.
The Current State Of Modern Slavery Reporting In The UK
According to a 2022 report by the Financial Reporting Council, many modern slavery statements are poorly written, lacking measurable objectives or real evidence of progress. Key findings include:
- 12% of companies failed to publish a statement at all
- 14% included a link to their statement in the annual report
- Most statements were “superficial and lacked meaningful data.”
Veriforce CHAS’s own research reflects this. While most businesses have a statement or policy in place, 72% lack the practices to fulfil their commitments, creating a disconnect between policy and action.
Related Reading: Modern Slavery in SMEs: 5 Key Findings of Our Preliminary Survey with the University of Nottingham’s Rights Lab
Free Anti-Modern Day Slavery & People Trafficking Policy Template
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How To Spot A Modern Slavery Policy That Works
If you’re reviewing your own policy or a supplier’s, here are key questions you need to be asking:
- Is the policy regularly updated or simply renewed each year without review?
- Was it developed with input from relevant stakeholders, such as HR, procurement, or external human rights experts?
- Does it include measurable actions? Such as the number of staff trained, suppliers audited, or whistleblowing reports followed up.
- Are responsibilities clearly defined across departments and supply chains?
- Does it reference international standards such as the UN Guiding Principles on Business and Human Rights?
Common Gaps In Modern Slavery Policies
Even when businesses have a modern slavery policy in place, many fall short when it comes to meaningful implementation. Here are some of the most common weaknesses found in modern slavery policies and why they matter.
1. Lack Of Training Or Staff Awareness
A policy is only as effective as those who understand and enforce it. Without regular, role-specific training, staff may not recognise the signs of modern slavery or know how to report potential risks. This is especially critical in construction, manufacturing and logistics sectors, where vulnerable workers may be hidden in complex subcontractor chains.
Related Reading: Spotting and Stopping Modern Slavery in Construction
2. No Supplier Engagement Or Audits
Many policies discuss ethical sourcing, but few follow through with due diligence beyond first-tier suppliers. High-risk activities, such as outsourcing labour, raw material sourcing, or subcontracting to smaller firms, often occur deep within supply chains. Without supplier questionnaires, site visits, or independent audits, businesses can’t confidently say they are mitigating modern slavery risks.
Related Reading: What Is Modern Slavery Risk Assessment?
3. No Grievance Mechanisms
Workers facing exploitation are unlikely to come forward if there are no safe, confidential and accessible ways to report abuse. A lack of grievance mechanisms, or ineffective ones, allows modern slavery to go unchallenged. Policies should include clear information about reporting channels (e.g. hotlines, third-party platforms) that protect the identity and safety of whistleblowers. These systems should also be communicated in workers’ native languages and made available to contractors and agency staff.
4. No Board Level Oversight
Modern slavery is as much a governance issue as it is an operational one. If senior leadership isn’t actively involved in reviewing, approving and overseeing the modern slavery policy, there’s little accountability or incentive to drive improvements. The most effective policies are those that are signed off at a board level, reported on annually, and integrated into broader risk and ESG strategies.
Related Reading: What Is An ESG Policy And What Should It Include?
Why A Modern Slavery Policy Matters
Modern slavery isn’t just a legal issue; it’s also a key pillar of social sustainability. Businesses that commit to ethical sourcing, fair labour and human rights protections don’t just reduce risk; they also improve brand reputation, attract ethical investors and future-proof their operations.
Sustainability frameworks like the EU Corporate Sustainability Reporting Directive (CSRD) and EU Taxonomy are already pushing companies to disclose how they address social issues like forced labour, regardless of where they operate.
Get Your FREE Modern Slavery Policy Template
Need help drafting or updating your organisation’s modern slavery and people trafficking policy? Our FREE guide and template will walk you through everything you need to know to ensure your business and your supply chain are not knowingly employing vulnerable or trafficked workers.
Veriforce CHAS can help you build safer and more ethical supply chains
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Modern slavery policies are only worth the paper they’re written on if they’re backed by meaningful action. With growing pressure from regulators, investors and the public, businesses can no longer afford to ignore having a robust modern slavery policy in place.
Ready to take the next step? Get in touch with Veriforce CHAS today to find out how we can support your organisation’s journey toward more ethical, sustainable supply chain practices.
