Modern Slavery Act in UK Procurement

The Modern Slavery Act 2015 consolidated and strengthened UK law on slavery, servitude, forced or compulsory labour, and human trafficking. The Act has criminal-law provisions (creating specific offences for slavery and trafficking) and supply-chain transparency provisions (most importantly section 54). For procurement professionals, the most directly relevant provisions are section 54 and the supply-chain due diligence expectations that have grown around it.

Section 54 requires every commercial organisation supplying goods or services in the UK with annual turnover of at least £36 million to publish an annual slavery and human trafficking statement. The statement must set out the steps the organisation has taken (or, in some cases, that it has taken none) to ensure that slavery and trafficking are not occurring in its supply chains or own business. The statement must be approved by the board (or equivalent governing body), signed by a director, and published on the organisation's website with a prominent link from the homepage.

The public sector is also caught: from 2020, the government extended s.54 to apply to public sector bodies with annual budgets above the same threshold. NHS trusts, larger local authorities, government departments, and arm's-length bodies all need to publish s.54 statements.

For UK procurement teams, this matters in two directions. First, your own organisation may need to publish a statement and demonstrate due diligence in its supply chains — including the suppliers you contract with. Second, the suppliers you contract with may need to publish their own statements, and the quality of those statements is now a routine part of selection-stage evaluation.

Section 54 doesn't prescribe specific due diligence steps — it requires transparency about the steps an organisation takes. But over the decade since the Act, expectations have crystallised around a set of recognised practices. UK public sector buyers in particular are expected to incorporate modern slavery due diligence into procurement processes.

The Cabinet Office's Procurement Policy Note 09/16 (and subsequent updates) sets out the expected approach for central government procurement. Local authorities and the NHS have generally adopted similar approaches. Key elements include:

• Pre-contract assessment. Modern slavery risk is one of the selection-stage assessments — typically through a standard Selection Questionnaire (SQ) or equivalent.
• Risk-based prioritisation. Higher-risk sectors (construction, cleaning, hospitality, agriculture, electronics, garment manufacture) and higher-risk geographies require deeper assessment than lower-risk categories.
• Contract clauses. Standard public sector contract terms include modern slavery clauses requiring suppliers to comply with the Act, support due diligence, and notify the buyer of any identified concerns.
• Ongoing supplier engagement. Annual or biennial confirmation that suppliers continue to meet obligations. For higher-risk contracts, more active engagement — including on-site checks where appropriate.

Our procurement compliance basics guide covers the broader compliance picture; modern slavery is one strand within it.

For suppliers, modern slavery considerations are now a routine part of bidding for public sector contracts — particularly contracts of any meaningful value. Three things suppliers should expect:

1. Selection-stage questions on your modern slavery position. Almost every public sector SQ now includes a question along the lines of: "Does your organisation comply with the Modern Slavery Act 2015? Provide your most recent s.54 statement, or explain why one is not required." Suppliers turnover above £36 million who cannot provide a current statement effectively cannot bid.

For suppliers below the £36 million threshold, the answer is usually a brief statement of compliance, evidence of supply chain due diligence proportionate to your size, and confirmation of policies (modern slavery policy, supplier code of conduct, whistleblowing channel). Smaller suppliers should not over-claim — saying you have processes you don't actually operate is more risk than admitting you are scaling up incrementally.

2. Higher-risk sectors face deeper assessment. If you are in construction, cleaning, hospitality, agriculture, electronics, or garment manufacture — or use materially sub-contracted labour — expect detailed questions on your own supply chain mapping, audit programme, and remediation processes.

3. Standard contract clauses. Public sector contracts include modern slavery clauses requiring you to comply with the Act, support buyer audits, and notify any identified concerns. Read these clauses carefully — they create real obligations that can result in contract termination if breached.

Our Supplier Tender Readiness Checklist includes a modern slavery readiness section.

The Procurement Act 2023 significantly strengthened the link between modern slavery and procurement exclusion. Under the new Act:

• Conviction for a modern slavery offence is a mandatory exclusion ground. A supplier with such a conviction in the previous 5 years must be excluded from public procurements unless they can demonstrate "self-cleaning" measures.
• Modern slavery concerns can also trigger the new discretionary exclusion grounds where the supplier has been involved in serious supply-chain failures, even without a criminal conviction.
• The new Debarment Register may list suppliers found responsible for serious modern slavery failures — making them ineligible for public contracts for a defined period.

For buyers, this means: check the Debarment Register routinely (it's now part of the standard exclusion grounds check); use the Procurement Act's mandatory exclusion process where convictions are identified; and apply the discretionary exclusion thoughtfully where credible modern slavery concerns exist.

For suppliers: keep your modern slavery records demonstrable. Cooperation with audits, prompt response to identified concerns, and a credible due diligence programme are now operationally important — not just statements of good intent. Our Procurement Act 2023: What Changed guide covers the broader exclusion grounds in more detail.

• Modern Slavery Act 2015 — legislation.gov.uk (canonical text)
• Modern Slavery collection — gov.uk (Home Office guidance)
• Transparency in supply chains: a practical guide — gov.uk (Home Office statutory guidance on s.54)
• Modern Slavery Statement Registry — gov.uk (the government registry where s.54 statements are published)

Accessed 2026-07-30.