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Standards and reporting

Modern Slavery Statement

A modern slavery statement is an annual account of steps taken under a defined legal route, so preparation must connect the organisation, reporting year, actions and approved publication.

What does section 54 require?

A commercial organisation within the statutory conditions must prepare a slavery and human-trafficking statement for each financial year Modern Slavery Act 2015 section 54(1)–(4).

Define the annual accountRequirements and evidence

Module 01 / 04

Organisation

Identify the commercial organisation and relevant relationships.

Read the detailed guidance and evidence

The statement is not a certificate that modern slavery is absent from every supplier, and its existence does not establish that each action described was effective.

The standards overview distinguishes statements, standards and claims, while the ESRS value-chain workers guide addresses a separate reporting framework.

Which conditions should be checked before assigning a statement owner?

Read the legal form, UK business connection and turnover test together rather than assume the duty concerns only UK-incorporated companies.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Legal formBody corporate or qualifying partnershipWhether the statutory organisation definition applies
UK connectionBusiness or part of a business carried on in the UKWhether the relevant territorial connection exists
SupplyGoods or services suppliedWhether the section 54 condition is satisfied
TurnoverOrganisation plus relevant subsidiary turnoverWhether the prescribed threshold is met
Read the detailed guidance and evidence

The £36 million amount is prescribed by SI 2015/1833, which also defines total turnover including subsidiary undertakings, rather than appearing as a number in section 54 itself Regulations 2–3.

The Home Office publication guidance gives a practical summary, but the Act and regulations remain the provisions supporting the conclusion Annual statement guidance.

Are LLPs or overseas organisations automatically outside scope?

The statutory definition reaches bodies corporate wherever incorporated with the relevant UK business connection, and an LLP is a body corporate rather than being caught through the partnership label Section 54(12) LLP Act section 1(2) and (5).

Check the actual formRequirements and evidence

Module 01 / 04

Entity

Identify the body making the statement.

Read the detailed guidance and evidence

A group should not assume that one website publication answers every entity question without checking which organisations and financial years the statement covers.

An organisation below its own statutory threshold may still receive supplier-evidence requests from a customer preparing a statement, which is a separate commercial task.

The CSDDD guide explains why a UK statement assessment cannot be substituted for an EU corporate due-diligence scope review.

Are the six suggested content areas mandatory?

Section 54(5) says the statement may include the listed information, while the underlying statement obligation remains defined separately.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Structure and policiesActual organisational arrangementsWhether the account describes the relevant business
Due diligence and riskActivities actually performedWhether claims can be supported by evidence
EffectivenessMeasures and their limitationsWhether results are described honestly
TrainingWho received what and for what purposeWhether attendance is confused with effectiveness
Read the detailed guidance and evidence

The Home Office practical guide helps structure a useful account, but the suggested areas should not be described as six separate statutory content mandates Section 54(5) Practical guide.

An organisation should avoid replacing a substantive account of its steps with headings that merely reproduce the guidance.

How should a fictional organisation test its draft claims?

Fictional case: Stonemere Hospitality’s draft says every labour supplier was checked, but the supporting tracker covers only the suppliers used at its largest locations.

Test the population claimRequirements and evidence

Module 01 / 04

Assertion

Identify the exact claim proposed for publication.

Read the detailed guidance and evidence

The problem is not cured by attaching the tracker because the population behind the word “every” is narrower than the statement suggests.

Stonemere should reconcile the labour-supplier population and investigate the omitted relationships before deciding what the annual statement can support.

The Home Office guidance warns against relying on audits alone, so an audit label cannot by itself close the coverage or effectiveness question Practical guide, audits and inspections.

What evidence would improve Stonemere’s account?

This original fictional review distinguishes records of activity from evidence about what the activity achieved.

Original fictional statement-review example, not a prescribed audit or due-diligence method.
Evidence questionRecord to inspectDecision supported
Supplier reviewPopulation and questions actually coveredA claim limited to the reviewed relationships
Audit reportPeriod, locations and proceduresUnderstanding of the audit’s actual coverage
Worker concernSource, investigation and responseA supported description of the issue and action
Training recordAttendance, content and follow-upA claim about delivered training without invented outcomes
Read the detailed guidance and evidence

A training session or policy acknowledgement can be reported as an action without claiming it proves the absence of abuse.

The evidence review should preserve unresolved concerns rather than turn a missing or conflicting record into a clean supplier result.

Who must approve and sign the statement?

Section 54 sets approval and signature arrangements by organisational form, which should be checked against the actual entity rather than treated as a universal marketing sign-off Section 54(6).

Approve the real accountRequirements and evidence

Module 01 / 04

Version

Identify the draft being approved.

Read the detailed guidance and evidence

Stonemere’s board paper should identify the corrected supplier-coverage statement and any remaining limitation, rather than only request approval of a polished design.

The approved document and website version should match, including any later correction to the account of steps taken.

The UK SRS for boards guide develops the wider evidence-challenge problem, without implying that the two reporting routes share identical approval rules.

What should be checked when the statement is published?

Website access and the voluntary registry are separate publication decisions.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Organisation websiteStatement and prominent homepage linkThe section 54 publication route
No websiteThe statutory request processHow a copy will be supplied where applicable
Government registryAccepted statement and relevant informationA voluntary additional publication route
Version consistencyWebsite and registry documentsWhether readers encounter the same approved account
Read the detailed guidance and evidence

Section 54(7)–(8) supplies the website or request mechanism, while the registry and Home Office guidance encourage adding a statement rather than making registry submission an existing statutory filing duty Section 54(7)–(8) Registry service Annual statement guidance.

Does the registry’s reporting-year convention set a legal deadline?

Keep the registry process and guidance conventions distinct from the wording of the statutory duty Registry submission process Section 54.

Separate process from lawRequirements and evidence

Module 01 / 04

Financial year

Identify the year the statement describes.

Read the detailed guidance and evidence

The registry process explains its own year convention and optional summary questions, which should not be promoted into additional mandatory statutory statement topics Registry process guidance.

The historical government response records policy intentions, but it does not replace the current Act with a future mandatory-registry or single-deadline regime Government response, historical policy source.

A current-law review is necessary before describing any proposed reform as already applying.

What must remain distinct from the section 54 statement?

Shared supplier information can support several outputs without making their purposes or applicability identical.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Customer questionnaireSpecific customer evidence requestA contractual response rather than automatic statutory scope
Government procurementBuyer’s identified procurement questionsThe separate PPN context and applicable requirements
Corporate annual reportHuman-rights information where the company-law provisions applyA separate reporting basis and location
EU due diligenceScope and process under the relevant directiveA distinct legal assessment rather than statement equivalence
Read the detailed guidance and evidence

Cabinet Office PPN 009 addresses government supply-chain procurement, while Companies Act section 414CB has its own scope and reporting content, so neither should be collapsed into a universal section 54 template PPN 009 guidance Companies Act section 414CB.

What would a useful original statement-evidence register contain?

A claim-to-evidence register can make the approval review practical without becoming a supplier certification scheme.

Trace each public claimRequirements and evidence

Module 01 / 04

Claim

Exact statement wording and intended coverage.

Read the detailed guidance and evidence

Stonemere’s planned register would show the initial “every supplier” claim, the discovered population gap and the corrected approved statement.

Sensitive worker information should be referenced through controlled records rather than copied into a workbook circulated with a public-report draft.

A software RFP should test whether a revised claim preserves the source and earlier reviewer challenge.

Which assertions deserve a final wording challenge?

Make the final account proportionate to the evidence and avoid unsupported assurance language.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
“All suppliers checked”Reconciled supplier populationDoes the stated coverage match the actual work?
“No modern slavery”Scope and limits of the evidenceIs the claim stronger than the investigation supports?
“Audited and compliant”Actual audit and legal-basis assessmentAre distinct conclusions being conflated?
“Registry filing mandatory”Current law and registry guidanceHas a future intention been mistaken for an operative rule?
Read the detailed guidance and evidence

The Act’s statement duty and permissive content list do not require a particular audit scheme, rating or certification Section 54(4)–(5) Practical guide.

A consultancy brief should specify statement preparation and evidence review without promising that drafting proves the absence of exploitation.

What if evidence changes after board approval?

Compare the final published account with the approved wording and assess the consequence of a newly discovered limitation.

Check the approved versionRequirements and evidence

Module 01 / 04

Discovery

Identify the new fact and the assertion affected.

Read the detailed guidance and evidence

Stonemere discovers after approval that a supplier review described in the draft took place outside the financial year the statement covers.

The report owner should resolve the timing and wording with the appropriate approving team rather than leave a misleading account because the publication design is finished.

Retain the actual approved and published versions so the section 54 approval and publication record can be reconstructed Section 54(6)–(8).

How can the team prepare a reviewable evidence file?

This editorial workflow organises preparation without certifying compliance or replacing a statutory process.

  1. 101

    Assess the organisation

    Check form, UK activity and turnover basis.
  2. 202

    Set the period

    Identify the financial year and statement population.
  3. 303

    Collect the steps

    Record what was actually done.
  4. 404

    Reconcile coverage

    Check suppliers, sites and group entities described.
  5. 505

    Review effectiveness claims

    Read evidence and limitations behind outcomes.
  6. 606

    Resolve the draft

    Correct broad or unsupported statements.
  7. 707

    Approve and sign

    Use the applicable organisational requirements.
  8. 808

    Publish accessibly

    Check the website route and any voluntary registry entry.
  9. 909

    Retain the record

    Preserve approved wording, evidence and subsequent corrections.

Which specialist buyer or assessment workflow fits the next task?

Use the detailed workflow for the actual study, operational record, assessment or submission being commissioned.

Choose the guide for the actual study, scheme, reporting population or evidence handover.
Reader questionDetailed guide
How do platform membership, site audit and corrective-action records differ?Sedex and SMETA

Frequently asked

Questions people ask

Who must publish a modern slavery statement?

Assess the commercial-organisation, UK-business, goods/services and turnover conditions together.

Is the turnover threshold in the Act?

The £36 million amount and turnover calculation are set in the regulations rather than stated as a figure in section 54.

Are the six content areas legally mandatory?

Section 54(5) says the statement may include those areas, which is different from six mandatory content duties.

Must we use the government registry?

The current registry and guidance encourage submission as an additional route, separate from the statutory website-publication duty.

Does an audit prove the statement is accurate?

No, review its scope and limitations and avoid relying on audits alone.

Are LLPs automatically excluded?

No, an LLP is a body corporate and must be assessed against the section 54 conditions.

Sources

Primary sources

Primary provisions and official owner guidance checked on 26 October 2026; historical and draft resources are labelled in the guide.

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