Modern Slavery Act (UK)
UK legislation from 2015 that consolidates slavery and trafficking offences, establishes the Independent Anti-Slavery Commissioner, and requires commercial organisations with annual turnover of GBP 36 million or more to publish an annual modern slavery statement.
- What Is the Modern Slavery Act?
- Criminal Offences Under the Act
- Section 54: Transparency in Supply Chains
- HR's Role in Modern Slavery Prevention
- High-Risk Sectors for Modern Slavery
- The National Referral Mechanism (NRM)
- Penalties and Enforcement
- Modern Slavery Statistics [2026]
- Frequently Asked Questions About the Modern Slavery Act
What Is the Modern Slavery Act?
Key Takeaways
- ✓The Modern Slavery Act 2015 is the UK's primary legislation addressing slavery, servitude, forced or compulsory labour, and human trafficking. It consolidated previous legislation into a single statute.
- ✓Section 54 requires any commercial organisation operating in the UK with an annual turnover of GBP 36 million or more to publish a modern slavery statement for each financial year.
- ✓The Act created the offence of holding a person in slavery or servitude (section 1) and the offence of human trafficking (section 2), with maximum penalties of life imprisonment.
- ✓The Independent Anti-Slavery Commissioner (IASC) was established under the Act to encourage good practice in preventing, detecting, investigating, and prosecuting modern slavery offences.
- ✓The National Referral Mechanism (NRM) received 16,938 referrals of potential modern slavery victims in 2023, a 49% increase from 2020 (Home Office).
Modern slavery isn't a historical problem. It exists in the UK today, in sectors ranging from agriculture and construction to hospitality, manufacturing, and domestic work. The Modern Slavery Act 2015 was the first legislation of its kind in Europe, creating a single framework to address all forms of modern slavery and human trafficking. For HR teams, the Act matters in two ways. First, it creates criminal offences for holding people in slavery, servitude, or forced labour, and for trafficking. Any employer who knowingly or recklessly allows these conditions faces prosecution. Second, Section 54 creates transparency obligations for large organisations, requiring them to report publicly on what they're doing to identify and prevent modern slavery in their operations and supply chains. The Act recognises that businesses play a critical role in combating modern slavery because they control the supply chains where exploitation often occurs. A company buying goods produced by forced labour is part of the problem, even if the exploitation happens several tiers down the supply chain.
Criminal Offences Under the Act
The Act creates two primary offences and a preparatory offence. Understanding the definitions matters for employer due diligence.
Slavery, servitude, and forced labour (Section 1)
A person commits an offence if they hold another person in slavery or servitude, or require them to perform forced or compulsory labour. The Act refers to Article 4 of the European Convention on Human Rights for definitions. Indicators include: restrictions on movement, withholding of identity documents, debt bondage, threats of violence, deception about the nature of work, and payment of wages below the minimum or withheld entirely. The maximum penalty is life imprisonment.
Human trafficking (Section 2)
A person commits an offence if they arrange or facilitate the travel of another person with a view to exploitation. "Travel" includes recruitment, transportation, transfer, harbouring, or receipt of persons. Exploitation covers slavery, servitude, forced labour, sexual exploitation, organ harvesting, and securing services by force, threats, or deception. Trafficking can be international or entirely domestic. Moving someone from one city to another within the UK to exploit them is trafficking under this Act.
Committing an offence with intent (Section 4)
A person commits an offence if they commit any offence with the intention of committing a human trafficking offence. This captures preparatory activities like forging documents, arranging transport, or acquiring premises for exploitation. The maximum sentence is 10 years' imprisonment.
Section 54: Transparency in Supply Chains
Section 54 is the provision that directly affects corporate HR and procurement teams. It requires qualifying organisations to publicly state what they're doing about modern slavery risks.
Who must comply
Any commercial organisation (including partnerships) that supplies goods or services, carries on business (or part of a business) in the UK, and has an annual turnover of GBP 36 million or more. "Turnover" is the total turnover of the organisation and any subsidiaries (group turnover). The government's modern slavery registry shows that thousands of organisations are required to comply, though compliance rates are far from 100%. Non-commercial organisations (charities, educational institutions, public bodies) aren't covered by Section 54, though the government introduced separate reporting requirements for public bodies in 2022.
What the statement must include
The statement must cover the steps the organisation has taken during the financial year to ensure that slavery and human trafficking are not taking place in its business or supply chains. The Act suggests (but doesn't mandate) covering: the organisation's structure, business, and supply chains; policies in relation to slavery and human trafficking; due diligence processes; risk assessment and management; performance indicators used to measure effectiveness; and training available to staff. If the organisation has taken no steps, it must say so. A blank or boilerplate statement technically complies with the letter of the law, though it creates reputational risk.
Publication requirements
The statement must be published on the organisation's website with a prominent link from the homepage. It must be approved by the board of directors (or equivalent) and signed by a director (or equivalent senior figure). Since 2021, organisations must also submit their statements to the government's modern slavery statement registry at modern-slavery-statement-registry.service.gov.uk. Statements should be published within 6 months of the organisation's financial year end.
HR's Role in Modern Slavery Prevention
HR teams sit at the intersection of recruitment, employment practices, and worker welfare, making them critical to identifying and preventing modern slavery risks within the organisation's own operations.
- Review recruitment processes for signs of labour exploitation: agencies that don't verify workers' right to work, unusually low agency fees (suggesting costs are recovered from workers), workers who seem coached or fearful during interviews.
- Ensure all workers receive their pay directly and in full. Third parties collecting wages on behalf of workers is a major red flag for forced labour.
- Verify that agency workers and contractors have legitimate contracts, understand their terms, and aren't subject to debt bondage (where workers owe money to the person who arranged their employment).
- Train HR staff and line managers to recognise indicators of modern slavery: workers who are transported to and from work in groups, who live at the workplace, who have no access to their own documents, who appear malnourished or frightened, or who have signs of physical abuse.
- Establish a confidential reporting mechanism (whistleblowing hotline or third-party service) for concerns about modern slavery, both internally and in the supply chain.
- Include modern slavery clauses in supplier contracts requiring compliance with the Act and granting the right to audit.
- Conduct due diligence on recruitment agencies, particularly those supplying temporary or seasonal labour in high-risk sectors (agriculture, food processing, cleaning, construction).
High-Risk Sectors for Modern Slavery
Modern slavery occurs across the economy, but certain sectors have consistently higher rates of exploitation.
| Sector | Risk Factors | Common Exploitation Types |
|---|---|---|
| Agriculture and food processing | Seasonal labour, rural isolation, reliance on migrant workers, complex supply chains | Forced labour, debt bondage, substandard living conditions |
| Construction | Subcontracting layers, cash-in-hand payments, transient workforce | Labour exploitation, wage theft, unsafe working conditions |
| Care and hospitality | Low-paid work, live-in roles, agency staffing, high turnover | Domestic servitude, forced labour, document confiscation |
| Hand car washes | Cash-heavy, limited regulation, high proportion of migrant workers | Labour exploitation, trafficking, wage theft |
| Textiles and manufacturing | Global supply chains, price pressure from buyers, informal workshops | Forced labour, child labour, excessive working hours |
| Cleaning and facilities management | Outsourced services, limited direct employer oversight, night work | Labour exploitation, wage underpayment, restricted movement |
The National Referral Mechanism (NRM)
The NRM is the UK's framework for identifying and supporting victims of modern slavery. Understanding it matters for employers who may encounter potential victims in their workforce.
How the NRM works
When a potential victim is identified, a first responder organisation (such as the police, local authority, or specified NGOs) makes a referral to the NRM. The Single Competent Authority (part of the Home Office) then makes two decisions: a reasonable grounds decision (within 5 working days, assessing whether there are reasonable grounds to believe the person is a victim) and a conclusive grounds decision (within 45 days of the reasonable grounds decision). During the NRM process, potential victims receive support including safe accommodation, financial support, and access to legal advice.
Employer responsibilities when identifying potential victims
If an employer or HR team suspects that a worker may be a victim of modern slavery, they should not attempt to investigate themselves (this could put the victim at risk or compromise a criminal investigation). Instead, contact the Modern Slavery Helpline (08000 121 700), report to the police, or refer to the Gangmasters and Labour Abuse Authority (GLAA) for labour exploitation cases. The worker should not be dismissed or have their employment terminated simply because they may be a victim. The duty of care remains, and removing the victim from the workplace without proper support can push them back into exploitation.
Penalties and Enforcement
The Act's enforcement operates on two tracks: criminal penalties for slavery and trafficking offences, and civil enforcement for transparency reporting failures.
Criminal penalties
Section 1 (slavery, servitude, forced labour) and Section 2 (trafficking): maximum sentence of life imprisonment. Section 4 (preparatory offences): maximum 10 years. Courts can also make Slavery and Trafficking Prevention Orders (STPOs) restricting the movements and activities of convicted offenders, and Slavery and Trafficking Risk Orders (STROs) for individuals who haven't been convicted but pose a risk. Reparation orders can require convicted defendants to pay compensation to their victims.
Section 54 enforcement
The enforcement of Section 54 has historically been weak. There's no direct financial penalty for failing to publish a statement. The Secretary of State can seek an injunction through the High Court to compel publication, but this power has rarely been used. However, enforcement is tightening. The government has consulted on introducing financial penalties for non-compliance with reporting requirements. Additionally, failing to report creates significant reputational, procurement, and investor relations risks, as institutional investors and public sector buyers increasingly scrutinise modern slavery statements.
Modern Slavery Statistics [2026]
Data showing the scale of modern slavery in the UK and the response to it.
Frequently Asked Questions
Does the Modern Slavery Act apply to businesses headquartered outside the UK?
What happens if an organisation doesn't publish a modern slavery statement?
Are charities and public bodies covered by Section 54?
How should HR teams handle a suspicion of modern slavery in the workplace?
Does a modern slavery statement need to cover the entire global supply chain?
Written by Adithyan RK