Modern Slavery laws in England and Wales: what businesses and legal professionals need to know

Legislation has evolved to address forced labour, human trafficking and exploitation, with the Modern Slavery Act 2015 (“the Act”) standing as the cornerstone of the current legal framework. 

The Act imposes clear obligations on businesses to ensure transparency in supply chains, reflecting growing expectations from government and the public alike and in March 2025, Statutory Guidance (“the Guidance”) was published by the Government which detailed how business should comply with Section 54 of the Act which requires certain commercial organisations to publish an annual slavery and human trafficking statement.

What This Means for Businesses and Organisations

Section 54 of the Act requires businesses with an annual turnover of £36 million or more to set out in a modern slavery statement the steps they have taken to prevent modern slavery within their operations and supply chains. 

The content that may be included, in accordance with Section 54(5) of the Act is:

• organisational structure, its business and its supply chains
• organisational policies
• assessing and managing risk
• due diligence in relation to modern slavery (including approach to remediation)
• training
• monitoring and evaluation (understanding and demonstrating effectiveness)

This duty under Section 54 of the Act applies not only to UK-registered companies but also to overseas firms conducting business in the UK.

Failure to comply can result in injunctive proceedings being issued with the risk of unlimited fines for failure to comply, as well as reputational damage and exclusion from public procurement processes. 

The Act demands a proactive approach, reviewing contracts, conducting due diligence, and engaging suppliers on ethical standards. The emphasis is on transparency and accountability with a view to organisations continuing to improve their outcomes based on better due diligence, rather than simply avoiding criminal liability and reporting zero risk or incident.

Potential Changes: What’s on the Horizon?

It is anticipated the modern slavery compliance landscape is set to become more rigorous with plans to strengthen the Act including the introduction of mandatory reporting areas, standardising statements and imposing new civil penalties for non-compliance. 

There is also discussion of a central government-run online registry for modern slavery statements, which would increase public scrutiny and transparency.

Future legislative changes may also lower the turnover threshold, bringing more businesses within scope, and require board-level sign-off to reinforce accountability. 

As these potential reforms are on the table early engagement and policy review is therefore essential for staying ahead of the curve.

Getting Your House in Order: Practical Steps for Compliance

To ensure compliance with the Act and manage risk, organisations should take a systematic approach:

• Start by mapping your supply chain and identifying areas of potential vulnerability;
• Update internal policies to reflect current best practice and ensure all staff receive training on modern slavery risks;
• Engage suppliers with clear expectations and contractual commitments; and
• Conduct regular audits to assess compliance.

Businesses and organisations would also be wise to review and update their annual statement, ensuring it covers all required areas and is approved at board level. 

Is it imperative businesses and organisations keep abreast of legislative changes and are prepared to adapt their approach as new regulations come into force. 

By embedding modern slavery compliance into an organisation’s culture and processes, it will not only meet its legal obligations but also strengthen its reputation and resilience.