Modern Slavery Statement: How to Draft a Compliant Statement

The UK Modern Slavery Act 2015 mandates that organisations with an annual turnover of at least £36 million supplying goods or services in the UK must publish an annual modern slavery statement. This statement must transparently disclose the organisation’s efforts to tackle modern slavery risks in their supply chains and operations. Similarly, the Australian Modern Slavery Act 2018 requires entities with consolidated revenue exceeding AUD 100 million to report on modern slavery risks and actions, while Canadian Bill S-211 (2023) obliges companies to report on measures taken to prevent forced and child labour risks.

With the introduction of the EU CSDDD (Directive (EU) 2024/1760), companies operating in the EU must not only report but actively implement due diligence processes to identify, prevent, mitigate, and account for adverse human rights impacts, including modern slavery. This guide explains how to draft a compliant modern slavery statement aligned with these legal frameworks, detailing the six required sections under the UK Act, additional criteria under Australian and Canadian laws, and the enhanced requirements under the EU CSDDD.

Understanding and complying with these obligations will help you avoid penalties of up to 5% of global annual turnover under the EU CSDDD, fines up to £20 million or 4% of turnover under the UK Act, and reputational damage that can severely impact your business.

Who Must Publish a Modern Slavery Statement?

Six Required Sections of a UK Modern Slavery Statement

Under Section 54 of the UK Modern Slavery Act 2015, your statement must include the following six sections:

1. Organisation structure, business, and supply chains: Describe your company’s structure, operations, and supply chain complexity.
2. Policies in relation to slavery and human trafficking: Outline policies addressing modern slavery risks, such as supplier codes of conduct.
3. Due diligence processes: Explain how you assess and manage modern slavery risks in your supply chains.
4. Risk assessment and management: Detail the procedures to identify and mitigate high-risk areas.
5. Key performance indicators (KPIs): Provide measurable outcomes to track progress against modern slavery.
6. Training: Describe training programs for staff and suppliers on modern slavery awareness and prevention.

These sections ensure transparency and accountability, enabling stakeholders to assess your commitment and effectiveness in combating modern slavery.

Additional Criteria under Australian and Canadian Laws

The Australian Modern Slavery Act 2018 requires reporting against seven mandatory criteria, which expand on the UK’s six sections by including:

• Structure, operations, and supply chains
• Modern slavery risks in operations and supply chains
• Actions taken to assess and address risks
• Effectiveness assessment of actions
• Consultation with entities owned or controlled by the reporting entity
• Other relevant information

Canadian Bill S-211 (2023) focuses on forced labour and child labour risks, requiring companies to report on:

• Steps taken to prevent and reduce these risks
• Due diligence processes implemented
• Outcomes and remediation efforts

How to Draft a Compliant Modern Slavery Statement: Step-by-Step Guide

Follow these eight practical steps to ensure your statement meets all legal requirements and aligns with the EU CSDDD due diligence expectations:

1. Map your supply chain: Identify all suppliers and sub-suppliers, focusing on high-risk sectors such as garments, electronics, agriculture, and construction, and high-risk geographies like Southeast Asia, Sub-Saharan Africa, and parts of Eastern Europe.
2. Conduct a risk assessment: Use authoritative tools such as the Global Slavery Index, Transparency International Corruption Perceptions Index, and sector-specific risk assessment frameworks to evaluate risks.
3. Document your policies: Include a supplier code of conduct explicitly prohibiting forced labour, a whistleblower policy protecting reporters of abuses, and a recruitment policy banning recruitment fees charged to workers.
4. Describe your due diligence processes: Detail supplier audits, questionnaires, and third-party verifications used to monitor compliance and identify violations.
5. Report on outcomes: Quantify the number of suppliers audited, issues identified, and remediation actions completed, providing transparency on effectiveness.
6. Describe training: Outline training programs delivered to staff and suppliers to raise awareness and build capacity to prevent modern slavery.
7. Obtain board approval: Ensure the statement is reviewed and approved by your board of directors and signed by a senior director to demonstrate leadership commitment.
8. Publish and submit: Publish the statement prominently on your website and submit it to the relevant government registry, such as the modernslaveryregistry.com for UK statements or the Australian Border Force registry.

Comparison of Key Legal Requirements

Practical Compliance Checklist

• Confirm if your organisation meets the turnover or revenue thresholds for your jurisdiction.
• Map your entire supply chain, identifying high-risk sectors and geographies.
• Conduct a comprehensive risk assessment using recognised indices and tools.
• Develop and document clear policies addressing modern slavery risks.
• Implement robust due diligence processes, including audits and supplier engagement.
• Collect and report measurable KPIs demonstrating progress and impact.
• Deliver targeted training programs to employees and suppliers.
• Secure board approval and director signature on the statement.
• Publish the statement on your website and submit it to the relevant government registry.
• Review and update the statement annually to reflect evolving risks and actions.