Supply chain responsibility
Modern slavery statements for UK manufacturers
Manufacturers buy raw materials, electronic components and services through long supply chains, some of them in places where forced labour is a known risk. Section 54 of the Modern Slavery Act 2015 requires larger organisations to report each year on what they do about it, and customers of every size now ask the same questions. This guide covers who must publish, what a statement should contain, and how to map the risks behind it.
Not legal advice. The Home Office guidance "Publish an annual modern slavery statement" and its statutory guidance, "Transparency in supply chains: a practical guide", are the authoritative sources. The government has announced future changes to the reporting rules that are not yet in force.
Who must publish a statement
Under section 54, a statement is required from a commercial organisation that:
- is a body corporate or a partnership, wherever incorporated or formed;
- carries on a business, or part of a business, in the UK;
- supplies goods or services; and
- has a total annual turnover of £36 million or more.
GOV.UK guidance says total turnover includes the turnover of the organisation's subsidiary undertakings, including those operating outside the UK. A parent and its subsidiaries that each meet the test can publish a group statement that covers them all, provided it meets the requirements for each organisation.
The formal requirements
| Requirement | What GOV.UK says |
|---|---|
| Frequency | A statement for each financial year; publishing within six months of the year end is recommended |
| Approval | Approved by the board (or equivalent), with the statement saying so and giving the date |
| Signature | Signed by a director or equivalent, with name, job title and date |
| Website | Published on the organisation's UK website, with a link in a prominent place on the homepage |
| No website | Provide a copy in writing within 30 days to anyone who asks |
| Registry | Organisations are strongly encouraged to add the statement to the government's modern slavery statement registry; the guidance says this will become mandatory in future |
What a good statement covers
The guidance recommends covering six areas. For a manufacturer, each has a practical meaning:
- Structure, business and supply chains. What you make, where, and the main categories you buy: metals, plastics, electronic components, chemicals, packaging, logistics, cleaning and agency labour.
- Policies. Your modern slavery and human trafficking policy, supplier code of conduct, recruitment and whistleblowing policies.
- Due diligence. How you check suppliers: questionnaires, contract clauses, audits, and how you follow up findings.
- Risk assessment and management. Which categories and countries you consider higher risk, why, and what you do about them.
- Effectiveness. Measures you track, such as the share of spend with suppliers that have signed your code, or training completion.
- Training. Who is trained, especially buyers, HR and site managers who use agency labour.
If you have taken no steps in an area, say so plainly. A statement that describes real, limited activity is more useful, and more credible, than one that describes a programme that does not exist.
Mapping supply chain risk in manufacturing
- Raw materials. Metals and minerals can be linked to forced labour or conflict at the mining and smelting stage, several tiers away from you.
- Electronic components. Assembly of components and sub-assemblies can involve labour-intensive work in higher-risk locations.
- On-site labour. Agency workers, cleaning, security and catering contracts are a risk closer to home. Check how agencies recruit and pay workers, and whether workers pay recruitment fees.
- Logistics. Warehousing and transport subcontractors can involve the same labour risks.
A simple first step is to rank your spend categories by risk and start due diligence with the highest.
A first-year plan
- Appoint an owner and get board sponsorship.
- Map spend by category and country, and rank the risks.
- Adopt a supplier code and add modern slavery clauses to new contracts.
- Send a short questionnaire to the highest-risk suppliers and labour agencies, and follow up on the answers.
- Train buyers, HR and site managers.
- Write the statement from what actually happened, and set measures for next year.
Minerals: what applies in the UK
The UK does not have a general equivalent of the EU Conflict Minerals Regulation or the US reporting rule on conflict minerals. UK manufacturers that supply EU or US customers are nevertheless often asked to complete industry templates, such as the Responsible Minerals Initiative's Conflict Minerals Reporting Template, covering tin, tantalum, tungsten and gold, and sometimes cobalt and mica. Answering these depends on your own suppliers' answers, so ask for them early.
Public sector and defence customers
Government buyers are expected to assess modern slavery risk in their contracts. Cabinet Office procurement policy notes set out how, and bids may include questions about your approach whatever your turnover. Prime contractors ask the same questions in pre-qualification such as JOSCAR. See also the Procurement Act 2023 for suppliers.
Records make statements credible
Statements are only as good as the information behind them: which suppliers provided which materials, what evidence they gave, and what happened when something was found. Keeping supplier evidence alongside the records of what you bought and received makes it possible to show that due diligence happened. Cargovate for manufacturers keeps lot-level records of where parts came from and who handled them.
Common questions
We are under £36 million turnover. Should we publish anyway?
It is voluntary below the threshold. Many smaller suppliers publish a statement or a policy because their customers ask for one. If you do, follow the same approach: describe what you actually do.
Does the statement have to say our supply chain is free of slavery?
No. The law requires a statement of the steps taken, or a statement that no steps have been taken. Claims that a supply chain is entirely free of slavery are hard to support.
What changes are planned?
Following its transparency in supply chains consultation, the government said it would mandate the topics statements must cover, require publication on the registry and set a single reporting deadline. GOV.UK says these changes have not yet come into effect, so report under the current requirements.
Who enforces section 54?
The Act allows the Secretary of State to seek an injunction to require compliance. In practice, customer and investor scrutiny is the pressure most organisations feel.
Last reviewed 2026-09-17