TPRM maturity check: Take the check
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ESG and modern slavery

Evidence-led supplier checks for environmental, social and labour risks.

Overview

Under section 54 of the UK Modern Slavery Act 2015, organisations with a turnover of £36 million or more must publish an annual slavery and human trafficking statement.

The statement sets out the steps the organisation has taken during the financial year to ensure that slavery and human trafficking are not taking place in any of its supply chains or in any part of its own business, or states that it has taken no such steps.

Section 54 does not prescribe a fixed format, but lists six areas a statement may cover. Home Office statutory guidance sets out expectations on content and approval, and government departments encourage publication on the government modern slavery statement registry.

EU due diligence rules were narrowed in 2026: the Corporate Sustainability Due Diligence Directive now applies from July 2029 to the largest companies only.

Applies to

  • Commercial organisations supplying goods or services in the UK with turnover of £36 million or more
  • Bodies corporate and partnerships, wherever incorporated or formed, that carry on a business or part of a business in the UK
  • Businesses asked by customers or buyers for responsible sourcing evidence
  • Suppliers to public bodies, where procurement rules (PPN 009 and the Procurement Act 2023) require modern slavery risks to be identified and managed

Scope and applicability

Confirm the requirements that apply to your entity, the service and the arrangement before selecting the depth of review. How the rules apply depends on your entity.

Key dates

2015

Modern Slavery Act 2015 enacted

Financial years ending on or after 31 March 2016

First statements required under section 54

11 March 2021

Government modern slavery statement registry launched

Annually

Slavery and human trafficking statement published

25 July 2024

EU Corporate Sustainability Due Diligence Directive (EU) 2024/1760 enters into force

18 March 2026

Omnibus I (Directive (EU) 2026/470) narrows the CSRD and CSDDD; CSDDD obligations apply from July 2029

Inside the regulation

Section 54 in outline

Section 54 of the Modern Slavery Act 2015, Transparency in supply chains, applies to commercial organisations that supply goods or services and have a total turnover at or above the threshold set by regulations, currently £36 million.

The statement covers the organisation’s financial year. Statutory guidance says statements should be published as soon as possible and at most within six months of the financial year end. This is guidance rather than a legal deadline.

Wider ESG supply chain rules

Beyond section 54, organisations may face supply chain due diligence or disclosure expectations under EU law, including the Corporate Sustainability Due Diligence Directive, the Corporate Sustainability Reporting Directive and the Forced Labour Regulation, as well as customer and investor requirements. Applicability depends on the organisation's size, turnover in the EU and sector.

Changes adopted in 2026 (Omnibus I) narrowed the CSRD and CSDDD, and the EU Deforestation Regulation was postponed to 30 December 2026.

Detailed requirements

01

Annual statement

Publish a slavery and human trafficking statement each financial year.

02

Approval and signature

For a company, the statement must be approved by the board of directors and signed by a director. Equivalent rules apply to limited liability partnerships and other partnerships.

03

Publication

If the organisation has a website, publish the statement there with a link in a prominent place on the homepage. Without a website, provide a copy within 30 days to anyone who requests it in writing.

04

Know your supply chain

Identify the parts of the business and supply chains where modern slavery risks arise, and how they are assessed and managed

05

Suggested content

Section 54(5) says a statement may include: the organisation’s structure, business and supply chains; its policies on slavery and human trafficking; its due diligence processes; the parts of its business and supply chains where there is a risk and the steps taken to assess and manage it; its effectiveness, measured against appropriate performance indicators; and training available to staff.

06

Due diligence

Assess suppliers for labour, environmental and social risks.

07

Evidence and follow-up

Record findings and the actions taken.

08

Enforcement

The Secretary of State may bring civil proceedings for an injunction (or, in Scotland, specific performance) to require an organisation to comply with section 54.

How Trestec supports it

Requirement

Supply chain visibility

How Trestec supports it

Suppliers and their suppliers mapped by country and category

Requirement

Supplier questionnaires

How Trestec supports it

ESG and labour questionnaires through the supplier portal

Requirement

Supporting documents

How Trestec supports it

Policies, audits and certifications checked for dates

Requirement

Risk rating

How Trestec supports it

Supplier ESG risk scored with reasons

Requirement

Contract commitments

How Trestec supports it

Modern slavery and code-of-conduct clauses reviewed

Requirement

High-risk regions

How Trestec supports it

Suppliers in higher-risk locations flagged against a high-risk country list and geographic event monitoring

Requirement

Remediation

How Trestec supports it

Actions assigned to named owners and tracked

Requirement

Annual statement evidence

How Trestec supports it

Records gathered for the statement as work happens

Requirement

Supplier audit and termination rights

How Trestec supports it

Audit, remediation and termination clauses identified in supplier contracts

Requirement

Performance indicators

How Trestec supports it

Due diligence coverage and open actions recorded for year-on-year comparison

Illustrative mapping, not a compliance determination.

Supervisory review: gaps to examine

Illustrative review questions, not findings from a supervisor.

Tier one only

Checks stop at direct suppliers where risk is often lower.

Self-declarations only

No documents or follow-up behind supplier answers.

No contract clauses

Supplier contracts do not include modern slavery commitments.

Statement written once a year

Evidence pulled together at the last minute.

Statement not approved properly

Statement not approved by the board or not signed by a director.

No measures of effectiveness

The statement describes policies but gives no indicators showing whether they work.

Homepage link missing

The statement is published but not linked prominently from the homepage.

Remediation not followed through

Issues found at suppliers have no owner, deadline or record of outcome.

Evidence you can produce

  • Supply chain map
  • Supplier questionnaires
  • Audits and certifications
  • Risk ratings with reasons
  • Contract clauses
  • Remediation actions
  • Statement support pack
  • Board approval of the statement
  • Year-on-year performance indicators

Common questions

See Trestec on your own supplier list.