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What the New Guidelines on Modern Slavery Laws Mean for Your Supply Chain

The UK Government has issued updated guidance on the Modern Slavery Act 2015, marking the first substantial clarification since its introduction. While the law itself remains unchanged, the new guidelines provide clearer direction on which organisations are affected and the steps needed to ensure compliance.

For businesses—particularly those with large, international supply chains—this signals a renewed focus on corporate accountability and ethical sourcing.

What Is Modern Slavery – And Why Should Your Business Care?

Modern slavery refers to the exploitation of individuals for commercial gain through coercion, deception, or force. It includes practices such as forced labour, human trafficking, debt bondage, and forced marriage.

Though often thought of as a historical issue, modern slavery remains widespread—particularly within global supply chains and outsourced operations. In fact, the Home Office reported a 13% rise in modern slavery referrals in 2024, the highest since records began. This increase highlights a growing need for businesses to take proactive steps toward compliance.

For businesses, the stakes are higher than ever. Involvement in modern slavery—directly or indirectly—can lead to far-reaching consequences, including reputational damage, investor concerns, and pressure from stakeholders demanding greater transparency and due diligence.

Modern slavery frequently lurks within vertical supply chains, particularly in situations where:

  • Temporary labour or agency staff are employed;
  • There are seasonal or unexpected spikes in demand;
  • Contractors are engaged for construction, maintenance, or cleaning services;
  • Profit-driven procurement places undue pressure on suppliers with limited oversight.

Companies can be implicated in modern slavery practices even if the exploitation occurs far down the supply chain, far beyond their immediate control.

Your Legal Obligations Under Section 54 MSA 2015

The Modern Slavery Act 2015 (MSA) sets out specific obligations for businesses, particularly those that:

  • Are a body corporate or partnership (regardless of where they are formed);
  • Operate or conduct part of their business in the UK;
  • Supply goods or services;
  • Have an annual turnover of £36 million or more.

These organisations are required to produce a Modern Slavery Statement each financial year, which must:

  • Outline the steps taken to assess and address modern slavery risks within their operations and supply chains;
  • Be approved by the board of directors (or equivalent governance body) and signed by a director or designated member;
  • Be published on the organisation’s website, with a clear and easily accessible link to the statement and the Home Office guidelines.

Although non-compliance doesn’t yet carry direct legal penalties, the regulatory landscape is evolving, and the reputational damage from failing to act could be severe.

Practical Steps to Protect Your Business

Legal compliance is only part of the story—proactive risk management is key. Here are some recommended actions for businesses looking to protect themselves:

  • Incorporate robust anti-slavery clauses in all supply chain contracts;
  • Include audit rights and clear termination provisions for any breaches;
  • Develop a supplier code of conduct that aligns with anti-slavery commitments;
  • Conduct regular risk assessments and due diligence checks across all tiers of your supply chain.

Taking these steps not only protects your business’s reputation and strengthens your ESG (Environmental, Social, and Governance) standing but also positions you as a leader in ethical trade and governance.

How Berry Smith Can Help

At Berry Smith, we bring deep expertise in drafting tailored anti-slavery provisions, contractual clauses, and compliance frameworks. We assist businesses across various sectors in reviewing their supply chain arrangements, implementing governance policies, and preparing for potential regulatory changes.

Whether you’re preparing your next Modern Slavery Statement or reviewing supplier contracts, our commercial and legal team is ready to help you navigate these important updates with confidence.