Modern Slavery Act supply chain compliance: turnover threshold for businesses lowered

Modern Slavery Act supply chain compliance: turnover threshold for businesses lowered


Author: Ron Reid

Applies to: UK wide

The UK government's commitment to anti-slavery and supply chain transparency was confirmed in a speech given by prime minister David Cameron in Singapore.

The prime minister stated: 'From October, we will also require all businesses with a £36 million turnover or above to disclose what they are doing to ensure their business and supply chains are slavery free. This measure is one of the first of its kind in the world and it will be a huge step forward, introducing greater accountability on business for the condition of their supply chains'.

We reported on the key sections of the legislation and its implications for commercial businesses who carry on business in the UK. The threshold appears to have been significantly lowered from the previously expected level to £36m which means more businesses will be affected.

Although much of the legislation is now in force, the provisions relating to supply chain transparency are expected to be implemented in October 2015. The government is yet to publish guidance for compliance.

Act now - practical tips

It is important for businesses (particularly those with a turnover of £36m) to act now to ensure compliance.

Although the guidance has yet to be published, businesses can prepare by taking the following practical steps now:

  • assure yourself of the working practices of those you have a direct contractual arrangement with
  • make it clear that you only allow subcontracting either with the approval of your business or with companies having a zero tolerance to forced / child labour
  • train your buyers and those involved in procurement to make them aware of these forthcoming changes.
  • add compliance with these issue to any audit regime of suppliers that you may have in place

By the end of this financial year businesses are going to need information and policies in place to be able to prepare a statement.

If you are in any doubt about what to do, please contact Ron Reid, or a member of our dispute resolution and compliance team.


This document is for informational purposes only and does not constitute legal advice. It is recommended that specific professional advice is sought before acting on any of the information given.

About the author

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Ronald Reid


03700 868471

Ron is a consultant with Shoosmiths having previously headed the regulatory & compliance team advising clients on non contentious matters as well as those facing investigation or prosecution for breaches of regulatory legislation. He has considerable experience of crisis management. He has over 40 years' experience including having prosecuted complex matters on behalf of the Health and Safety Executive giving him considerable insight into the enforcement process and the major causes of prosecution.

Ron also formed part The Law Society Steering Group on the Modern Slavery Act practice note and spoke alongside Kevin Hyland, OBE, at the Law Society on the 6th December 2016.

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