Modern Slavery Act Compliance: What We’ve Learnt So Far

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What is the judgement on the statements so far? Photo credit Green MPs @ Flickr
What is the judgement on the statements so far?
Photo credit Green MPs @ Flickr

From its inception nearly a year ago, the UK Modern Slavery Act (MSA) has presented businesses with an exciting opportunity: a chance to lead the fight against modern slavery and forced labour.

To review, Section 54 of the MSA requires that all companies with a turnover of over £36m that run some activity in the UK issue a yearly statement indicating the steps the organisation has taken (or not) to ensure that slavery and human trafficking is not taking place.

Although there is no direct penalty for businesses not tackling potential slavery issues, the government hopes pressure from the media and the public will encourage companies to champion awareness, transparency, and anti-slavery efforts within their organisation and their supply chains.

A few months under the MSA and about 100 statements later, here’s what we’ve learnt so far:

Businesses are having serious issues with compliance

According to analysis by the Business and Human Rights Resource Center, only 22 of 83 evaluated statements meet the MSA’s two legal requirements: an authorizing signature from an executive figure and a link to the statement in a prominent place on the website’s homepage (54(6) & (7)). Additionally, only 9 companies included information from all six of the MSA’s six recommended areas of disclosure.

Nearly all the statements are brief

Companies are struggling with the letter and the spirit of the Modern Slavery Act.

A recent report by Ergon Associates found 90% of published statements are under 1000 words, and many statements don’t go beyond general disavowals of slavery and broad overviews of company policy.

There are clear frontrunners

Although the majority of statements published so far have been disappointing, a few companies have taken the lead in the fight against modern slavery. Specifically, Ford and Intel have published very detailed statements, providing a strong example of industry leaders taking modern slavery in the supply chain seriously.

Trafficking prosecutions are on the rise

Since the MSA’s introduction in April to the end of December 2015, the Crown Prosecution Service reported 12 slavery and trafficking prevention orders – a number falling only four short of the orders issued in the 12 months before the act.

Prosecutors from all four parts of the UK have pledged support to a new anti-human trafficking action plan. According to an official release, the plan commits “respective organisations to work together in order to react to the changing nature of trafficking around the world.”


This has been a slow start for the modern slavery act and in particular when it comes to clause 54 on transparency in the supply chain. As time goes by the hope is that best practices will emerge, paving the way for increasingly better statements and industry standards.


Business and Human Rights Resource Center - Statements Analysis


Ergon Associates - Statements Analysis