Section 54: transparency in supply chains

Section 54 of the Modern Slavery Act 2015 is the part of the law aimed squarely at business. It requires commercial organisations that carry on business in the UK and have an annual turnover of £36 million or more to publish a modern slavery statement every financial year.

What the statement must do

The statement must set out the steps the organisation has taken during the year to ensure slavery and human trafficking are not taking place in its own business or in its supply chains. If it has taken no steps, it must say so, a statement to that effect is technically permitted, though commercially it is a poor look.

The statement must be approved at the top of the organisation, for example by the board and signed by a director, and published prominently, with a link on the organisation's website homepage.

What good statements cover

The Act suggests areas a statement may cover, including:

• 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 risk is highest, and how that risk is managed.
• The training available to staff.
• How it measures whether its steps are effective.

Why it matters below the threshold

If your organisation is under the £36 million threshold, section 54 may still reach you indirectly. Large customers increasingly push obligations down their supply chains, asking smaller suppliers to confirm their own practices, complete questionnaires, or accept anti-slavery clauses in contracts. Being able to answer those questions honestly and well is becoming part of winning and keeping business, whatever your size.

The deeper point of section 54 is cultural. It forces large organisations to look at their supply chains, ask uncomfortable questions, and put their name to the answers in public.