Category: Regulatory Frameworks

Slavery and Human Trafficking Statement

Also known as: Modern Slavery and Human Trafficking Statement, Statement on Slavery and Human Trafficking, Anti-Slavery and Human Trafficking Statement, Modern Slavery Statement

Simply put

A Slavery and Human Trafficking Statement is a public document in which an organization describes the steps it has taken to identify and address the risk of modern slavery and human trafficking within its own operations and its supply chain. It typically explains what an organization has done during a given financial year, such as assessing risks and implementing policies. It is generally a disclosure of steps taken rather than a guarantee that slavery or trafficking is absent.

Formal definition

A Slavery and Human Trafficking Statement is a formal, typically annual disclosure setting out the actions an organization has taken to identify, assess, and mitigate the risk of modern slavery and human trafficking across its business and supply chain, often covering a defined financial year. In some jurisdictions such statements are made pursuant to specific legislation, for example, section 54(1) of the UK Modern Slavery Act 2015, and are prepared to satisfy the reporting obligations of that regime; requirements and applicability vary by jurisdiction and are not globally uniform. The statement covers the steps and efforts undertaken (such as policy adoption, risk understanding, and supply chain measures) and constitutes an attestation of process rather than independent verification that slavery or trafficking is absent; its scope is generally limited to the reporting organization's own operations and the supply chain visibility it has, which in practice may not extend fully beyond the first tier.

Why it matters

For third-party and supply chain risk professionals, a Slavery and Human Trafficking Statement is both a compliance artifact and a signal of how seriously a counterparty treats human rights risk in its extended supply network. Because the statement is a disclosure of steps taken rather than a guarantee that slavery or trafficking is absent, its value lies in what it reveals about an organization's due diligence maturity: whether it has assessed risk, adopted relevant policies, and put supply chain measures in place. Statements that describe concrete actions, risk assessment, policy adoption, and supplier engagement, are more informative than boilerplate language that merely asserts a commitment without evidence of process.

The statement also matters because its scope is generally limited to the reporting organization's own operations and the supply chain visibility it actually has. In practice, that visibility often does not extend fully beyond the first tier, which means modern slavery risks concentrated in lower tiers of the supply chain may fall outside what a statement can meaningfully address. Risk teams relying on a counterparty's statement should treat it as an attestation of process, not as independent verification, and should not assume that the presence of a statement confirms the absence of forced labor or trafficking in deeper tiers.

Regulatory context adds further weight. In some jurisdictions the statement is prepared to satisfy a specific legal reporting obligation, for example, statements made pursuant to section 54(1) of the UK Modern Slavery Act 2015. Requirements, thresholds, and applicability vary by jurisdiction and are not globally uniform, so a statement that satisfies one regime may not meet the expectations of another. Professionals assessing partners across multiple regions should account for this variation rather than treating any single regime as a global standard.

Who it's relevant to

Procurement and Sourcing Teams

Procurement professionals use a supplier's statement as one input when evaluating human rights risk in sourcing decisions. Because the statement documents steps taken rather than confirming the absence of slavery or trafficking, it should inform, not replace, supplier due diligence, particularly for tiers beyond the first, where the reporting organization's visibility may be limited.

Compliance and Legal Functions

Compliance and legal teams are often responsible for preparing their own organization's statement and for assessing whether counterparties meet applicable reporting obligations. Where a statement is made under legislation such as section 54(1) of the UK Modern Slavery Act 2015, these functions must track requirements that vary by jurisdiction and cannot assume that one regime's obligations apply globally.

ESG and Human Rights Analysts

Analysts assessing a partner's human rights performance can use the statement to gauge due diligence maturity, looking for described risk assessments, policy adoption, and supply chain measures rather than generic commitments. They should treat the statement as an attestation of process rather than independent verification of outcomes.

Third-Party Risk Managers

TPRM practitioners incorporate a counterparty's statement into onboarding and periodic review, recognizing that it is a point-in-time, self-reported disclosure that can become stale between annual updates. Its scope is generally bounded by the counterparty's own operations and first-tier visibility, so it should be corroborated with additional monitoring where risk tiers warrant.

Inside Slavery and Human Trafficking Statement

Organizational structure and supply chain description

A summary of the reporting entity's business, its organizational structure, and the nature of its supply chains, providing context for where modern slavery and trafficking risks may arise. This typically describes the business at a high level rather than mapping every tier of the supply chain.

Policies relating to slavery and human trafficking

An account of the internal policies the organization maintains to address forced labor, servitude, and human trafficking, such as codes of conduct or supplier standards. A stated policy reflects commitment but does not by itself evidence operational enforcement.

Due diligence processes

A description of the due diligence undertaken across operations and supply chains to identify and address modern slavery risks. In many programs this focuses on direct suppliers and may have limited visibility into fourth-party or lower-tier relationships.

Risk assessment and management

An explanation of how the organization identifies which parts of its business and supply chains carry higher risk, and the steps taken to manage those risks. This should be distinguished from a completed risk assessment questionnaire, which is an input rather than the assessment itself.

Effectiveness measures and KPIs

Any indicators the organization uses to measure how effective its actions have been in ensuring slavery and trafficking are not occurring. These measures vary widely between organizations and are often self-defined.

Training and capacity building

A description of training provided to staff and, where relevant, to suppliers to help identify and respond to indicators of forced labor and trafficking.

Approval and sign-off

Confirmation that the statement has been approved and signed by the appropriate senior governance body or director, which is generally an expectation of the disclosure regimes requiring such statements.

Common questions

Answers to the questions practitioners most commonly ask about Slavery and Human Trafficking Statement.

Does publishing a slavery and human trafficking statement certify that an organization's supply chain is free of forced labor?

No. The statement is a disclosure document, not a certification or a guarantee of a slavery-free supply chain. In many regimes the underlying obligation is to describe the steps an organization has taken (or to state that it has taken none), not to prove the absence of forced labor. A statement attests to disclosed activity; it does not independently verify conditions across suppliers, and it does not confer compliance assurance about actual labor practices, particularly beyond the first tier.

Is a slavery and human trafficking statement the same as the underlying due diligence work it references?

No. The statement is a summary output that may describe policies, risk assessments, and monitoring, but it is distinct from the substantive due diligence itself. A published statement can exist alongside limited or superficial underlying work, so the presence of a statement should not be read as evidence of the depth or effectiveness of the controls it describes. Reviewers typically need to examine the underlying activity rather than relying on the statement as a proxy for it.

Who within an organization is typically responsible for preparing and approving the statement?

Responsibilities vary by program and jurisdiction, but in many organizations preparation is led by legal, compliance, procurement, or sustainability functions, drawing on inputs from third-party risk and human resources. Depending on the applicable regime, the statement may require sign-off by a senior governing body or director-equivalent and formal approval before publication. Because approval and signature expectations differ across regions and sectors, organizations generally confirm the specific requirements applicable to each entity that must report.

How often should the statement be updated?

Update frequency depends on the applicable regime, but statements are commonly refreshed on an annual basis tied to a financial year or reporting period. Because a statement reflects a point in time, it can become stale as supplier relationships, risk exposures, and remediation activity change between publications. Some programs supplement the periodic statement with interim reviews when significant changes occur, though this is typically a matter of internal practice rather than a uniform obligation.

What content is typically expected in the statement, and what commonly falls outside its scope?

Depending on the regime, statements often describe organizational structure and supply chains, relevant policies, risk assessment approaches, due diligence and monitoring steps, training, and how effectiveness is measured. What frequently falls outside scope is detailed supplier-level data, assurance over lower supply chain tiers, and independent verification of the described steps. A statement generally documents the organization's own account of its activity rather than validating conditions at individual suppliers.

How does the statement relate to broader third-party and supply chain risk processes?

The statement typically draws on existing due diligence, onboarding, and ongoing monitoring processes rather than replacing them. In many programs it functions as a reporting layer over supplier risk assessment and monitoring activity, and its credibility depends on the substance of those underlying controls. Because visibility often diminishes beyond the first tier, the statement may reflect limited assurance over deeper supply chain levels even where first-tier processes are more developed.

Common misconceptions

Publishing a Slavery and Human Trafficking Statement demonstrates that an organization's supply chain is free of modern slavery.

The statement is a transparency and disclosure mechanism describing what actions have been taken; it is not a certification or guarantee of compliant conditions. Depending on the applicable regime, an organization may satisfy the disclosure requirement even while acknowledging gaps or limited progress.

The statement covers the organization's full multi-tier supply chain.

Statements often reflect direct (third-party) relationships and higher-risk areas, with limited visibility into lower-tier, fourth-party, or Nth-party suppliers. Coverage typically narrows the further one moves from the first tier.

A single such statement satisfies obligations everywhere the organization operates.

Disclosure expectations differ across jurisdictions and sectors in terms of thresholds, required content, and approval formalities. A statement that meets one region's requirements may not satisfy another's, so jurisdiction-specific review is generally needed.

Best practices

Describe risk on a tiered basis, being explicit about where visibility exists and where it ends beyond direct suppliers, rather than implying full multi-tier coverage.

Distinguish stated policies from evidence of enforcement by reporting due diligence activities, findings, and remediation actions rather than commitments alone.

Include effectiveness measures or KPIs and, where possible, show trends over successive reporting periods so readers can gauge progress rather than intent.

Confirm approval and sign-off by the appropriate senior body and document the date and approver in line with the applicable disclosure regime.

Review the statement against the specific requirements of each jurisdiction in which the entity is obligated to report, as content and approval expectations vary.

Treat the statement as a point-in-time disclosure and refresh it on the required cycle, noting that self-reported information should be complemented by ongoing monitoring rather than a single onboarding assessment.