A modern slavery statement is, for many companies, the most visible expression of their approach to forced labour and human trafficking. 

It is read by investors, customers, NGOs, regulators, and increasingly by other companies assessing their supply chains. And it is subject to a growing body of scrutiny that looks beyond what a statement says to what it demonstrates. 

The gap between the two — between describing processes and evidencing action — is where most statements fall short. Research consistently shows that the majority of published statements, even from large, well-resourced companies, do not meet the quality bar set by current best practice guidance, let alone where regulation is heading. 

This page sets out what a modern slavery statement needs to cover, what distinguishes a strong statement from a weak one across each of the six recommended areas, how to approach the statement as part of an ongoing programme rather than an annual compliance exercise, and how to use ETI’s evaluation framework to assess and improve your own statement before publication. 

For context on what the law requires and which companies are in scope, see: Modern slavery legislation: what businesses need to know.

What a modern slavery statement is — and what it is not 

A modern slavery statement is not a guarantee that modern slavery is absent from your supply chain. The UK Home Office guidance, the Australian Modern Slavery Act guidance, and ETI’s own evaluation framework all recognise that no company can make this claim credibly — the scale and depth of global forced labour risk makes it an unrealistic and ultimately unhelpful assertion. 

What a statement is — and what it should demonstrate — is that your organisation understands where forced labour risks exist in its operations and supply chains, has taken meaningful steps to address them, and is committed to continuous improvement over time. 

This distinction matters. Organisations that approach the statement as a guarantee to be defended tend to produce vague, hedged documents that disclose little and demonstrate less. Organisations that approach it as an honest account of where they are, what they have done, and where the gaps remain tend to produce statements that are more useful, more credible, and — as regulatory expectations tighten — more defensible.  

Who needs to produce a statement 

The UK Modern Slavery Act requires commercial organisations with annual turnover of £36 million or more that supply goods or services in the UK to produce a statement annually. Australia requires entities with consolidated annual revenue of at least AUD $100 million. Canada requires in-scope entities to report by 31 May each year. 

Even where a legal obligation does not apply, many companies produce statements voluntarily — because customers, investors, and public sector procurement teams increasingly expect them. The March 2025 update to UK Home Office guidance encourages all organisations to upload their statements to the government registry, regardless of whether they are in scope of the legal requirement. 

For a full breakdown of which companies are in scope of which laws across multiple jurisdictions, see: Modern slavery legislation: what businesses need to know.

The six areas a statement should cover 

The UK Modern Slavery Act sets out six recommended areas for disclosure. These are closely mirrored in Australian, Canadian, and California reporting requirements, making them a practical common framework for companies reporting across multiple jurisdictions. 

1. Your organisation’s structure, business, and supply chains 

A statement should give the reader enough context to understand your organisation’s footprint and what that means for forced labour risk. This is not a marketing exercise — it is the foundation on which everything else in the statement rests. 

What to include: 

• The structure of your organisation, including subsidiaries, joint ventures, and entities covered by the statement
• Where you operate geographically and in which sectors
• An overview of your supply chains — the types of suppliers you work with, which countries you source from, how many suppliers you have, and which categories carry the highest risk
• Any material gaps in your supply chain knowledge — particularly at lower tiers — and how you are working to address them 

The quality gap: Many statements describe the business at a high level without connecting that description to forced labour risk. A statement that lists sourcing countries without noting which of those carry elevated risk, or that refers to “thousands of suppliers” without any indication of how they are categorised or assessed, provides little usable information. The updated UK guidance explicitly expects companies to identify the unknown aspects of their supply chains — acknowledging gaps is a mark of honesty, not a weakness. 

2. Policies in relation to slavery and human trafficking 

This section should demonstrate that your organisation has a coherent policy position on forced labour, grounded in recognised standards, and that those policies are communicated and applied in practice — not just held on a server somewhere. 

What to include: 

• Your human rights or modern slavery policy, and how it aligns with international standards including the ETI Base Code, the UN Guiding Principles on Business and Human Rights, and ILO Conventions
• Your supplier code of conduct and how forced labour expectations within it are communicated to suppliers -
• Your recruitment policy — specifically, adherence to the Employer Pays Principle (no worker should pay fees to access employment) and how this is applied across direct operations and supply chains
• Internal policies relevant to modern slavery — including whistleblowing, grievance mechanisms, and responsible purchasing 

The quality gap: Policies without implementation evidence are unconvincing. Statements that list a suite of policies without describing how they are applied, monitored, or updated over time — and without connecting them to the actual risks identified in the supply chain — provide limited assurance. The question a strong statement answers is not “do we have a policy” but “how does this policy affect what happens in practice.” 

3. Risk assessment, prevention, and mitigation 

This is the section that most often determines whether a statement reads as a genuine risk management document or as a compliance exercise. It should demonstrate that your organisation has systematically identified where forced labour risks are highest in your operations and supply chains, and has taken proportionate action to address them. 

What to include: 

• Your risk assessment methodology — how you identify forced labour risk, what data and tools you use, how frequently assessments are conducted, and who is responsible
• The risks you have identified — including specific geographies, sectors, supplier categories, and labour practices that present the highest risk to workers
• The steps taken to prevent and mitigate those risks — including supplier engagement, capacity building, worker voice mechanisms, and changes to your own purchasing practices
• How risk assessment is integrated into supplier onboarding and ongoing supplier management 

The quality gap: Risk assessment sections are among the most commonly weak areas in published statements. Generic descriptions of audit programmes, without any indication of what risks were found or how they were addressed, are not evidence of risk management — they are evidence of process. A strong statement names the risks it has identified and describes what was done in response. If no risks have been identified, this should prompt reflection on whether the assessment methodology is fit for purpose. 

For practical guidance on what forced labour risk assessment should involve, see: How to identify forced labour in your supply chain. 

4. Due diligence processes 

This section should describe the systematic processes your organisation uses to prevent and address forced labour across its value chain — going beyond periodic audit to encompass the full range of engagement, monitoring, and improvement activities. 

What to include: 

• How you conduct supplier due diligence — at onboarding, at regular intervals, and in response to identified concerns
• Your approach to social auditing, its role in your overall due diligence system, and its limitations in detecting forced labour specifically
• How you engage with suppliers beyond auditing — including training, collaborative improvement programmes, and long-term relationship-building
• Your approach to worker voice — grievance mechanisms, confidential reporting channels, and engagement through trade unions and civil society
• How your purchasing practices support rather than undermine supplier compliance — including payment terms, lead times, and price negotiations
• Steps taken in response to due diligence findings — what happened when issues were identified 

The quality gap: Due diligence sections that describe auditing as the primary mechanism without acknowledging its limitations — particularly for detecting forced labour — are increasingly likely to attract scrutiny from investors and civil society. The March 2025 UK guidance, the CSDDD framework, and ETI’s evaluation framework all emphasise the importance of worker-centred approaches alongside formal audit processes. 

5. Effectiveness, measured against appropriate KPIs 

This is the section where the shift from description to evidence is most clearly visible — and where the majority of statements are weakest. Regulators, investors, and civil society are increasingly focused on this section as the test of whether a company is managing forced labour risk or simply reporting on the appearance of doing so. 

What to include: 

• The key performance indicators your organisation uses to measure progress — including both activity metrics (training completed, suppliers assessed, grievances received) and outcome metrics (issues identified, remediated, and followed up)
• Your performance against those KPIs during the reporting period, including where targets were not met and why - How you assess the effectiveness of your due diligence — not just whether processes were completed, but whether they are working
• How your approach has changed in response to what you have learned 

The quality gap: Many statements include KPIs that measure activity rather than outcomes — the number of suppliers audited, rather than what the audits found; the number of training sessions delivered, rather than whether behaviour changed as a result. The updated UK guidance encourages companies to move toward outcome-based measurement and to demonstrate continuous improvement over successive statements, not just repeat the same figures year after year. 

6. Training and capacity building 

Training is the mechanism through which modern slavery policy becomes embedded in the behaviour of the people who make sourcing, procurement, and supplier management decisions. This section should demonstrate that training is targeted, relevant, and connected to the specific risks your organisation faces. 

What to include: 

• Who receives modern slavery training within your organisation — including which functions (procurement, sustainability, legal, HR, logistics) and at what level
• What the training covers — including practical application to your specific supply chain risks, not just generic awareness
• How training is delivered, updated, and refreshed
• How you support suppliers to build capacity on forced labour identification and prevention
• Any training made available to workers in your supply chains 

The quality gap: Generic e-learning modules delivered to all staff without tailoring to specific roles or risks are frequently cited as a weakness in assessed statements. Training that equips procurement teams to understand how their decisions affect forced labour risk in supplier facilities is substantially more valuable than awareness training that treats modern slavery as an abstract concept unrelated to day-to-day commercial decisions.  

Beyond the six areas: what distinguishes a strong statement 

The six-area framework is the baseline, not the ceiling. The companies whose statements attract genuine respect from investors, civil society, and regulators tend to share several characteristics that go beyond section-by-section compliance: 

They are honest about what they don’t know. Strong statements acknowledge gaps in supply chain visibility, limitations of their current due diligence methodology, and areas where progress has been slower than hoped. This honesty is a marker of credibility, not weakness. 

They demonstrate continuity and progression. A statement that can be compared to the previous year’s — showing how risks identified have been addressed, how KPIs have moved, how the approach has developed — demonstrates genuine engagement. Statements that look the same year after year suggest process without progress. 

They connect disclosure to action. The strongest statements are those where the risks described in section 3 are clearly connected to the due diligence activities in section 4, which are measured by the KPIs in section 5, and which have informed the training described in section 6. Internal coherence across the six areas is a mark of a statement that reflects a real programme, not a series of disconnected disclosures. 

They disclose what was found. Companies are often reluctant to report modern slavery findings for fear of reputational damage or legal exposure. In practice, investors and civil society are far more concerned by companies that claim never to have found any issues in complex, high-risk supply chains than by companies that report findings alongside credible remediation responses. The UK guidance explicitly encourages transparency about incidents and responses. 

They reflect worker perspectives. A statement that describes due diligence without any reference to what workers have reported — through grievance mechanisms, worker surveys, or civil society engagement — is describing a system that looks inward, not one that engages with the people most affected by forced labour risk.  

Using ETI’s Modern Slavery Statements Evaluation Framework 

ETI has developed a structured evaluation framework that allows companies to assess the quality of their modern slavery statement against best practice standards across all six areas. The framework is used both by companies reviewing their own statements and by civil society organisations and investors benchmarking statements across peers. 

The framework is structured in six areas — mirroring the UK Government’s statutory guidance — and sets out key content principles for each, along with detailed suggested information to include. It provides a best practice standard that is appropriate and proportionate to the reporting organisation, recognising that different organisations have different resources, knowledge, and experience. 

The framework’s overarching principles are that statements should: be specific to modern slavery; be detailed and well-evidenced; align with relevant best practice and international standards; be open and transparent about uncertainties; demonstrate continuous progress; and include steps to prevent modern slavery in the long term, not just mitigate short-term risks. 

Using the framework before finalising your statement helps identify where disclosures are thin, where the connection between risk and action is unclear, and where the language is too generic to be meaningful. Given that ETI is planning to refresh the framework, it is worth checking the current version directly before use. 

Access ETI’s Modern Slavery Statements Evaluation Framework 

Practical guidance for the drafting process 

Start with the programme, not the statement. A statement that reflects genuine activity is far easier to write than one that tries to construct a narrative from limited evidence. If the statement feels difficult to complete credibly, that is often a signal that the underlying programme needs development, not that the statement needs better wording. 

Involve the right internal stakeholders. Modern slavery statements that reflect only the sustainability team’s perspective tend to miss important dimensions — particularly around purchasing practices and supplier relationships, which are central to forced labour risk but owned by procurement and commercial functions. Effective statements require input from across the business. 

Allow sufficient time for review. The statement must be approved by the board and signed by a director (under the UK Modern Slavery Act). Building in time for meaningful board engagement — not just sign-off — is both good practice and an increasingly expected marker of seriousness. 

Plan for the next statement while writing this one. An effective approach treats each statement as part of a multi-year journey. Note where gaps in evidence or supply chain knowledge exist, and build those as priorities for the coming year. A statement that commits to specific improvements and then reports on them the following year demonstrates credibility in ways that generic commitments to “continuous improvement” do not. 

Upload to the government registry. The UK government’s modern slavery statement registry makes statements searchable and comparable. The March 2025 guidance encourages all organisations to upload, regardless of whether the legal requirement applies to them. Uploading demonstrates transparency and makes it easier for investors, customers, and civil society to engage with your disclosures.  

Multi-jurisdictional reporting: UK, Australia, and Canada 

Companies with obligations in more than one jurisdiction will find that the six-area framework largely satisfies the content requirements of all three. The March 2025 UK Home Office guidance includes an international reporting template specifically designed to support companies reporting under the UK, Australian, and Canadian frameworks simultaneously. 

The key differences to be aware of: 

• Australia requires reporting against seven mandatory criteria rather than six recommended areas, and expects explicit consideration of the entity’s operations and supply chains rather than just the parent company
• Canada requires entities to report on the steps taken to prevent and reduce forced labour and child labour — the explicit inclusion of child labour is a distinction from the UK framework
• Submission deadlines differ: UK statements should be published within six months of the financial year end; Canadian reports must be submitted to the government by 31 May each year; Australian statements are due within five months of the financial year end  

Frequently asked questions 

Is our modern slavery statement legally required? If your organisation supplies goods or services in the UK and has annual turnover of £36 million or more, yes — under Section 54 of the Modern Slavery Act 2015. Similar obligations apply in Australia (AUD $100 million threshold) and Canada (specific entity criteria). If you are below these thresholds but are a supplier to companies above them, you may face indirect pressure to produce a statement through customer requirements. 

What are the penalties for not producing a statement? Under the current UK law, there are no direct financial penalties for failing to produce a statement. However, the government has committed to reviewing this, and non-compliant companies can be named publicly. The Procurement Act 2023 also gives government contracting authorities stronger grounds to exclude suppliers from public contracts where modern slavery failings are identified. In Australia, the Modern Slavery Act is being reviewed with a view to introducing penalties. 

How long should a modern slavery statement be? There is no prescribed length. The UK guidance notes that statements can be succinct while still covering all relevant points. A statement that covers the six areas with specificity and evidence will naturally be longer than one that offers generic descriptions — but length is not the goal. Clarity, specificity, and connection between sections matter more than word count. 

Should we report on incidents of modern slavery we have found? Yes — and increasingly, yes. Investors and civil society are highly sceptical of companies that claim never to have identified any forced labour risks despite complex, high-risk supply chains. The March 2025 UK guidance explicitly encourages transparency about findings and the responses to them. A well-described incident response — focused on worker welfare and remediation — is a mark of a mature programme, not a liability. 

Can we produce a combined statement covering multiple entities? Yes. The UK Modern Slavery Act allows parent companies to produce a single statement covering their subsidiaries, provided it is clear which entities are covered. This is common practice for large corporate groups. The statement should be clear about which entities are included and whether they have been assessed separately. 

How does a modern slavery statement relate to our HRDD obligations under the CSDDD? For companies in scope of the CSDDD, the statement and the due diligence programme should be closely connected — the statement is, in part, the public account of what the due diligence system has found and done. Under the CSDDD, reporting is primarily through the Corporate Sustainability Reporting Directive (CSRD) rather than a standalone statement, but the substantive content — risk identification, mitigation measures, worker engagement, effectiveness assessment — aligns closely. Companies already producing strong modern slavery statements are well-placed to meet CSDDD reporting expectations.  

Further reading in this cluster 

What is modern slavery? Definitions, forms and scale 
How to identify forced labour in your supply chain
Modern slavery legislation: what businesses need to know
Forced labour & modern slavery: a complete guide for business
ETI Modern Slavery Statements Evaluation Framework 

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Modern slavery statements: evaluation framework

A tool to assess the quality of modern slavery statements.

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