Modern Slavery Statement
Supply chain transparency disclosure detailing steps taken to prevent human trafficking in operations.
What is a Modern Slavery Statement?
Supply chain transparency disclosure detailing steps taken to prevent human trafficking in operations.
Regulators across UK, Australia, EU treat a Modern Slavery Statement as a baseline legal requirement. Without one, your business is immediately exposed to enforcement action — regardless of size or industry.
Who Needs a Modern Slavery Statement?
Large entities operating in the UK, Australia, or EU (typically £36M+ or $100M+ revenue).
- Any organisation that large entities operating in the uk, australia, or eu (typically £36m+ or $100m+ revenue)
- Businesses operating in UK and Australia
- Anyone using third-party services that process data on your behalf
Legal Framework
Mandated by the Modern Slavery Act 2015 (UK) and Modern Slavery Act 2018 (AU).
UK
UK GDPR — ICO enforcement
Australia
Privacy Act 1988
EU
EU GDPR — up to €20M or 4% turnover
What Your Modern Slavery Statement Must Include
- 1
Organizational Structure & Supply Chains
Organizational Structure & Supply Chains — Clearly define organizational structure & supply chains so users and regulators understand its scope and why it matters for your compliance obligations.
- 2
Policy Framework
Policy Framework — Clearly define policy framework so users and regulators understand its scope and why it matters for your compliance obligations.
- 3
Due Diligence Processes
Due Diligence Processes — Clearly define due diligence processes so users and regulators understand its scope and why it matters for your compliance obligations.
- 4
Risk Assessment & Management
Risk Assessment & Management — Clearly define risk assessment & management so users and regulators understand its scope and why it matters for your compliance obligations.
- 5
Performance Indicators (KPIs)
Performance Indicators (KPIs) — Clearly define performance indicators (kpis) so users and regulators understand its scope and why it matters for your compliance obligations.
- 6
Staff Training & Awareness
Staff Training & Awareness — Clearly define staff training & awareness so users and regulators understand its scope and why it matters for your compliance obligations.
How to Write a Modern Slavery Statement
Building a compliant Modern Slavery Statement from scratch takes legal expertise and hours of research. Here is a framework covering the core steps:
- 1Step 1: Organizational Structure & Supply Chains — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 2Step 2: Policy Framework — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 3Step 3: Due Diligence Processes — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 4Step 4: Risk Assessment & Management — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 5Step 5: Performance Indicators (KPIs) — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 6Step 6: Staff Training & Awareness — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 7Final step: Legal review — Review with qualified legal counsel before publishing, especially if operating in high-risk jurisdictions.
Common Mistakes to Avoid
Copying another website's Modern Slavery Statement verbatim — Every business has different data flows. A generic copy may fail to disclose what you actually do, creating false statements that are worse than no policy at all.
Using vague or ambiguous language — Regulators and courts expect plain, specific language. Phrases like "we may share your data with partners" are too vague and regularly cited in enforcement actions.
Forgetting to update after product changes — Your Modern Slavery Statement must reflect current practice. Outdated policies are a compliance liability — some regulators treat an outdated policy as a violation in itself.
Not making your Modern Slavery Statement easy to find — Buried in a footer or behind multiple clicks, your policy may not meet the "easily accessible" standard required by most regulations.
Missing jurisdiction-specific requirements — A policy compliant in one jurisdiction may still fail in another. If you operate across UK and Australia, you need to address each framework's specific requirements.
How Often Should You Update Your Modern Slavery Statement?
At minimum, review your Modern Slavery Statement once a year — and immediately whenever you: change the data you collect, add new third-party tools, enter new jurisdictions, or experience a data incident.
Consequences of Non-Compliance
Beyond financial penalties, non-compliance with Modern Slavery Statement requirements can result in: reputational damage and loss of customer trust, app store removal (for mobile apps), inability to process payments (for ecommerce), and difficulty attracting enterprise customers who require compliance evidence.
Frequently Asked Questions
Is a Modern Slavery Statement legally required?
Yes. A Modern Slavery Statement is a legal requirement under Mandated by the Modern Slavery Act 2015 (UK) and Modern Slavery Act 2018 (AU).. Operating without one puts your business at risk of regulatory enforcement action.
How long should a Modern Slavery Statement be?
A typical Modern Slavery Statement runs 5 pages. Length matters less than completeness — every required disclosure must be present, written in plain language that users can understand.
How often should I update my Modern Slavery Statement?
At minimum, review your Modern Slavery Statement once a year — and immediately after any business change.
What are the penalties for not having a Modern Slavery Statement?
Injunctions by the Secretary of State, public shaming, and exclusion from government contracts.
Can I use a free Modern Slavery Statement template?
Free templates are a starting point, not a solution. A template that was not drafted for your specific business, jurisdiction, and data practices may create false statements — which is legally worse than having no policy at all. Always customise any template and have it reviewed by qualified counsel.
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Read guidePolicifyAI is a technology provider, not a law firm. The information on this page is for orientation only and is not legal advice. Generated templates are intended as a structured starting point for review by qualified counsel before publication.