Name: Modern slavery policy template | Sep 26
Brand: HRDocBox
SKU: HRDBOX-526
Price: 14.99 GBP
Availability: InStock

What's included in this template?

This template brings together the key information, sections and considerations you need to create a clear, comprehensive and professional HR document. Preview the document below.

Overview and commitment
Scope
General principles
Modern slavery risks
Employee responsibilities
Recruitment and employment practices
Supply chain due diligence
Supplier expectations
Reporting concerns
Responding to concerns
Training and awareness
Policy monitoring and review

Specifications

Template

Modern slavery policy

1 Overview

1.1 [Company Name] is committed to preventing modern slavery, human trafficking, forced labour and other forms of exploitation within our business and supply chain.

1.2 We recognise our responsibility to respect human rights and to take reasonable and proportionate steps to identify, prevent and address modern slavery risks associated with our operations, workforce, suppliers and business relationships.

1.3 The Company has zero tolerance for modern slavery and will not knowingly support, facilitate or engage with practices involving forced labour, servitude, human trafficking or exploitation.

2 Scope

2.1 This policy applies to all employees, workers, contractors, agency workers, apprentices, consultants and other individuals working for or on behalf of [Company Name].

It also applies to our suppliers, contractors, subcontractors and other business partners where the Company's activities or relationships may create or contribute to modern

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What is a modern slavery policy?

Modern slavery is not limited to extreme or obvious cases of exploitation. Forced labour, trafficking and other forms of exploitation can occur within legitimate businesses and supply chains, making it important for employers to understand where risks may arise and how concerns should be dealt with. This Modern Slavery Policy gives employers a practical framework for setting expectations and managing those risks.

A clear commitment to preventing exploitation

The policy establishes a zero-tolerance approach to modern slavery and explains the standards expected across the organisation. It covers employees, workers, agency staff, contractors and relevant business partners rather than treating modern slavery solely as a procurement issue.

Recognising potential warning signs

The policy helps managers and employees understand some of the potential indicators of forced labour and exploitation, while making clear that individuals do not need to prove that modern slavery has occurred before raising a genuine concern.

Managing supply chain risk

Modern slavery risks can arise beyond an organisation's direct workforce. The template therefore includes proportionate supplier due diligence, supplier expectations and escalation arrangements, allowing the organisation to apply greater scrutiny where the level of risk warrants it.

Responding when concerns arise

The policy establishes a route for reporting concerns and sets out how the organisation should respond, including protecting individuals from retaliation and considering external assistance where there may be an immediate risk to someone's safety.

Keeping controls proportionate and current

Not every organisation will face the same modern slavery risks. The policy is designed to be adapted to the organisation's size, sector, workforce and supply chain, with regular review to reflect changes in operations, legislation, guidance and identified risks.

Example

A manufacturing business reviews its supply chain and identifies that some of its raw materials are sourced through several tiers of suppliers in countries where forced labour risks are known to be higher.

The business introduces proportionate supplier due diligence, requiring relevant suppliers to confirm their approach to modern slavery and providing additional scrutiny for higher-risk relationships. Managers and employees are also reminded that concerns about exploitation can relate to agency workers and contractors as well as directly employed staff.

An employee subsequently raises a concern that an agency worker appears to be having a significant amount deducted from their wages and seems reluctant to discuss their circumstances. The manager does not attempt to dismiss the concern because there is no proof of exploitation. Instead, they refer it through the Company's reporting process.

HR assesses the concern, speaks with the appropriate parties and takes further action where necessary. The business records the concern and uses the outcome as part of its ongoing review of its labour and supplier arrangements.

The wider HR process

Related HR resources and workflow

Explore the HR resources that may be relevant before and / or after using the Modern slavery policy, helping you understand the wider process, maintain appropriate documentation and follow a consistent approach.

Modern Slavery Risk Assessment form

The Modern Slavery Risk Assessment Template provides a structured way for employers to identify, assess and manage the risk of modern slavery and human trafficking within their own operations and supply chains.

This

Modern slavery policy

Modern slavery policy statement form

Our Modern Slavery Policy Statement empowers ethical practices, showcasing dedication to responsible conduct and accountability.

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Implementation guidance

Use these best practice actions, recommended timescales and process stages to understand when and how the Modern slavery policy should be used, helping ensure each step is handled consistently and appropriately documented.

Step	Description	Responsibility	Timing
1	Assess the Risk: Consider where modern slavery risks could arise within the workforce, recruitment arrangements, operations and supply chain.	HR / Management	Initially and regularly
2	Implement the Policy: Communicate the policy and ensure managers, employees and relevant suppliers understand their responsibilities.	HR / Management	On implementation
3	Apply Due Diligence: Build proportionate modern slavery considerations into recruitment, supplier selection and ongoing supplier management.	HR / Procurement	Ongoing
4	Report and Respond: Provide a clear route for raising concerns and investigate or escalate potential exploitation appropriately.	All employees / Management	As required
5	Review Effectiveness: Review risks, incidents, supplier information, training and procedures and update controls where necessary.	Policy owner	At least annually

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Common mistakes

Understand the common mistakes to avoid when using this HR template, helping you reduce risk, prevent unnecessary costs and ensure the process is handled correctly.

Treating modern slavery as purely a supply chain issue and overlooking risks affecting directly employed, agency or contracted workers.
Having a policy but no practical process for employees or suppliers to report concerns.
Assuming that modern slavery cannot occur because the organisation operates in the UK or uses reputable suppliers.
Failing to carry out proportionate due diligence on higher-risk suppliers, labour providers or recruitment arrangements.
Failing to train people who may be well placed to recognise potential indicators of exploitation.
Not reviewing modern slavery risks when the organisation, workforce, suppliers or geographical exposure changes.

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HR considerations

UK employment law and best practice

This template is designed to support the process, but the document should be used alongside the relevant HR procedure and applied to the circumstances of the individual case.

The Modern Slavery Act 2015 consolidates offences relating to slavery, servitude, forced or compulsory labour and human trafficking. Employers should consider the risks of modern slavery within their own operations and supply chains and take appropriate steps to prevent and address exploitation. https://www.gov.uk/government/collections/modern-slavery-bill

Modern Slavery Act 2015

The Modern Slavery Act 2015 creates offences relating to slavery, servitude and forced or compulsory labour, as well as human trafficking. It also provides protections for victims and powers for enforcement authorities. https://www.legislation.gov.uk/ukpga/2015/30/contents

Transparency in supply chains

Section 54 of the Modern Slavery Act requires certain commercial organisations supplying goods or services in the UK with a total turnover of at least £36 million to prepare a slavery and human trafficking statement for each financial year. The legislation specifies the organisations within scope and the information that may be included in such statements. https://www.gov.uk/government/publications/transparency-in-supply-chains-a-practical-guide

Slavery and human trafficking statement

Organisations within the statutory threshold should publish an appropriate slavery and human trafficking statement explaining the steps taken during the financial year to ensure that slavery and human trafficking are not taking place in their business or supply chains. https://www.gov.uk/government/publications/transparency-in-supply-chains-a-practical-guide

Supply chain due diligence

Government guidance encourages organisations to understand their supply chains, identify modern slavery risks, undertake appropriate due diligence and take action where risks are identified. The level of due diligence should reflect the organisation's circumstances and risk profile. https://www.gov.uk/government/publications/transparency-in-supply-chains-a-practical-guide

Employment practices

Employers should consider whether their recruitment, pay, working arrangements and use of labour providers could create or contribute to exploitation risks. Right to work checks, clear employment terms and appropriate management of agency and temporary labour can form part of broader controls against illegal working and exploitation. https://www.gov.uk/government/publications/modern-slavery-how-to-identify-and-support-victims

Identifying victims

Government guidance identifies a range of potential indicators of modern slavery and explains how organisations and professionals can identify and support potential victims. Employers should ensure that relevant people know how to recognise and escalate concerns. https://www.gov.uk/government/publications/modern-slavery-how-to-identify-and-support-victims

Record keeping and review

Organisations should retain appropriate evidence of their risk assessment, due diligence and actions taken. Regular review is particularly important where the organisation's workforce, suppliers, geographical exposure or other risk factors change.

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FAQs

What is a Modern Slavery Policy?

A Modern Slavery Policy explains an organisation's commitment to preventing slavery, forced labour, human trafficking and exploitation. It sets out responsibilities, reporting arrangements and controls for managing risks within the workforce and, where relevant, the supply chain.

Does every UK employer need a Modern Slavery Policy?

There is not a universal statutory requirement for every employer to have a standalone Modern Slavery Policy. However, organisations should consider the risks of modern slavery within their operations and supply chains. Certain commercial organisations with a total turnover of at least £36 million are subject to specific transparency requirements under section 54 of the Modern Slavery Act 2015. https://www.gov.uk/government/publications/transparency-in-supply-chains-a-practical-guide

What are the signs of modern slavery?

Potential indicators can include threats or intimidation, restricted movement, withholding identity documents, debt bondage, excessive working hours, poor living conditions, unusual deductions from pay or a person appearing unable to leave their employment or situation freely. These indicators do not necessarily prove modern slavery but should be taken seriously.

Who should employees report concerns to?

The policy should identify a clear internal reporting route, such as HR, a line manager, senior manager or whistleblowing contact. Employees should be encouraged to raise genuine concerns even where they cannot establish that modern slavery has definitely occurred.

Does modern slavery apply to suppliers?

Yes. Modern slavery risks can occur at different levels of a supply chain, including through contractors, labour providers, subcontractors and other business partners. The appropriate level of supplier due diligence will depend on the organisation's circumstances and identified risk.

Why use HRDocBox for a Modern Slavery Policy?

HRDocBox combines practical HR experience with employment compliance knowledge to create policies that can be used in real workplaces. This template goes beyond a generic statement of intent by covering workforce risks, supply chain due diligence, reporting, responsibilities and the practical response to concerns.

How this content is developed and reviewed

The Modern slavery policy template is developed using a practical HR methodology that considers current UK employment legislation, ACAS guidance, CIPD good practice and the real-world HR process it supports. Templates are regularly reviewed and updated, with additional reviews triggered by significant changes to legislation, guidance or established HR practice, helping ensure each document remains practical, relevant and suitable for UK employers.

About the author

Darryl Horn, Chartered HR Director

Darryl is a Chartered HR professional with over 25 years' experience in senior HR and employee relations roles.

He has extensive practical experience of managing ethical processes and founded hrdocbox to provide businesses with practical, professionally developed HR resources grounded in UK employment law and best practice.

HRDocBox has been creating practical UK HR documents since 2009.

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"Darryl provides support and advice with excellent judgement, and has a strong understanding of people, policies and UK employment legislation."

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Ruth Brock Chief Executive Officer The Hygiene Bank