Creating a modern slavery statement for your UK startup: a practical guide

If your startup supplies goods or services and meets a certain turnover threshold, you may need to publish an annual modern slavery statement. This requirement catches many fast-growing companies by surprise.

Modern slavery encompasses forced labour, human trafficking, and debt bondage. The UK's Modern Slavery Act 2015 requires qualifying organisations to be transparent about how they address these risks in their operations and supply chains.

Consult a solicitor for specific advice on whether the law applies to your startup. This guide explains the practical steps to prepare your statement.

Do you need to publish a statement?

The requirement applies to commercial organisations that supply goods or services and have a total annual turnover of £36 million or more. Turnover includes the turnover of any subsidiary undertakings.

Most early-stage startups fall below this threshold. But if you are scaling quickly, approaching a funding round that will push you toward that turnover, or being acquired by a larger group, it is worth understanding the framework now.

Even if you are not legally required to publish a statement, creating one voluntarily can strengthen your position during due diligence. Investors and enterprise clients increasingly ask about modern slavery commitments.

When and where to publish

You must publish your statement within six months of your financial year end. It must be approved by the board of directors, signed by a director, and published on your website with a prominent link from the homepage.

If you do not have a website, you must provide a copy to anyone who requests one within 30 days. For most startups, a dedicated page under your "Legal" or "About" section works well.

Keep records of board approval. Add the statement to your compliance calendar so you update it annually.

What to include

The legislation lists six areas you should cover. You do not need to address every area if you have nothing to report, but you must state that openly.

Your organisation's structure and business

Describe what your startup does, your operating model, and the countries you operate in. Keep this factual and brief. A short paragraph will usually suffice.

Your supply chains

Outline the types of suppliers you use and the countries they operate in. If your startup is software-only, your supply chain might be limited to office supplies, equipment, and cloud service providers. Say so honestly.

Policies on slavery and human trafficking

Reference any relevant policies you have in place, such as a code of conduct, supplier code, or whistleblowing policy. If you are in the process of developing these, mention that.

Due diligence processes

Describe how you assess modern slavery risks in your supply chain. For a small startup, this might involve asking key suppliers to confirm their own practices or including modern slavery clauses in new supplier agreements.

Risk assessment and management

Identify where you believe the highest risks sit. For example, if you manufacture physical products in jurisdictions with weaker labour protections, flag that sector. If you have identified no high risks, explain your reasoning.

Measuring effectiveness

Explain the key performance indicators you use to track progress. This could be the number of suppliers screened, the percentage of staff completing training, or the number of concerns raised through your reporting channels.

Training

Note any training you provide to staff involved in procurement, recruitment, or supplier management. Even a short briefing session counts. Record it.

How to structure a straightforward statement for a small startup

Start with a brief introductory statement from the board, acknowledging the importance of the issue and your commitment to continuous improvement.

Follow with sections covering each area above. Use plain language. Screenshot examples from other similar-sized companies can help you find an appropriate tone.

Be honest about limitations. Saying "As a seven-person startup with no physical supply chain, we have not identified high-risk areas. We will review this as we grow" is more credible than boilerplate claims of exhaustive audits.

Steps to get started this week

• Confirm whether the turnover threshold applies to your startup now or in the near future.
• Add the statement to your annual compliance calendar.
• Map your actual supply chain, including indirect suppliers like recruitment agencies and equipment providers.
• Draft a short template covering the required areas.
• Present it to the board for discussion and approval.

Building in good habits early

Even if you are years away from the turnover threshold, simple habits help. Include a modern slavery compliance clause in standard supplier agreements now. Keep a central list of your key suppliers with brief notes on their locations and sectors.

When you eventually need to publish, you will have a foundation to build on rather than starting from scratch. Procurement teams at larger companies notice when startups take this seriously early on.

The key is proportionality. A short, honest statement that reflects your actual position is better than a polished document that does not match reality.