Modern slavery statement vs policy for tenders
By the companypolicies.ai team, published by Spire Trade Advisors Ltd · Published · Last updated · 7 min read
In short
A modern slavery statement is an annual public report required under section 54 of the Modern Slavery Act 2015 from organisations with total turnover of £36m or more. A modern slavery policy is an internal document setting out how you prevent slavery. Public-sector buyers ask suppliers of any size for the policy.
The modern slavery statement (section 54)
- Required from commercial organisations supplying goods or services with total turnover of £36m or more (s.54 and SI 2015/1833).
- Prepared for each financial year, approved by the board and signed by a director (or equivalent).
- Published on your website with a link in a prominent place on the homepage.
- It may cover your structure and supply chains, policies, due diligence, risk assessment, effectiveness measures and training.
- Organisations are encouraged to add it to the government's modern slavery statement registry.
The modern slavery policy
- An internal policy that sets out your commitment, responsibilities, risk assessment, supplier due diligence, recruitment checks, training and reporting routes.
- No turnover threshold. Any organisation can, and buyers regularly ask suppliers of all sizes for one.
- It forms the evidence base for a statement if you later cross the £36m threshold.
Side-by-side comparison
| Statement | Policy | |
|---|---|---|
| Legal requirement | Yes, at £36m+ total turnover | No, but commonly requested |
| Audience | The public | Staff, suppliers and buyers |
| Frequency | Every financial year | Reviewed periodically (e.g. annually) |
| Sign-off | Board approval and director signature | Director approval recommended |
| Where it lives | Website, prominent homepage link | Internal, shared with buyers on request |
What tenders ask
Slavery and human trafficking offences are mandatory exclusion grounds under Schedule 6 of the Procurement Act 2023. Buyers commonly ask whether you are subject to s.54 (and for a link to your statement if so) and, regardless of size, how you identify and manage modern slavery risk in your supply chain. A written modern slavery policy and a supplier code of conduct answer that directly.
Central government departments, their agencies and NHS bodies also follow PPN 009, which asks buyers to assess the modern slavery risk of each procurement. Where the risk is higher, expect more detailed questions about your supply chain and how you check it. Some questionnaires based on the government template include a standard question asking whether you are a "relevant commercial organisation" (£36m+ turnover) and compliant with section 54.
Proposed changes: the Immigration and Asylum Bill (not yet law)
The Immigration and Asylum Bill, introduced in Parliament on 30 June 2026, includes proposed amendments to section 54. As at 2 October 2026 these are proposals only: the Bill has not been passed, and the current section 54 rules described above still apply.
As introduced, the Bill would make the content of statements mandatory (structure and supply chains, risk assessment, policies, due diligence, training and an assessment of effectiveness, or an explanation of why a step hasn't been taken), add a publication and submission deadline of six months after the financial year end, extend the duty to public authorities above a budget threshold set by regulations, and allow regulations to set financial penalties for organisations that fail to comply without reasonable excuse. The details could change as the Bill goes through Parliament.
For smaller suppliers the practical point is the same either way: buyers already ask how you assess and manage modern slavery risk, and a written policy, supplier checks and training records are the evidence a mandatory statement would draw on.
Frequently asked questions
Do I need a modern slavery statement if my turnover is under £36m?
No. The section 54 duty applies to commercial organisations supplying goods or services with total turnover of £36m or more. You can publish a statement voluntarily, but in tenders smaller suppliers are usually asked for a modern slavery policy and how they manage supply-chain risk.
Where should a modern slavery statement be published?
On your website, with a link in a prominent place on the homepage. The government also encourages organisations to add it to the modern slavery statement registry.
Is a modern slavery policy enough for a tender?
Where the question asks how you identify and manage modern slavery risk, a signed policy backed by supplier checks, recruitment checks and training usually answers it. If you are over £36m, buyers will also want the link to your current statement.
Is the modern slavery statement becoming mandatory for more organisations?
Not yet. The Immigration and Asylum Bill (introduced 30 June 2026) proposes mandatory statement content, a six-month deadline, penalties and an extension to public authorities, but it is still going through Parliament and is not law. The £36m turnover threshold for commercial organisations is unchanged.
Related guides
Sources
- Modern Slavery Act 2015, section 54 (legislation.gov.uk)
- The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015, reg. 2
- Transparency in supply chains: a practical guide (GOV.UK)
- Modern slavery statement registry (GOV.UK)
- Immigration and Asylum Bill: proposed modern slavery reporting changes (Linklaters, July 2026)
Written and reviewed by the companypolicies.ai team at Spire Trade Advisors Ltd, using the official sources listed above; last checked 2 October 2026. General information, not legal advice. Procurement rules and guidance change, and individual tenders set their own requirements; always check the procurement documents and current GOV.UK guidance.