Due diligence through modern slavery statements, supplier codes and supply chain risk mapping that hold up to a client questionnaire, a tender response or a regulator.
Human rights risk sits in the part of the business you do not directly control. A modern slavery statement signed off without underlying due diligence, a supplier code nobody monitors against, and a supply chain mapped by spend rather than by risk are some of the most common gaps. They are also the ones that surface in a client questionnaire, a tender response, or a journalist’s email.
23,411
Potential victims of modern slavery referred to the Home Office in 2025, up 22% and the highest since the National Referral Mechanism began in 2009
Home Office, February 2026
£36mn
Turnover threshold above which an annual modern slavery statement is required under section 54
Modern Slavery Act 2015
14 Dec 2027
EU Forced Labour Regulation takes effect, prohibiting products made with forced labour from the EU market
European Commission
Cost to the organisation
Referrals to the National Referral Mechanism reached a record 23,411 in 2025, a 22% rise on the previous year, with construction, agriculture, distribution and hospitality accounting for the largest share of labour exploitation cases. Section 54 of the Modern Slavery Act 2015 applies above £36mn turnover and is enforceable by injunction, with breach punishable as contempt of court by unlimited fine.
For most organisations the commercial exposure arrives ahead of the legal one: buyers increasingly make human rights due diligence a condition of contract.
What could improve?
Policy and reporting
• Modern slavery statements produced to meet a deadline rather than to reflect actual due diligence and governance, with the same wording carried over year after year
• Supplier codes of conduct issued at onboarding and never referenced again with no monitoring, no escalation route, no consequences if any breaches are found
Visibility across the supply chain
• Supply chains mapped by spend rather than by risk, so the highest-risk tiers may be the least visible
• Labour supply exposure from umbrella companies, agencies and sub-contractors that has not been mapped or risk-assessed
• No grievance or remedy mechanism that workers beyond the first tier can actually utilise
Accountability and evidence
• Client and tender questionnaires arriving with human rights due diligence questions that procurement cannot evidence an answer to
• Legal, procurement and sustainability each holding part of the picture, with limited collaboration or nobody accountable for the whole
Find the gaps in your supply chain
These questions arrive through tenders and client questionnaires before a regulator asks. Send us your modern slavery statement and we will tell you what’s missing.
How can Energise help
Supplier code of conduct | Drafting a code of conduct from scratch or auditing your existing one against current expectations and updating it to close any gaps we find.
Modern slavery statement | Drafting a section 54 statement or reviewing and updating your existing one against Home Office statutory guidance, analysis of where your due diligence realistically stands.
Supply chain assessment | Mapping supplier risk to assessed supply chains across human rights, modern slavery, and supplier due diligence that satisfy client and regulatory requirements.
Labour supply due diligence | Mapping and managing exposure across umbrella company use, agency workers and contractors.
Human rights regulation
What’s changing and when
Our Social Sustainability consultancy customers
These issues rarely sit in isolation
Energise works with organisations to understand where things are not working and build the conditions for lasting change, not just short-term fixes.
Human Rights & Responsible Supply Chains FAQs
Who has to publish a modern slavery statement?
Any organisation carrying on business in the UK with turnover above £36mn, under section 54 of the Modern Slavery Act 2015. The statement must be approved by the board and signed by a director. Section 54 is enforceable by injunction, with breach punishable as contempt of court.
What should a modern slavery statement include?
Home Office statutory guidance, updated in March 2025, raised expectations on content without changing the underlying duty. It expects a statement to reflect actual due diligence: how risk is assessed, what was found, what was done, and what changed. Carrying over last year’s wording is the most common weakness.
Is section 54 of the Modern Slavery Act going to change?
The UK government has committed to consider strengthening it, including the turnover threshold, reporting requirements and penalties for non-compliance. Nothing is confirmed. Organisations building due diligence now rather than statement wording will be better placed whichever way the review lands.
Does the EU Forced Labour Regulation apply to UK businesses?
It applies from 14 December 2027 and prohibits products made with forced labour from being placed on or exported from the EU market, enforced by customs and national authorities. UK businesses selling into the EU, or supplying customers who do, fall within its practical reach.
Do agency workers and umbrella companies count as part of our supply chain?
Yes, and they are frequently the least mapped part of it. Umbrella companies are being brought within agency regulation under the Employment Rights Act 2025 during 2027, which extends enforcement across labour supply. Exposure sitting with sub-contractors and agencies is still your exposure.
How do we answer human rights questions in tenders and client questionnaires?
With evidence rather than policy. Buyers increasingly ask what your due diligence found, not whether you have a supplier code. For most organisations the commercial cost of not being able to answer arrives well before any legal one does.
Have a question for us?
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