Modern Slavery Statement Checklist Template

What the Modern Slavery Statement Checklist Covers

1. 1
   Phase 1

   Phase 1: Duty, Scope & Owners

   8 tasks

   Start about two months before the financial year ends. Answer the questions in the first task first: the kind of organisation shows who approves and signs, and the other answers add the tasks for a group statement, a first statement or an update, and another country’s law. Due dates count back from the year end for the planning and forward from it for the rest.

   • Set up the statement — the organisation, the financial year the statement covers and the date it ends (which the due dates count from), the kind of organisation, whether it is a single or a group statement, whether it is the first statement or an update, whether another country’s law also applies, and the statement owner, procurement lead, HR lead and the director (or equivalent) who signs; later tasks are assigned from these fields
   • Confirm whether the duty applies — the four tests in section 54: a body corporate or a partnership, carrying on a business or part of a business in the UK, supplying goods or services, and a total turnover of at least £36 million including subsidiaries, with the answer recorded
   • Take advice on whether the duty applies — shown when the answer is not yet known: the facts that decide it, such as income from business activities for a charity or the UK presence of an overseas company, taken to a lawyer, with the advice recorded
   • Decide what the statement covers — the organisation’s own business and all its supply chains, any subsidiaries whose activities form part of its business or supply chains, and, for a group, which organisations the statement covers
   • List each organisation the group statement covers — shown for a group statement: each parent and subsidiary that meets the tests, named in the statement, with its company number and UK website
   • Confirm who approves and signs the statement — the board of directors (or equivalent management body) and a director for a company, the members and a designated member for an LLP, a general partner for a limited partnership or a partner for any other partnership, and a meeting date that fits the timetable
   • Review last year’s statement and its commitments — shown for an update: last year’s statement, the goals and actions it promised, and any feedback from customers, investors or campaigners, so this year’s statement reports progress against them
   • Agree the timetable and owners — the dates for the year’s evidence, the approval meeting, publication and the registry submission, aiming to publish within six months of the year end as the guidance asks, with an owner for each area of the statement
2. 2
   Phase 2

   Phase 2: Structure, Business & Policies

   6 tasks

   Describe the organisation and its supply chains and gather the policies before the year ends, while the people who know them are easy to reach. These are the first two areas section 54(5) says a statement may cover.

   • Describe the organisation’s structure and business — its size, the countries it operates in, its trading entities, its main products and services and the sectors it works in
   • Map the supply chains — how goods and services are sourced, produced and distributed, the countries and tiers known, support services such as cleaning and catering, how workers are recruited, and what is not yet known below the first tier
   • Name who is responsible and how senior managers oversee it — who identifies, assesses and responds to modern slavery risks, and the governance that gives the board or senior management oversight of them
   • Gather the policies that relate to modern slavery — the employee and supplier codes of conduct, recruitment (including a ban on fees paid by workers), responsible purchasing, whistleblowing and any others, with links to those that are public
   • Check supplier contracts and onboarding terms — whether contracts and onboarding terms include the supplier code of conduct, modern slavery terms, the right to audit and what happens on a breach
   • Confirm the grievance and whistleblowing channels — the channels staff, agency workers and suppliers’ workers can use to raise concerns, anonymously and in a language they understand, and how reports reach the statement owner
3. 3
   Phase 3

   Phase 3: The Year’s Due Diligence, Training & Progress

   6 tasks

   Once the year has ended, collect what was done during it. The statement reports the steps taken in the financial year, so every figure here should come from that year.

   • Collect the due diligence carried out in the year — supplier questionnaires, onboarding checks, engagement with suppliers and workers, and work with industry groups, NGOs or trade unions, with what each found
   • Collect the audits and site visits and what they found — each audit or visit in the year, whether it was announced, whether the auditors were trained in the ILO indicators of forced labour and spoke the workers’ language, and the findings
   • Collect the training figures — the training given to the whole organisation, frontline, HR, procurement and executive staff, and suppliers, with its content and the numbers trained
   • Measure progress against goals and KPIs — each goal the organisation set and the indicator that measures it, with this year’s figure and what it shows about whether the steps are working
   • Report progress on last year’s commitments — shown for an update: each commitment last year’s statement made, whether it was done, and what changed as a result
   • Collect each covered organisation’s steps — shown for a group statement: the steps each organisation the statement covers took during the year, since a group statement must cover them all
4. 4
   Phase 4

   Phase 4: Supply Chain Risk Review

   4 tasks

   Assess where the risk of modern slavery to workers is highest, using the year’s evidence, and record any indicators or cases found. The guidance says the risk assessment should focus on risk to workers, not to the organisation. Indicators or a suspected case add the response phase that follows.

   • Identify the risks across the supply chains — each supplier category assessed for its industry, the nature of its workforce, its location, the context it works in, the commodity and the business model, including services such as cleaning and facilities
   • Assess and prioritise the risks — likelihood and severity of harm to workers for each risk, the most salient ones ranked first, and how much influence the organisation has over the suppliers concerned
   • Agree actions on the highest risks — the prevention and mitigation steps for each priority risk, such as working with the supplier, changing purchasing or recruitment practices or joining an industry initiative, each with an owner and a date
   • Record any indicators or cases of modern slavery found — whether the year’s work found indicators of modern slavery, or a suspected case, in the business or its supply chains; either answer adds the response tasks
5. 5
   Phase 5

   Phase 5: Responding to Indicators or Cases

   5 tasks

   Applies only when indicators or a suspected case were found. Act on them straight away rather than at the due dates, and keep this work apart from publishing: the statement can be approved and published while the response continues.

   • Report the suspected case and protect the people affected — shown for a suspected case: in the UK, report it to the Gangmasters and Labour Abuse Authority or the police straight away, call 999 if anyone is in immediate danger, and contact the local authority as well if the person may be under 18
   • Investigate and verify what was found — shown when indicators or a case were found: what happened, the workers affected and the supplier’s part in it, putting the safety of the people affected first
   • Agree remediation for the workers affected — shown when indicators or a case were found: the remedy agreed with the workers affected or their representatives, such as repaying recruitment fees, and the supplier’s corrective actions
   • Decide whether to stay engaged with the supplier — shown when indicators or a case were found: whether to continue with corrective actions or to disengage responsibly as a last resort, considering the effect on the workers
   • Track the actions to an outcome — shown when indicators or a case were found: each action followed up until it is closed, with the outcome for the workers and what the statement will say about it
6. 6
   Phase 6

   Phase 6: Drafting the Statement

   5 tasks

   Write the statement in plain English against the areas section 54(5) suggests, using the evidence gathered. The law requires a statement of the steps taken in the year, or that none were taken; the guidance expects the six areas to be covered and to improve each year.

   • Decide the level of detail for a first statement — shown for a first statement: the guidance suggests starting with its level 1 disclosures in each area and adding level 2 detail in later years
   • Draft the statement against the six areas — structure and supply chains, policies, risk assessment and management, due diligence (including remediation), training, and effectiveness measured against KPIs, using the year’s evidence and naming every organisation it covers
   • Set goals and actions for the coming year — what the organisation will do next year in each area, with measures, so next year’s statement can report progress
   • Check the draft against section 54 — the financial year it covers, the steps taken in that year (or a statement that none were taken), every organisation covered named, plain language, links to policies, and space for the approval date and the signatory
   • Review the draft with procurement, HR and legal — comments from the people who supplied the evidence and a legal check that every statement of fact is accurate, with the final draft ready for approval
7. 7
   Phase 7

   Phase 7: Approval & Signature

   4 tasks

   Send the final statement to the board (or equivalent) for approval and to the director (or equivalent) to sign. Approval and signature halt the checklist: nothing in the later phases can be completed until they are recorded.

   • Send the statement to the board for approval — the final statement with a short paper covering what changed since last year, the main risks, any cases found and what was done, and the goals for next year
   • Board approves the statement and a director signs it — the board (or equivalent body, or the members of an LLP) approves the statement and the director, designated member or partner signs it, recorded with the date of approval and the signatory’s name and job title; nothing is published until this is recorded
   • Record how each covered organisation approved the group statement — shown for a group statement: how and when each organisation the statement covers approved it; neither the Act nor the guidance says how each organisation in a group approves a shared statement, so take advice where it is unclear
   • Add the approval date and the signatory to the statement — the date of approval and the name, job title and date of the person who signed, as the gov.uk guidance asks; a physical signature is not needed, but the statement should say it has been signed
8. 8
   Phase 8

   Phase 8: Publishing & the Registry

   9 tasks

   Publish the statement on the website with a prominent homepage link, then add it to the government registry. A group statement goes on each covered organisation’s UK website, and Australia, Canada or another law adds its own filing.

   • Publish the statement on the website — the signed statement on the organisation’s website or, if it has no website, a copy sent within 30 days to anyone who asks for one in writing
   • Add a prominent link on the homepage — a clearly named link, such as Modern Slavery Act Transparency Statement, directly on the homepage or in an obvious drop-down menu
   • Publish it on each covered organisation’s UK website — shown for a group statement: the statement, or a link to it, on the UK website of every organisation it covers, each with its own homepage link
   • Keep previous years’ statements online — shown for an update: last year’s and earlier statements left available so readers can compare progress, as the guidance recommends
   • Register the organisation on the statement registry — shown for a first statement: an account for the organisation on the government’s modern slavery statement registry, found by name or company number
   • Submit the statement to the government registry — the link, a PDF copy, the period covered, the signatory, the approval date, the areas covered, sector and turnover, and the optional summary questions; submission is voluntary, and the government encourages it
   • Prepare and give the Australian statement — shown when Australia’s Act applies: a statement meeting the mandatory criteria in section 16, approved by the principal governing body, signed by a responsible member and given to the Minister within six months after the end of the reporting period
   • Prepare and file the Canadian report — shown when Canada’s Act applies: a report on the steps taken in the previous financial year, approved by the governing body, signed by one or more of its members, given to the Minister by 31 May and published prominently on the website
   • Check the other reporting law and its deadline — shown when another country’s or state’s law applies: what it requires, who must approve the report and by when, checked with local advice
9. 9
   Phase 9

   Phase 9: Sharing & Next Year

   4 tasks

   Tell people where the statement is, turn the goals into actions with owners, and set up next year’s run so the evidence is collected as the year goes.

   • Tell staff, suppliers and customers where the statement is — a link sent to staff, key suppliers and the customers or investors who ask for it, and the statement used in tender and supplier questionnaires
   • Assign the actions for next year — each goal and action from the statement given an owner and a date, with the open actions from the risk review and any response carried into them
   • Review how this year’s statement went — what was hard to find, what took too long and what to collect during the year next time
   • Set up next year’s statement — next year’s financial year end entered in a new run, or on a recurring schedule, so the planning starts about two months before it