Blog entry by Darren Bindert
Most small business owners, when they hear ‘modern slavery,’ reach the same conclusion: that’s for large companies. The Modern Slavery Act 2015 requires businesses with an annual turnover of £36 million or more to publish a slavery and human trafficking statement. If your business is below that threshold, you’re not in scope.
That conclusion is correct as far as it goes. But it stops short of the full picture, and the gap between what the law technically requires and what your clients, insurers, or procurement teams expect of you is where most small businesses get caught out.
This post covers what the Modern Slavery Act actually says, why it still has practical implications for businesses well below the reporting threshold, and what modern slavery awareness training needs to include to satisfy those expectations.
To find out more about compliance training for SMEs, read our guide.
What the Modern Slavery Act 2015 actually requires
The Modern Slavery Act 2015 consolidated and strengthened existing legislation covering slavery, servitude, forced labour, and human trafficking. Its primary criminal offences apply to individuals and organisations engaged in those activities, not to businesses generally.
Section 54 of the Act introduced the transparency in supply chains provision, which requires commercial organisations with a global annual turnover of £36 million or more, and which supply goods or services in the UK, to produce an annual modern slavery statement. The statement must describe the steps the organisation is taking to ensure modern slavery is not occurring in its business or supply chains.
There is no equivalent statutory requirement for businesses below the £36 million threshold. A business turning over £2 million, £5 million, or £15 million has no legal obligation under section 54 to produce a statement or to run modern slavery training.
That is the accurate legal position. It is also, for many small businesses, increasingly irrelevant to their day-to-day experience of the topic.
Why it still matters for small businesses
The organisations subject to section 54 (large businesses and public sector bodies) are increasingly passing their modern slavery obligations down through their supply chains. If your business supplies goods or services to a larger organisation, that organisation’s own compliance programme will often extend to its suppliers.
In practice, this shows up in supplier questionnaires, procurement due diligence, and contract terms. A business tendering for a public sector contract, or onboarding as a supplier to a large corporate, will frequently be asked to confirm whether it has a modern slavery policy, whether it provides modern slavery awareness training to its staff, and how it monitors its own supply chain for risk. Answering ‘we’re below the £36 million threshold’ does not satisfy those questions.
The Procurement Act 2023, which came into force in February 2024, strengthened the expectation that public sector suppliers demonstrate ethical supply chain practices. While it does not mandate modern slavery training directly, modern slavery is explicitly referenced as a ground for exclusion from public procurement where a supplier has been convicted under the Modern Slavery Act.
Beyond procurement, some sectors have their own expectations. Financial services firms, for example, are increasingly asked to evidence supply chain due diligence by their regulators and auditors. Hospitality, food production, and care sectors carry a higher inherent risk of modern slavery in their supply chains, and responsible procurement standards in those sectors commonly require supplier training.
SkillsCircle includes a modern slavery awareness course as part of its pre-loaded compliance catalogue, alongside the full range of statutory and best-practice training your business needs. See what’s included.
What modern slavery awareness training should cover
Modern slavery awareness training is not about turning your staff into investigators. It is about ensuring that the people in your organisation can recognise the signs of exploitation and know what to do if they see them. At a minimum, training should cover:
• What modern slavery is: the different forms it takes, including forced labour, debt bondage, domestic servitude, and sexual exploitation, with examples relevant to everyday working contexts rather than abstract definitions.
• How to recognise the signs: indicators that a colleague, contractor, or individual encountered in a work context may be a victim of exploitation, such as signs of physical abuse, an inability to speak freely, being transported to work by a third party, or showing signs of fear or control.
• How and where to report: the internal reporting route within your business, and the external channels available, including the Modern Slavery Helpline (08000 121 700) or the police on 101.
• Your organisation’s position: a brief overview of your modern slavery policy, your commitment to ethical supply chains, and the expectation that staff act on concerns rather than overlook them.
Not every employee needs the same depth of training. Staff in procurement, supplier management, or roles with regular contact with contractors or agency workers should receive more detailed training on supply chain risk indicators. For the majority of employees, a well-constructed awareness course that covers the basics clearly and memorably is sufficient.
How to document it
If the purpose of running modern slavery training is partly to satisfy a procurement questionnaire or supplier audit, then the record of completion is as important as the training itself. A supplier that can say ‘yes, our staff receive modern slavery awareness training’ but cannot produce evidence of when and by whom is in a weaker position than one that can.
The documentation requirement here is the same as for any other compliance training: a dated record of who completed the training, which course or programme was used, and when renewal is due. Annual refresh is standard. New starters should complete training at induction regardless of where they fall in the annual cycle.
If your business is tendering for public sector contracts or completing supplier questionnaires regularly, it is worth keeping a summary document ready: the name of the course, the provider, the date training was last completed across the organisation, and your modern slavery policy reference. Having that to hand reduces the time cost of responding to procurement due diligence significantly.
How SkillsCircle helps
SkillsCircle is a ready-made LMS for businesses with fewer than 200 employees. Its pre-loaded compliance catalogue includes a modern slavery awareness course alongside health and safety, equality and diversity, data protection, and cyber security training. Staff complete courses online, completion is recorded automatically, and certificates are available for download, giving you the evidence trail you need for supplier audits and procurement questionnaires without any manual administration.
Pricing starts from £8 per user per month. Find out more about SkillsCircle or book a demo.