Modern Slavery Training: What UK Employers and SMEs Need to Know

Modern Slavery Training: What UK Employers and SMEs Need to Know

Modern slavery training is workplace awareness training that helps staff recognise the signs of forced labour, human trafficking, and exploitation, and know what to do when they see them. Whether your business is legally required to provide it depends almost entirely on one number. The Modern Slavery Act 2015 places a reporting duty on commercial organisations with a global annual turnover of £36 million or more. Below that threshold there is no statutory training obligation at all.

Most small business owners, when they hear “modern slavery”, reach the same conclusion: that is for large companies. If your business is below the threshold, you are not in scope, and 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 guide covers what the Modern Slavery Act actually says, who needs to complete training and at what depth, how often it should be repeated, what a compliant course contains, what a certificate does and does not prove, and why all of this still has practical consequences for businesses well below the reporting threshold.

For the wider picture, read our guide to compliance training for UK small businesses.

Is modern slavery training a legal requirement in the UK?

For most employers, no. 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. Nothing in the Act requires an ordinary employer to train its staff.

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. Training is one of the things a statement commonly describes, which is why organisations in scope almost always run it, but even here the Act specifies the disclosure rather than the training.

There is no equivalent statutory requirement 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, and it is where most guidance stops. It is also, for a growing number of businesses, close to irrelevant to their actual experience of the topic, for reasons set out below.

Who needs to complete modern slavery training?

Where an organisation decides to run training, whether because it is in scope for section 54 or because a customer has asked, the next question is who it applies to. Treating every employee identically is the most common approach and the least effective one, because the risk is not evenly distributed across a workforce.

A general awareness level suits the majority of employees. The purpose here is recognition and escalation: knowing what exploitation looks like, and knowing who to tell. This is short, and it does not need to be technical.

An enhanced level suits anyone whose role brings them into contact with the supply chain or with the recruitment of labour. That typically means procurement and buying teams, supplier relationship managers, HR and recruitment staff, anyone who engages agency workers or subcontractors, and site or operations managers who oversee contracted labour. These roles need to understand supply chain risk indicators, not only individual ones, and they need to know how the organisation’s due diligence process works.

Senior managers and directors sit in a third group. Where an organisation publishes a modern slavery statement, that statement must be approved at board level, and approving a document about steps you do not understand is a poor position to be in. Board-level briefing tends to be short and focused on risk exposure and accountability rather than on signs and indicators.

Sector matters as much as role. Businesses operating in construction, agriculture, food production and processing, hospitality, cleaning, care, logistics, and textiles carry a higher inherent risk of exploitation in their labour supply, and responsible procurement standards in those sectors commonly expect training to reflect that.

Modern slavery training for SMEs: why it matters below the £36 million threshold

The organisations subject to section 54, meaning 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 are below the £36 million threshold” does not satisfy those questions, and in a competitive tender it can be enough to lose the work.

The Procurement Act 2023, which came into force on 24 February 2025 after a four-month delay from its originally announced date, strengthened the expectation that public sector suppliers demonstrate ethical supply chain practices. It does not mandate modern slavery training directly, but 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 are increasingly asked to evidence supply chain due diligence by their regulators and auditors. Hospitality, food production, and care carry a higher inherent risk of modern slavery in their supply chains, and responsible procurement standards in those sectors commonly require supplier training.

The practical position for an SME, then, is that modern slavery training is rarely a legal obligation and increasingly a commercial one. That distinction matters, because it changes who you are satisfying and therefore what evidence you need to keep.

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. Browse the compliance course catalogue.

What a compliant modern slavery training course contains

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 on 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.

Content is only half of what makes a course defensible. If the reason you are running training is to satisfy a procurement questionnaire or a supplier audit, the course also needs to produce evidence, which means four practical features worth checking before you buy.

It should record completion against a named individual with a date, not simply mark a course as watched. It should include some form of assessment, because a completion record with a pass score answers a procurement question more convincingly than one without. It should be maintained and updated by the provider, since guidance and case examples date quickly and an obviously stale course undermines the point of running it. And it should be accessible to your actual workforce, which for businesses employing people whose first language is not English is a substantive question rather than a box to tick.

On depth, apply the role distinction described above. For the majority of employees, a well-constructed awareness course that covers the basics clearly and memorably is sufficient. 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.

How often should modern slavery training be repeated?

No UK legislation specifies an interval, for the straightforward reason that no UK legislation mandates the training in the first place. What exists instead is a convention, and the convention is annual.

That convention is worth following, not because a regulator will check the date, but because the questions you are answering are asked by procurement teams and auditors who have a fixed idea of what a well-run programme looks like. A supplier questionnaire asking when your staff last completed modern slavery training is looking for a date inside the last twelve months. A date from three years ago invites a follow-up question you would rather not receive.

Two things should override the annual cycle. New starters should complete training at induction regardless of where they fall in it, because the alternative is a member of staff who is untrained for up to eleven months. And a change in circumstances should trigger retraining outside the cycle: entering a new sector, taking on agency or subcontracted labour for the first time, winning a contract with enhanced supply chain conditions, or an incident or concern being raised internally. A training record that shows you responded to events reads considerably better than one showing an unbroken annual rhythm regardless of what was happening in the business.

What a modern slavery training certificate actually proves

Certificates are the currency of this kind of compliance, and it is worth being precise about what one establishes.

A certificate evidences that a named individual completed a defined course on a specific date and, where assessment is included, that they met the pass threshold. For procurement purposes that is usually exactly what is being asked for. What a certificate does not establish is that the training content was appropriate to your risk profile, that the person has retained anything, or that your organisation has a functioning process for acting on concerns. Those remain your responsibility, and no certificate transfers them.

CPD certification, which is attached to many online compliance courses including modern slavery awareness, indicates that the course has been reviewed against continuing professional development standards for structure and learning value. It is a quality signal about the course. It is not a statement that the course satisfies a legal duty, and no accreditation body can make that guarantee on your behalf.

The practical implication is that certificates are necessary rather than sufficient. Keep them, keep them retrievable, and keep alongside them a short note of why the training you chose was appropriate. That second part is the piece most organisations skip, and it is what turns a folder of certificates into a defensible position.

Free versus paid modern slavery training

Free modern slavery training does exist, and it is worth being straightforward about it rather than pretending otherwise. Several anti-slavery charities and specialist organisations publish awareness courses at no cost, some as open online courses and some as downloadable packages you can load into your own learning system. For a business that needs to demonstrate awareness and nothing more, these can be a reasonable starting point, and the content is often excellent because it comes from organisations who work on this every day.

The limitations are administrative rather than educational. A free course delivered outside a learning system generally leaves you to solve the record-keeping problem yourself, which is the part that procurement questionnaires actually test. It usually will not track completion against named individuals, flag renewals, or produce a certificate you can attach to a tender response. And modern slavery is rarely the only compliance training a business needs, so a free standalone course tends to solve one square of a grid while leaving the rest untouched.

The sensible way to frame the choice is by what you are trying to evidence. If you need awareness, free is defensible. If you need to answer supplier questionnaires quickly and repeatedly, across several training categories, with dated records for every member of staff, the administration is the thing you are actually buying.

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.

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, and it is the difference between answering a questionnaire in an afternoon and answering it over a fortnight.

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. You can browse the full compliance course catalogue, find out more about SkillsCircle, or book a demo.