10 Voices, 10 Strategies: 5 legal approaches to tackling modern slavery

Featuring Louise Lightfoot, Partner at Eversheds Sutherland

I’m Louise Lightfoot, a partner at Eversheds Sutherland specialising in UK employment law. Throughout my career, I’ve spent considerable time advising organisations, both large and small, on how to comply with their obligations under the Modern Slavery Act. While compliance is a vital part of addressing this issue, as Paul McAnulty mentioned earlier, understanding your legal obligations is just the beginning. Below are five legal strategies that can help businesses take meaningful steps toward tackling modern slavery.

1. Leverage public resources

A crucial first step in understanding your legal obligations is to make use of publicly available resources. The National Standard BS 25700 on modern slavery offers clear definitions around forced labour, debt bondage, and forced marriage, as well as guidance on risk management and response strategies. Likewise, resources from HMRC, the UK government, and the Ethical Trading Initiative are excellent starting points. They provide practical advice for managing risks and understanding your responsibilities as an employer or business partner.

2. Publish a modern slavery statement

Publishing a modern slavery statement is a legal requirement for organisations with an annual turnover above £36 million. However, the UK government encourages companies of all sizes to voluntarily publish a statement. Doing so is about more than just compliance—it demonstrates a commitment to transparency and ethical business practices. The law outlines six areas that should be covered in the statement, including your business structure, supply chain practices, due diligence processes, training programs, risk assessments, and monitoring efforts. Addressing these areas can drive meaningful change within your organisation and across your supply chain.

3. Align policies with modern slavery goals

While publishing a modern slavery statement is essential, it’s not enough on its own. Your organisation must have supporting policies in place. These could include updates to existing recruitment, procurement, or operational policies that explicitly address modern slavery. There’s no need to create standalone policies if they already exist—amending and updating what you have is a practical way to ensure modern slavery concerns are woven into the fabric of your business.

4. Leadership buy-in is crucial

The Modern Slavery Act requires that a company’s modern slavery statement be approved by its board or an equivalent leadership body, and signed by a director. This legal requirement ensures that top leadership is engaged, which is crucial. Without visible commitment from the highest levels of the organisation, it’s unlikely that anti-slavery efforts will be taken seriously throughout the company. Engaged leadership signals that this issue is a priority and should be treated with the importance it deserves.

5. Continuously assess and improve

Finally, it’s important to continuously assess, monitor, and improve your modern slavery efforts. Regular reviews of your modern slavery statement and its impact can help ensure that your business is making progress year on year. Many organisations upload their statements to public repositories, allowing them to be compared with industry peers. A common area for improvement is in risk assessments and continuous progress. As modern slavery statements must be published annually, it’s critical that each year shows a commitment to building on previous efforts.

Key takeaways

• Use available resources to understand your legal obligations.
• Publish a modern slavery statement, even if your company is not legally required to do so.
• Ensure your organisation’s policies address modern slavery.
• Secure leadership buy-in to foster a culture of responsibility.
• Continuously assess, monitor, and improve your modern slavery efforts.

By following these strategies, your organisation can go beyond compliance and make a genuine impact in the fight against modern slavery.