Modern Slavery Acts: UK + Australia + supply-chain disclosure

What it requires

• Annual statement signed by board / senior officer + published on website
• Disclosure of organisational structure, supply chains, business
• Policies in relation to slavery and human trafficking
• Due-diligence processes (audits, training, risk assessment)
• Risk-assessment by sector + geography of supply tiers
• KPIs for measuring effectiveness (audit closure, remediation cases)
• Training content and reach for staff and suppliers
• Mandatory criteria addressed (AU specifically requires 7)

How it impacts merch programs

• Cotton from Xinjiang region prohibited under UK + US WRO + EU FLR
• Indian / Pakistani embroidery sub-tiers carry forced-labour risk
• Migrant labour in UAE / Gulf manufacturing requires recruitment-fee audit
• Leather tanneries in South Asia historically high-risk
• Migrant garment workers in Turkey require Sedex / SA8000 audit
• Subcontracting transparency: Tier 2 + Tier 3 mapping mandatory

Documentation packet — what suppliers must provide

1. Sedex SMETA 4-pillar audit (current within 12 months)
2. SA8000 certification or BSCI audit
3. Recruitment-fee no-charge attestation per worker
4. Tier-2 fabric mill + Tier-3 fibre origin disclosure
5. Cotton-origin certificate (non-Xinjiang attestation)
6. Worker-grievance mechanism documentation
7. Annual modern-slavery training certificate for supplier staff
8. Remediation case log (with closure evidence)

Decision tree — when does this framework apply?

• Is your global turnover > GBP 36 m (UK) or AUD 100 m (AU)? Statement required
• Do you carry on business in UK / AU? Acts apply regardless of HQ
• Are you sourcing cotton, leather, electronics from high-risk regions? Heightened diligence
• Are workers migrant or recruited via agency? Recruitment-fee audit needed

Penalties for non-compliance

• UK: court orders requiring publication; reputational + tender-debarment risk
• Australia: public name-and-shame on Modern Slavery Register
• Loss of access to public-sector contracts (UK Procurement Act, AU Cth procurement)
• Civil litigation under tort claims for negligence

How we help

• Annual Sedex SMETA 4-pillar audit refreshed per supplier
• Tier-2 + Tier-3 traceability for cotton, polyester, leather lines
• Recruitment-fee no-charge attestation in supplier contracts
• Pre-formatted modern-slavery statement data pack
• Audit closure tracking with evidence per non-conformity
• Cotton-origin certificate (US WRO + EU FLR aligned)

Related frameworks

• Csrd Procurement
• Fcpa Uk Bribery
• Iso 9001 14001 27001

Related resources

• Glossary of compliance terms
• Material catalogue
• Sustainability report 2026
• Data Processing Addendum
• Whitepapers and reports

Frequently asked questions

Are we above the threshold?

UK GBP 36 m global turnover; AU AUD 100 m global revenue; Norway, Canada, Germany, EU CSDDD have separate thresholds.

What if our supplier sub-contracts?

You must reasonable-effort map sub-contracting tiers; we provide Tier-2 + Tier-3 traceability.

Is Sedex SMETA enough?

SMETA 4-pillar is widely accepted for risk-based diligence but not exhaustive; supplement with worker-grievance data.

How do we handle high-risk geographies?

Heightened diligence: third-party audit, recruitment-fee verification, worker-voice tools, on-site visit.

What about Xinjiang cotton?

Prohibited under US Uyghur Forced Labor Prevention Act and increasingly under EU FLR; we provide non-Xinjiang origin certificates.