Modern slavery is a serious crime that hides inside ordinary supply chains — in cleaning, construction, agriculture, manufacturing and many other sectors. The United Kingdom has a specific transparency law aimed at getting larger businesses to look hard at their own operations and report on what they find. This article explains what that law requires, which companies it actually applies to, and why we choose to publish a statement even though we are not legally obliged to. It is general commentary on the regime, alongside an honest account of our own position.
The transparency duty in the Modern Slavery Act 2015
The relevant provision is section 54 of the Modern Slavery Act 2015, often called the “transparency in supply chains” duty. In broad terms, it requires certain commercial organisations to prepare and publish a slavery and human trafficking statement for each financial year. The statement sets out the steps the organisation has taken to make sure that slavery and human trafficking are not taking place in its own business or its supply chains — or states that it has taken no such steps, if that is the case.
The Act suggests the kinds of things a statement might cover: the organisation’s structure and supply chains, its relevant policies, its due-diligence processes, the areas where it sees risk, and any training it provides. The aim is not to certify that a supply chain is spotless — no one can guarantee that — but to drive genuine scrutiny and public accountability.
Who section 54 applies to
The duty does not fall on every business. It applies to commercial organisations that carry on business in the UK, supply goods or services, and have an annual turnover at or above a set threshold — a figure measured in the tens of millions of pounds. The policy reason is straightforward: the largest organisations have the most extensive supply chains and the most leverage to influence them.
Smaller companies sit below that threshold and are therefore not legally required to publish a statement. That is the category most growing businesses are in, including us. The law does not compel a statement at our size.
Why we publish one anyway
We publish a modern slavery statement voluntarily, even though section 54 does not require it of a company our size. We think the reasoning a director might apply to their own business applies to ours: the fact that a duty is not yet mandatory is a poor reason to ignore a serious harm. Looking honestly at how you operate, and being willing to say so in public, is good practice regardless of turnover.
A voluntary statement also keeps us in the habit. As a business grows, the scale and complexity of its supplier relationships grow with it. Building the discipline of reviewing those relationships early means the practice is already in place if and when the legal threshold ever becomes relevant. You can read our current statement on our modern slavery page.
What this means — and what it does not
It is worth being clear about scope, because voluntary commitments can be over-read. Publishing a modern slavery statement is about the integrity of our operations and supply chains. It is a separate matter from how our lending is regulated. Our business lending to a company remains outside FCA consumer-credit regulation, and it is not covered by the Financial Ombudsman Service or the Financial Services Compensation Scheme — the modern slavery statement does not change any of that. The two simply address different things: one is about ethical operations, the other about the regulatory status of a financial product.
For company directors thinking about their own obligations, the practical takeaway is to check where your turnover sits relative to the threshold, and to treat the section 54 framework as a useful template even if you are below it. A short, honest statement — what your supply chain looks like, where the risks are, what you are doing about them — is more valuable than a long one full of reassurance.
If you want to understand the broader set of voluntary standards we hold ourselves to, our transparency page brings them together. Tackling modern slavery is everyone’s responsibility, and a statement is one small, public way of taking it seriously — whether or not the law yet requires it.
