How to spot modern slavery at work – and what the law requires

How to spot modern slavery at work – and what the law requires

If you employ staff, use contractors, or buy in goods and services, modern slavery risk could already sit inside your supply chain – not just overseas.

Car washes, nail bars, agricultural work, cleaning contractors, food processing plants. These are all sectors where modern slavery has been uncovered in the UK, often supplying mainstream businesses. If you employ staff, use contractors, or buy goods and services, you need to be aware of how this could affect you.

This article explains what modern slavery training for UK businesses should cover, and what the law requires of you. You’ll also learn how to help staff spot the warning signs before they become a much bigger issue.

Modern slavery could be closer to your supply chain than you think

Modern slavery covers forced labour, human trafficking, debt bondage and criminal exploitation. It’s not confined to a handful of high-risk industries – it turns up wherever there’s a demand for cheap, flexible labour and limited oversight.

In 2025, the National Referral Mechanism received 23,411 referrals of potential victims of modern slavery in the UK, a 22% increase on the previous year. That’s the highest figure recorded since the mechanism began.

Labour exploitation was the single most common type of exploitation among referrals, accounting for 36% of the total – itself a 37% rise on 2024. Supply chains involving subcontractors, agency staff or overseas suppliers carry particular risk, especially where no one takes clear ownership of the checks needed.

This is why modern slavery awareness training for staff matters for every business, not just those in construction, agriculture or hospitality.

What the Modern Slavery Act requires of your business

The Modern Slavery Act 2015 is the main piece of UK legislation covering this area. Section 54 applies to commercial organisations that carry on a business, or part of a business, in the UK and supply goods or services. If your annual turnover is £36 million or more, you must publish a modern slavery statement every financial year. It should set out the steps they’ve taken to prevent slavery and trafficking in their operations and supply chains.

The statement must:

  • Be approved by the board (or members, for a limited liability partnership), with the approval date clearly stated.
  • Be signed by a director, with their name and job title included.
  • Be published on your website, with a clear link to it from your homepage.

Government guidance also recommends publishing your statement as soon as possible after your financial year ends and, at most, within six months. It recommends covering six areas, including your supply chain structure, policies, due diligence, risk assessment, key performance indicators and staff training.

If your organisation is below the £36 million threshold, you’re not legally required to publish a statement. But the Act doesn’t stop being relevant just because you’re smaller. Any UK business can end up unknowingly using suppliers or subcontractors involved in exploitation. The ethical, operational and reputational risks don’t disappear just because your organisation is smaller.

It’s also worth flagging that guidance and legal duty aren’t the same thing. The government’s guidance sets out best practice for meeting section 54, but it doesn’t create new legal obligations beyond what’s already in the Act. Always check the current government guidance if you’re unsure how it applies to your organisation.

Spotting the signs of modern slavery at work

Most people assume they’d recognise modern slavery if they saw it. But victims rarely announce themselves, and the signs are often subtle enough to be missed or explained away.

Common indicators your staff should be trained to notice include:

  • Workers who seem anxious, fearful or reluctant to speak freely, especially in front of a particular colleague or supervisor.
  • Having little or no control over personal documents or finances, such as someone else holding their passport or controlling their bank account.
  • Being dropped off and collected in groups, always by the same vehicle or driver.
  • Signs of physical neglect or injury, including poor hygiene, exhaustion or untreated health issues.
  • Living at their workplace, or in overcrowded accommodation tied to their employer.
  • Debts owed to an employer or recruiter that seem to grow rather than shrink over time.

No single sign proves exploitation is taking place. But a pattern of several signs, particularly among agency staff, subcontracted workers or new starters, should be taken seriously and reported through the appropriate channels.


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Building modern slavery training into your business

Training shouldn’t sit with one compliance officer or HR lead. The people most likely to spot warning signs are often those furthest from head office: site managers, procurement teams, recruitment staff and frontline supervisors.

A few practical steps make this easier to embed:

  • Include modern slavery awareness in induction. New starters, including agency and temporary staff, should understand what to look for from day one.
  • Give procurement and recruitment teams deeper training. They’re the ones assessing suppliers and agencies, so they need to know what good due diligence looks like.
  • Refresh training regularly. Risks change as your supply chain changes, so a one-off session isn’t enough.
  • Make reporting straightforward. Staff need to know exactly who to tell and how, without fear of getting it wrong.

Training that’s properly understood and used protects your organisation. Training that exists purely to tick a compliance box doesn’t.

What to do if you suspect modern slavery

If a member of staff raises a concern, or you spot warning signs yourself, don’t wait for certainty before acting. If someone is in immediate danger, call 999. Otherwise, you can contact the Modern Slavery Helpline on 08000 121 700 or report your concerns to the police.

Document what’s been observed, keep it confidential, and avoid confronting a suspected perpetrator directly, as this can put a victim at greater risk. Check your organisation’s safeguarding, whistleblowing or modern slavery procedures for the appropriate reporting and escalation route.

Modern slavery is easier to miss when organisations assume it couldn’t happen in their business or supply chain. Ask yourself: if a member of staff spotted something today, would they know exactly what to do next?

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Please note: This article provides general information about modern slavery and isn’t intended as legal advice. Organisations should seek appropriate advice about how the requirements apply to their individual circumstances.

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