The Modern Slavery Act 2015 – Is it relevant to small businesses?

The Modern Slavery Act 2015 (“MSA”) imposes reporting obligations on all commercial organisations supplying goods or services which carry on their business or part of their business in the UK, and which have a total turnover exceeding £36 million in any financial year.  The legislation requires these businesses to publish a slavery and human trafficking statement setting out the steps that they have taken to ensure that slavery and human trafficking is not taking place in their business or anywhere in their supply chains.

Whilst small businesses won’t be caught directly by the legislation, they may find contractual provisions relating to modern slavery creeping into their contracts where they form part of the supply chain for a larger entity that is subject to the rules.  In addition, recent guidance from the government has suggested that smaller companies should be seeking to comply with the reporting rules as a matter of good practice.  It is therefore important for small businesses to understand what the reporting requirements are and what information they may be expected to provide.

Rebecca Gardner, Corporate & Commercial Partner at Howat Avraam Solicitors comments:  The extent of human trafficking and modern slavery in the UK is difficult to pinpoint.  The National Crime Agency announced earlier this year that previous figures of 10,000 to 13,000 likely victims in the UK were just the “tip of the iceberg”.  As criminals seek to expand the sectors in which they operate, it is increasingly important for businesses operating in high risk industries (such as manufacturing, agriculture, fishing, hospitality and beauty salons) to take steps to minimise the risk, regardless of their size.


Howat Avraam Solicitors provide Corporate, Commercial, Employment, Intellectual Property and Contract Dispute advice to companies, business owners and individuals.  As business owners ourselves, we have a pragmatic in-house approach to resolving issues before they arise by working alongside our clients, as part of their team.  We are commercial, practical and entrepreneurial in our approach to legal services.

To discuss any Corporate or Commercial matter with us on a no obligation basis, please contact Rebecca Gardner on 020 3735 6700 or email Rebecca at  Alternatively, visit our website at for more information.

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