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Policy Authority
Category: Ethics and Culture

Modern Slavery

Also known as: Modern Day Slavery
Simply put

Modern slavery is an umbrella term for situations where a person is exploited by others for personal or commercial gain and cannot refuse or leave because of coercion, deception, or threats. It covers several forms of exploitation, including forced labour, human trafficking, and forced marriage. It is widely recognised as a human rights violation and an exploitative crime.

Formal definition

Modern slavery is an umbrella term encompassing multiple forms of severe human exploitation, including forced labour, human trafficking, and forced marriage, in which individuals are exploited by others for personal or commercial gain and are unable to refuse or escape due to coercion, deception, or threats. Related concepts draw on the International Labour Organization's Forced Labour Convention, 1930 (No. 29), which defines forced labour as work or service exacted from a person under menace of a penalty and to which the person has not offered themselves voluntarily. The term does not correspond to a single universally codified legal definition; specific statutory definitions, reporting obligations, and enforcement mechanisms vary by jurisdiction and sector, and this entry does not address any particular national legislation or its due-diligence and disclosure requirements.

Why it matters

Modern slavery is widely recognised as a serious human rights violation and an exploitative crime, with severe consequences for the health and wellbeing of survivors. For organisations, it presents a compliance and reputational exposure that extends beyond their own workforce into supply chains, subcontractors, and third-party relationships, where exploitation such as forced labour or human trafficking may be concealed. Because the term spans several distinct forms of exploitation, the risks it raises can surface across procurement, recruitment, and operations in multiple jurisdictions simultaneously.

The compliance dimension is complicated by the absence of a single, universally codified legal definition. Statutory definitions, reporting obligations, due-diligence expectations, and enforcement mechanisms vary considerably by jurisdiction and sector. As a result, organisations operating across borders may face differing, and sometimes overlapping, requirements, and cannot assume that meeting the standard in one jurisdiction satisfies obligations elsewhere. This entry does not address any particular national legislation or its specific disclosure requirements, which should be assessed against the applicable legal regime.

The scale of the problem is substantial. The International Labour Organization has estimated tens of millions of people in situations of modern slavery worldwide, underscoring why boards, risk functions, and compliance teams treat it as a material human rights and governance concern rather than a peripheral issue. Because prevalence estimates and definitions are drawn from bodies such as the ILO, organisations typically align their understanding with those recognised sources rather than adopting ad hoc interpretations.

Who it's relevant to

Compliance officers
Compliance functions are typically responsible for interpreting how modern slavery obligations apply across the jurisdictions and sectors in which an organisation operates. Because statutory definitions and reporting requirements vary and no single universal legal definition exists, they commonly map the applicable obligations rather than assuming a uniform standard.
Risk managers
Risk managers assess the exposure that modern slavery, including forced labour and human trafficking, may pose across operations and third-party relationships. Their focus is on identifying and treating this exploitation risk against organisational objectives, recognising that it can be concealed and may span multiple jurisdictions.
Procurement and supply chain professionals
Those managing suppliers and subcontractors are often the first line for detecting indicators of exploitation within extended supply chains, where forced labour and trafficking risks may be present. Their due-diligence activities support the organisation's ability to identify and respond to such risks at their source.
Governance professionals and boards
Given that modern slavery is recognised as a human rights violation with reputational and compliance implications, governance bodies commonly treat it as a matter for oversight, ensuring appropriate decision rights, accountability, and reporting structures are in place across relevant jurisdictions and sectors.
Internal auditors
As an independent assurance function, internal audit may evaluate the design and operating effectiveness of the controls management has implemented to identify and address modern slavery risk. Their role is to provide objective assurance over those arrangements, distinct from the management activities they assess.

Inside Modern Slavery

Forced Labour
Work or service exacted from a person under threat of penalty and for which the person has not offered themselves voluntarily. It is one of the practices commonly grouped under the modern slavery umbrella, though its precise legal definition varies by jurisdiction.
Human Trafficking
The recruitment, transportation, transfer, harbouring, or receipt of persons through coercion, deception, or abuse of power for the purpose of exploitation. It is frequently addressed alongside modern slavery but is a distinct offence in many legal systems.
Debt Bondage
A condition in which a person's labour is pledged as security against a debt, where the value of the work is not reasonably applied to reducing the debt or the terms are indefinite. It is one recognised form of exploitation within modern slavery discourse.
Servitude and Slavery-like Practices
Conditions in which a person is compelled to provide labour or services and cannot freely leave, encompassing practices that may fall short of legal ownership but involve significant coercion and loss of freedom.
Supply Chain Transparency Obligations
Disclosure and reporting duties that certain jurisdictions impose on organisations to describe steps taken to identify and address modern slavery risks in their operations and supply chains. The applicability, thresholds, and content requirements differ across jurisdictions.
Due Diligence Processes
Risk management activities by which an organisation seeks to identify, assess, prevent, and mitigate modern slavery risks. These typically span governance oversight, supplier assessment, and remediation, and cut across the governance, risk, and compliance pillars.

Common questions

Answers to the questions practitioners most commonly ask about Modern Slavery.

Does modern slavery legislation only require organizations to eliminate slavery within their own workforce?
No. This is a common misconception. Modern slavery obligations in many jurisdictions extend beyond an organization's direct workforce to encompass its supply chains and, in some frameworks, its wider business relationships. The scope and the specific reporting or due diligence duties vary by jurisdiction, industry, and organization size, so entities should confirm which requirements apply to their particular circumstances rather than assume the duty is limited to internal employment practices.
Is publishing a modern slavery statement the same as demonstrating that no modern slavery exists in an organization's operations?
No. A statement is typically a transparency and disclosure mechanism describing the steps an organization has taken or plans to take; it does not, in itself, certify that operations or supply chains are free of modern slavery. Reporting requirements commonly focus on describing due diligence and risk management activities rather than guaranteeing an outcome. The distinction between disclosing effort and assuring the absence of harm is important and should not be blurred.
How does modern slavery relate to the governance, risk, and compliance pillars?
Modern slavery spans more than one pillar. It carries a compliance dimension where disclosure, due diligence, or reporting duties are imposed by applicable law; a risk management dimension in identifying, assessing, and treating human rights and supply chain exposures against objectives; and a governance dimension in assigning board and management accountability and decision rights for oversight. Treating it solely as a compliance filing task tends to understate the risk and governance responsibilities involved.
Which functions typically hold responsibility for modern slavery activities within an organization?
Responsibilities are commonly distributed across lines of activity. Operational management and procurement functions, often described as the first line, may own supplier engagement and day-to-day controls. Risk, compliance, or sustainability functions, often described as the second line, may set policy, monitor, and advise. Independent assurance functions such as internal audit may evaluate the effectiveness of these arrangements while preserving their objectivity. The allocation varies by organization, and the assurance role should remain distinct from the management activities it reviews.
What kinds of due diligence steps are commonly described in modern slavery contexts?
Frameworks commonly reference activities such as mapping supply chains, assessing risk by geography, sector, and supplier type, embedding contractual expectations, conducting supplier assessments or audits, providing training, and establishing grievance or remediation mechanisms. The specific expectations, and whether any are mandatory, depend on the applicable jurisdiction and framework. This entry does not cover implementation specifics, tooling, or legal advice, and organizations should confirm requirements against the authorities that apply to them.
How can an organization approach ongoing monitoring rather than treating modern slavery as a one-off exercise?
Monitoring is typically framed as a continuing process rather than a single event, given that supply chains and risk exposures change over time. Organizations commonly review and update risk assessments periodically, track the operation of relevant controls, and revisit their disclosures where reporting duties apply. Independent assurance may periodically evaluate whether monitoring arrangements are operating as intended, while remaining separate from the controls being assessed. The appropriate frequency and depth depend on the organization's risk profile and applicable obligations.

Common misconceptions

Modern slavery is only a concern for organisations operating in developing economies or high-risk regions.
Modern slavery risks can arise in many geographies and sectors, including through complex multi-tier supply chains that extend into lower-visibility suppliers. The relevance of the risk depends on an organisation's operations, sourcing, and labour practices rather than location alone.
Publishing a modern slavery statement means an organisation is compliant and the issue is resolved.
Where reporting obligations apply, a statement is typically a transparency measure describing steps taken; it does not by itself eliminate risk or guarantee that no modern slavery exists in operations or supply chains. Effective response depends on ongoing due diligence and remediation, not disclosure alone.
Modern slavery is purely a legal compliance matter handled by the legal team.
Addressing modern slavery commonly spans all three GRC pillars, requiring governance oversight and decision rights, risk identification and assessment, and compliance with applicable disclosure obligations. Treating it as a narrow legal task can leave operational and supply chain risks unmanaged.

Best practices

Confirm which jurisdictional reporting and disclosure obligations apply to your organisation based on its size, location, and sector, and note that thresholds and content requirements differ across jurisdictions.
Establish clear governance oversight and decision rights for modern slavery risk, so that accountability is defined rather than assumed to sit with a single function.
Embed modern slavery risk into existing risk assessment processes, distinguishing the inherent risk in operations and supply chains from residual risk after controls are applied.
Conduct due diligence across supply chain tiers, recognising that risks may be concentrated in lower-visibility suppliers beyond direct contractual relationships.
Design remediation and escalation pathways in advance, so that identified instances of forced labour, trafficking, or debt bondage can be addressed rather than only disclosed.
Treat any modern slavery statement as a description of steps taken and subject it to periodic review, keeping assurance over these activities independent from the management functions that operate them.
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