contracts

Modern Slavery Clauses, Explained (2026)

Adira EditorialLegal AI desk5 min read

A modern slavery clause is the part of a contract where a supplier promises there is no forced labour, servitude or human trafficking in its business or supply chain, agrees to help you meet your own reporting duties, and accepts audit and termination if it falls short. These clauses spread quickly once transparency laws made large companies report publicly on what they are doing to find and prevent modern slavery. The contract became the tool to push that duty down to the suppliers where the real risk sits. This guide explains the law, what a strong clause contains, and how to flow it down the chain. It is general information, not legal advice; confirm a live deal with a qualified lawyer. ## Why modern slavery clauses exist The main driver is transparency legislation rather than a direct ban in contract law. - The UK Modern Slavery Act 2015, at section 54, requires a commercial organisation that carries on business in the UK and has a total annual turnover at or above the threshold set by regulations (set at 36 million pounds) to publish an annual slavery and human trafficking statement. The statement sets out the steps the organisation has taken to make sure slavery and trafficking are not in its business or supply chains, or states that it has taken none. It must be approved at board level and published on the organisation's website.

  • Australia's Modern Slavery Act 2018 requires entities above a consolidated revenue threshold to submit an annual modern slavery statement to a public register.
  • California's Transparency in Supply Chains Act requires large retailers and manufacturers doing business in the state to disclose their efforts to address slavery and trafficking in their supply chains. These laws do not usually impose fines for the slavery itself in the same way, but they create strong pressure to report credibly, and a credible report depends on what a company can actually see and control in its supply chain. Contracts are how that control is built, so a modern slavery clause both reduces risk and gives the company something concrete to describe in its statement. ## What a strong modern slavery clause contains A well-built clause usually combines promises, cooperation and remedies: - Compliance covenant. The supplier agrees to comply with all applicable anti-slavery and human trafficking laws, naming the UK Modern Slavery Act 2015 and any local equivalents.
  • No slavery warranty. A direct statement that no modern slavery, forced or compulsory labour, servitude or human trafficking exists in the supplier's business or supply chain, so far as it is aware after reasonable checks.
  • Policies and procedures. A commitment to maintain its own anti-slavery policies, due diligence and training, and to keep records that evidence them.
  • Flow-down. A duty to impose equivalent obligations on its own subcontractors and suppliers.
  • Information and audit rights. The right to request information, certifications and, where justified, to audit the supplier's practices and sites.
  • Cooperation with reporting. A duty to provide the information the buyer needs for its own slavery and human trafficking statement.
  • Notice and remediation. A duty to notify any actual or suspected breach promptly, and to remediate, often with a plan and timeline rather than instant termination, because cutting off a supplier can leave affected workers worse off.
  • Remedies. Suspension and termination rights for serious or unremedied breach, with an indemnity where justified. ## Remediation before termination Modern slavery clauses differ from many compliance clauses in one respect: the better response to a finding is often to require remediation rather than to terminate at once. Walking away can harm the very workers the law is meant to protect and can hide the problem rather than fix it. Many buyers now draft a graduated response: notify, investigate, agree a corrective action plan, and reserve termination for cases where the supplier will not engage or the breach is severe. The clause should make this expectation explicit. ## Flowing obligations down the chain Modern slavery risk usually sits several tiers down, with raw materials and lower-tier labour, not with the direct supplier. So the clause has to travel. Require each supplier to impose equivalent anti-slavery terms on its own subcontractors and suppliers, to keep information and audit rights alive down the chain, and to treat a failure to flow down as a breach. This is how a buyer can honestly describe supply-chain due diligence in its statement. ## A short drafting checklist 1. Name the applicable laws (UK Modern Slavery Act 2015, local equivalents).
  1. State the compliance covenant and the no-slavery warranty.
  2. Require policies, due diligence, training and records.
  3. Include flow-down to subcontractors and suppliers.
  4. Add information, certification and proportionate audit rights.
  5. Require cooperation with the buyer's statement.
  6. Build a graduated remediation path, with termination for serious or unremedied breach. ## Keeping modern slavery terms consistent across a supplier base The difficulty is scale and consistency: making sure the right anti-slavery terms sit in every supplier contract, and finding the agreements that have a weak clause or none. That work, surfacing missing or weak clauses, editing them in plain English, and keeping a structured view of which contract holds which protection, is what an AI contract workspace can hold in one place. Adira is built for this, with a per-clause favourable, neutral or unfavourable risk view, a structured clause tree and plain-English clause editing with a diff; it is India-first today with other jurisdictions on its roadmap, so verify local depth before relying on it. More at Adira. The guidance above stands on its own. ## Bottom line A modern slavery clause turns transparency law into supplier promises, cooperation and remedies. The UK Modern Slavery Act 2015 section 54, along with Australia's Act and California's supply-chain law, pushes large companies to report credibly, and the contract is how they build the control behind that report. Match the clause to the risk, prefer remediation over instant termination, flow the terms down the chain, and get legal advice for high-risk sectors and regions.

Frequently asked questions

What is a modern slavery clause?
It is the part of a contract where a supplier promises there is no forced labour, servitude or human trafficking in its business or supply chain, maintains anti-slavery policies and due diligence, helps the buyer with its own reporting, and accepts audit and termination rights. It turns transparency law into enforceable supplier obligations.
What does section 54 of the UK Modern Slavery Act 2015 require?
It requires a commercial organisation carrying on business in the UK with annual turnover at or above the regulated threshold (set at 36 million pounds) to publish an annual slavery and human trafficking statement, approved at board level and placed on its website, describing the steps it has taken to ensure slavery and trafficking are not in its business or supply chains.
Should a modern slavery clause allow immediate termination?
Usually it should allow termination for serious or unremedied breach, but the better first response to a finding is often remediation. Cutting off a supplier at once can leave affected workers worse off and hide the problem, so many buyers use a graduated path: notify, investigate, agree a corrective action plan, and reserve termination for severe or uncooperative cases.
Do modern slavery clauses need to flow down the supply chain?
Yes. The real risk usually sits several tiers down, so good practice is to require each supplier to impose equivalent anti-slavery terms on its own subcontractors and suppliers, keep information and audit rights alive down the chain, and treat a failure to flow down as a breach.
Is this guide legal advice?
No. It is general information about modern slavery clauses and transparency laws. Reporting thresholds and the right clause strength depend on your turnover, sector and supply chain, so confirm the detail with a qualified lawyer.
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