[Home](/)/[Resources](/resources)/UK Modern Slavery Act UKSupply Chain # UK Modern Slavery Act: Supply Chain Transparency Obligations for Hardware Companies If your electronics business turns over £36 million or more and supplies into the UK, you need an annual modern slavery transparency statement on your website — signed by a director and submitted to the government registry. The Home Office has been publicly naming non-compliant companies, and institutional investors and procurement teams actively screen the registry before awarding contracts. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fuk-modern-slavery-act-supply-chain) At a glance Law Modern Slavery Act 2015 (Section 54) Threshold £36m annual turnover Statement Annual, board-approved, published Mandatory From 2015 (enforcement strengthening 2024+) ## What the Modern Slavery Act requires ### Transparency statement obligation — annual, board-approved, publicly published Section 54 of the Modern Slavery Act 2015 requires commercial organisations with annual turnover above £36 million that supply goods or services in the UK to publish a modern slavery and human trafficking transparency statement every financial year. The statement must be approved and signed by a director (or equivalent) of the company, published on the organisation's website with a prominent link from the homepage, and submitted to the government's modern slavery statement registry. ### Six recommended reporting areas — what the Home Office expects The Home Office's statutory guidance identifies six areas that a statement should address: the organisation's structure, business, and supply chains; policies in relation to slavery and human trafficking; due diligence processes in supply chains; risk assessment and management; key performance indicators to measure effectiveness; and training on modern slavery and human trafficking. Statements that address all six areas credibly — with specific evidence rather than generic policy commitments — are rated substantially higher in Home Office compliance assessments. ### Government registry — mandatory submission from 2021 Since 2021, in-scope companies must submit their statement to the government's online modern slavery statement registry (modern slavery statement registry portal). Statements that are not submitted to the registry, or that are submitted late, are noted as non-compliant in the registry's public records. The Home Office publishes compliance data and has named non-compliant companies publicly — a reputational risk that many procurement teams and institutional investors actively screen for. ### Sector risk for electronics — minerals, PCB fabrication, and assembly The electronics supply chain is flagged by the Home Office and the Gangmasters and Labour Abuse Authority (GLAA) as a high-risk sector for forced labour and human trafficking. Specific risk areas include artisanal and small-scale mining of tin, tantalum, tungsten, and gold in conflict-affected regions; PCB fabrication in countries with documented labour rights concerns; and large-scale electronics assembly operations where subcontracting practices can obscure conditions several tiers below tier-1 suppliers. ## How to produce a compliant modern slavery statement 01 Confirm whether your organisation is in scope — the £36 million turnover threshold applies at group level for corporate groups, meaning a UK subsidiary of a large multinational is likely in scope even if its individual turnover is below the threshold; parent company statements can cover subsidiaries but must describe each entity's supply chain specifically. 02 Map your tier-1 and tier-2 suppliers — identify the factories, fabrication partners, and raw material suppliers for your highest-volume components, document their locations and ownership structures, and cross-reference against the Home Office's supply chain risk guidance and ILO country profiles. 03 Conduct supplier due diligence appropriate to the risk level identified — for electronics supply chains this may include social compliance audits (RBA Validated Audit Program, Sedex SMETA, or equivalent), supplier self-assessment questionnaires, worker voice mechanisms, and desktop analysis of publicly available risk data for each key source country. 04 Draft the statement covering all six recommended reporting areas with specificity — the Home Office's transparency in supply chains guidance and the registry's own assessment criteria both penalise vague, boilerplate statements; include actual findings from your due diligence, specific actions taken in response to identified risks, and measurable KPIs with year-on-year performance data. 05 Submit the signed statement to the government modern slavery statement registry within six months of your financial year end, link it from your website homepage, and ensure the statement is signed by a director — statements signed only by a compliance manager or legal counsel do not meet the statutory requirement. ## Frequently asked questions ### Which companies must comply with the Modern Slavery Act? Section 54 applies to commercial organisations that: supply goods or services in the UK (not just UK-incorporated companies — overseas companies supplying into the UK market are in scope); have an annual turnover of £36 million or more; and carry on a business, or part of a business, in the UK. The threshold is assessed at group level for corporate groups. Charities and public bodies are not captured by Section 54 but may have separate public sector modern slavery obligations under related guidance. ### What must the statement actually say about electronics supply chains? The Home Office expects statements from electronics companies to go beyond generic policy statements and address the specific risks in their supply chain. This means naming the countries of sourcing for key components, describing the due diligence steps taken for high-risk inputs (particularly minerals and assembly operations), reporting on any incidents of forced labour or trafficking identified during the year, and explaining what corrective actions were taken. Statements that simply assert 'we have a supplier code of conduct' without evidencing how it is implemented receive low compliance ratings. ### Are there penalties for non-compliance? The Modern Slavery Act does not impose financial penalties directly on companies that fail to publish a statement — but the Secretary of State can seek a High Court injunction compelling compliance, which carries contempt of court sanctions if breached. In practice, enforcement has been reputational rather than legal: the Home Office publishes lists of non-compliant companies, procurement teams and institutional investors use the registry to screen suppliers and portfolio companies, and media coverage of named non-compliant companies in high-risk sectors has driven compliance more effectively than formal enforcement. ### How does the Modern Slavery Act relate to the EU CSDDD? The UK Modern Slavery Act Section 54 is a transparency obligation — it requires disclosure of what you have done to address modern slavery risk, but does not mandate that you actually identify, prevent, or remediate it. The EU Corporate Sustainability Due Diligence Directive (CSDDD) goes significantly further: it requires large companies to conduct active due diligence and take remedial action when adverse human rights impacts are found. UK companies with EU operations or EU-facing supply chains may be in scope of CSDDD in addition to the Modern Slavery Act, requiring a substantially more rigorous due diligence program than the Act's disclosure-only requirement. **Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions. 🇬🇧 UK roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇬🇧 UK compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/09-ukca-marking-for-electronics-products)[Prefer to read? 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