59 Virtual Brochure – March 2025 Structure, content and compliance of the Modern Slavery Statement Issues include: • Statements that are silent or lack detail regarding one or more of the six recommended areas (above). To aid transparency, statements can be structured in line with these six areas, addressing each in sufficient level of detail. • Contents are often heavily focused on supply chains. A greater emphasis on other risk areas, including staff and students, should go hand in hand with the development of institutions’ modern slavery agendas in business areas beyond procurement. • Statements should be published on the government online modern slavery statement registry soon after their approval. As part of the Government Transparency in Supply Chain consultation, it is expected this will become a mandatory requirement in future. • Institutions may wish to benchmark statements against those of peer institutions and industry leaders, drawing on the good / best practice identified. Policies The risk of non-compliance may not be adequately mitigated through institutions’ policy frameworks, through a failure to support stakeholders in how to identify modern slavery risks and report them. We have observed: • No specific and standalone Anti-Slavery and Human Trafficking Policy, or a policy existed but lacked visibility and accessibility, was out of date, or there was a lack of clarity around ownership and / or had a procurementdriven focus. Policies should outline the institutions’ commitment and expectations from all stakeholders, updated in response to changes to risks, legislation and standards and communicated to all stakeholders. • Other policies do not mutually link or refer to modern slavery. There are opportunities to reflect and explicitly embed modern slavery in institutions’ wider policy frameworks, identifying relevant connected policies through a review of the policy landscape as a first step.
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