How to Write an SME Modern Slavery Statement and Ethical Labor Declaration¶

If you supply physical goods, raw materials, or components to large corporate buyers, you are no longer evaluated solely on price and quality. In the modern regulatory landscape, corporate buyers must prove their supply chains are clean of human rights abuses.

Under laws like the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, and Canada's newer Bill S-211, large enterprises must publish annual public statements detailing how they prevent forced labor, child labor, and human trafficking in their global supply networks.

Because your small-to-medium enterprise (SME) is part of their supply chain, their compliance depends entirely on your data.

Even if your business is well below the legal revenue thresholds that mandate filing your own statement, you will still receive urgent requests from your buyers demanding a signed Modern Slavery Statement or an Ethical Labor Declaration.

If you cannot provide this document, you represent a compliance risk. To protect their business, corporate buyers will terminate your vendor status and switch to a compliant competitor. Here is how to draft a legally robust, audit-ready declaration.

1. What is an Ethical Labor Declaration vs. a Modern Slavery Statement?¶

While closely related, these two documents serve slightly different purposes in B2B procurement:

• Ethical Labor Declaration: A self-declaration certifying that your company’s internal operations and direct suppliers respect fundamental labor rights (e.g., fair wages, safe working conditions, maximum working hours, and the right to associate).
• Modern Slavery Statement: A formal public-facing document (or structured B2B declaration) detailing the concrete steps your business has taken to identify and mitigate the risks of forced labor, human trafficking, and debt bondage in your multi-tier supply chain.

2. Key Criteria Your Statement Must Address¶

Enterprise compliance teams are highly skeptical of generic "we respect human rights" letters. A legally valid statement must address specific risk areas:

Supply Chain Mapping¶

You must state clearly where your suppliers are located and what commodities you are sourcing. If you are importing materials from high-risk countries or industries (such as textiles from Southeast Asia or minerals from Central Africa), you must declare what specific due diligence steps you have taken.

Corporate Policies¶

You must verify that your business has implemented formal policies, such as a Supplier Code of Conduct or a Whistleblower Policy, and that these policies have been communicated to your team and suppliers.

Risk Assessments¶

You must outline how you identify potential labor risks in your supply network. This typically involves using standardized questionnaires to audit supplier hiring practices (ensuring suppliers do not withhold worker passports or charge recruitment fees, which are primary indicators of forced labor).

3. How to Draft the Declaration (Mandatory Fields)¶

To satisfy corporate legal and procurement teams, your declaration should be a formal, structured PDF containing:

• Corporate Header: Your legal business name, physical address, and company registration number.
• The Commitment Statement: An unambiguous declaration of your commitment to eliminating forced labor and respecting human rights.
• Scope of Operations: A brief description of what your business does, what you manufacture, and where your primary suppliers are located.
• Supplier Due Diligence Steps: A detailed list of the actions you take to verify supplier compliance (e.g., executing supplier self-assessments, reviewing third-party social audits like SMETA, or maintaining a code of conduct).
• Board/Executive Approval: Under most legislation, a Modern Slavery Statement is only legally valid if it has been formally approved by your board of directors (or sole director/owner) and signed by a named executive officer.

4. Automating Human Rights Compliance with Sustalium¶

Chasing global suppliers for signed labor attestations and tracking social audit data via email is an administrative nightmare for lean SME teams.

Sustalium provides a dedicated Modern Slavery Statement software designed explicitly for this challenge.

Our platform replaces manual spreadsheets with a secure, structured supplier portal. We provide your suppliers with guided questionnaires to declare their labor practices. Sustalium securely stores this evidence at the supplier level and automatically compiles a professional, legally compliant Modern Slavery Statement or Canada Bill S-211 Report. You can share this instantly via a secure public link or PDF, proving your supply chain readiness to enterprise buyers.

Frequently Asked Questions¶

Are small businesses legally required to file a Modern Slavery Statement? Legally, no. In the UK, the threshold is £36M+ in annual turnover. In Australia, it is AUD $100M+. However, because these large enterprises are legally required to report on their Scope 3 supply chain, they enforce compliance contractually on all their SME suppliers, making it a functional commercial requirement.

Can I use the same statement for the UK, Australia, and Canada? While the core principles of supply chain due diligence are similar, each country has slightly different reporting templates, filing registries, and board attestation rules. Sustalium maintains jurisdiction-specific templates to ensure your outputs conform perfectly to local laws.

Last updated: June 1, 2026