Company Reporting on Raw Material and Sector-Specific Risks Under the Transparency in Supply Chains Clause in the UK Modern Slavery Act 2015



Type of Resource

PDF document

Year of Release






Sub Categories

Human Trafficking, Child Labour, Forced Labour, Migrant Workers

Issues Addressed

Human Rights, Labour


The objective of this report is to provide a snapshot of company Slavery and Human Trafficking Statements published in compliance with the TISC clause. We chose to focus on companies that produce or provide products and services which reach a large number of customers and/or other businesses, and to complement the Business & Human Rights Resource Centre’s analysis of FTSE 100 statements by looking at smaller companies, those
listed on other exchanges and private firms.


The report’s focus is companies who source raw materials associated with a heightened risk of modern slavery - cocoa from West Africa, mined gold, mica from India, palm oil from Indonesia, and tea from Assam - and companies operating in sectors that are widely recognized as being at heightened risk: garment production; hotels and accommodation; construction; football clubs (which due to the nature of their businesses include a wide range of functions including hospitality and retailing manufactured goods); and outsourcing companies. The report looks at 50 companies’ Slavery and Human Trafficking statements; 25 from companies sourcing raw materials, five each under each material; 25 from at-risk sectors, five from each sector.

It explores if and how companies include information on the particular raw material and sector-specific risks in their statements, looking particularly at the description of their operations and supply chains and their due diligence. These areas correspond broadly with points (a), (c) and (d) of s54(5) of the Act. The report's team also looked for relevant information in other documents available on the companies’ websites, for instance Codes of Conduct. CORE was interested in the extent to which companies are making connections between the risk of slavery and human trafficking, wider labour rights issues (such as wages and working hours) and economic factors, most notably the price paid for raw materials. The report itself does not allege directly that any of the named companies have slavery or human trafficking in their operations or supply chains. Where references are made to previously published materials making such allegations, it provides a link to the company response, where available.