How to write a modern slavery answer for UK tenders

The modern slavery question has landed, you’re hunting for the policy, and the person who knows your suppliers is unavailable until tomorrow.

Your answer needs clear evidence, even when you’re fitting the bid around delivery work and everything waiting at home.

What should a modern slavery tender response cover?

A strong response explains how your organisation identifies, prevents and addresses exploitation within its workforce and supply chains. It should cover relevant risks, supplier checks, staff training, reporting routes and responsibility for action.

Answer the exact question. State your legal reporting position, describe controls relevant to the contract and support claims with evidence. Separate what you already do from commitments you will deliver.

Skip the impressive-sounding paragraph about commitment and give a practical answer showing who checks what, how concerns are handled and how improvements are monitored.

Where modern slavery shows up in a tender

Modern slavery can come up in three different places in a tender, and each one needs a different kind of answer.

• The selection questionnaire. This is the early form (called an SQ, or a PSQ under the Procurement Act) where you confirm basic facts about your organisation. You’ll usually tick boxes to say whether you have to publish a modern slavery statement and whether anything rules you out. For higher-risk contracts, the buyer may add a few questions about your suppliers.
• Part of a wider question. A question about your supply chain, staff or social value might ask how you tackle modern slavery as one of several points. A short, focused paragraph usually does the job.
• A question of its own. This is less common and tends to appear on contracts where the risk is higher, such as cleaning, security, construction or agency staffing. It’s scored like any other quality question.

This guide is about writing that answer, whether it’s a full question or one part of a bigger one. If you only need to fill in the selection questionnaire, the section on checking your legal position below covers what you need.

Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. Risks can sit within labour agencies, subcontractors and the production of goods your organisation purchases.

For a healthcare provider, that might involve agency staffing or medical supplies. For a charity, outsourced cleaning and catering still deserve attention.

The buyer needs confidence that your organisation can recognise exploitation and respond safely. Depending on the tender, this may involve declarations, participation requirements, scored questions or contract obligations.

That distinction matters, because a thoughtful narrative can’t repair an inaccurate declaration and an attached policy won’t automatically answer a scored question.

Read the evaluation method before drafting. Establish whether the question tests compliance, delivery quality or both.

Then involve whoever understands recruitment, purchasing and safeguarding. You shouldn’t have to reconstruct the organisation’s controls alone at 9pm.

The strongest answer usually begins with a short internal conversation, followed by the right records.

Check your legal position and the buyer’s rules

Section 54 of the Modern Slavery Act 2015 requires qualifying commercial organisations to publish an annual modern slavery statement covering slavery, human trafficking and forced labour.

The test includes carrying on business in the UK, supplying goods or services and meeting the £36 million annual turnover threshold. Check the statutory turnover calculation and organisational scope before making your declaration.

Don’t assume charitable status automatically settles the question. An organisation’s activities and circumstances matter.

The Home Office’s transparency in supply chains guidance, titled Transparency in Supply Chains, explains the reporting requirements, approval arrangements and recommended content.

A modern slavery statement is an annual statement describing steps taken during the financial year. A policy sets out organisational rules. Your tender answer explains how those arrangements apply to this contract.

Each one has a different job, so keep them separate in your answer.

Qualifying statements require the appropriate approval and signature. Where the organisation has a website, publication requirements include a prominent homepage link. Government guidance recommends publication within six months of financial year-end.

Smaller organisations may still be asked for proportionate policies, supplier checks or a voluntary statement.

If the statutory duty doesn’t apply, explain that accurately. Then answer the buyer’s remaining requirements. “Below the reporting threshold” doesn’t tell an evaluator how you manage agency workers or subcontractors.

PPN 009 guidance sets out a risk-based approach to modern slavery in government supply chains.

Its scope includes central government departments, executive agencies, non-departmental public bodies and NHS bodies, subject to stated exceptions. It covers procurement activity and existing contract management.

For new high risk procurements, the Procurement Specific Questionnaire, or PSQ, requests relevant supply-chain information. Buyers may also add questions, request evidence or set tender clauses and other contractual controls.

The Procurement Act 2023 regime applies to procurements started on or after 24 February 2025. Earlier procurements continue under the previous rules. Scotland has separate procurement arrangements.

Check the regime and policy version named in your tender pack.

Procurement thresholds are a separate matter from the £36 million reporting threshold, so don’t confuse the two.

Your practical task is to identify what this buyer requires, and to leave out requirements you’ve seen elsewhere that don’t apply here.

Map your risks and build a proportionate policy

High-risk sectors include the construction industry, healthcare and social care, cleaning, security, catering, textiles and electronics manufacturing.

Sector alone doesn’t determine risk. Recruitment arrangements, worker vulnerability, location and subcontracting also matter.

Check who supplies labour, whether recruitment fees could contribute to forced labour and whether workers can raise concerns safely. Consider excessive overtime, withheld documents and unexplained wage deductions.

For care services, review agency arrangements alongside safeguarding processes. Keep worker exploitation visible, as a general safeguarding policy may not cover every risk.

Start with suppliers supporting this contract. Use supply chain mapping to record what they provide, where it originates and which subcontractors are involved.

For higher-risk purchases, carry out due diligence beyond your immediate supplier where practicable. A UK distributor’s address doesn’t establish where products were manufactured or how workers were recruited.

The government’s Anti-slavery Risk Tiering Tool guidance explains a structured risk assessment for procurement.

For an SME, a maintained supplier register can be a sensible starting point. Record evidence reviewed, gaps identified and follow-up actions.

Be honest about visibility. Explain how you prioritise the unknowns, and avoid claiming oversight you can’t demonstrate.

A modern slavery policy for small and medium enterprises should fit their operations and exposure. A lengthy document borrowed from a multinational can create promises nobody owns.

Give responsibility to a named role with authority to act. Explain how procurement, recruitment, operations and safeguarding staff contribute where relevant.

Your policy should describe supplier assessment, workforce checks, reporting routes and escalation. It should also explain how concerns are addressed and how actions are reviewed.

Make reporting accessible to agency workers and subcontracted staff, as well as employees with access to your intranet.

Check that recruitment arrangements address worker-paid fees and the retention of identity documents. Explain how relevant staff recognise warning signs, and provide training staff can apply in practice.

Training should match responsibilities. Someone purchasing goods needs different practical guidance from a manager supervising agency workers.

Set a review cycle your team can maintain. Link additional reviews to significant changes, incidents or new supplier risks.

Then test the policy with one straightforward question: could a colleague use it to decide what to do next?

If they need three further documents and an unavailable director, improve the route.

Write your answer and back it with evidence

Build the answer around the buyer’s wording. Mirror its sub-questions so an evaluator can find each answer.

1. Confirm your position. State whether the statutory statement duty applies. Identify the relevant modern slavery policy or statement, its approval status and any requested publication details.
2. Explain the contract risks. Describe relevant labour arrangements, purchases and subcontractors. Show which risks you have prioritised and why.
3. Describe the controls. Explain onboarding checks, supplier requirements, recruitment safeguards and monitoring. State who performs each activity.
4. Show the response route. Describe safe reporting, escalation, specialist advice and corrective action. Include how the buyer will be informed where required.
5. Provide evidence and commitments. Support current practice with records. Give future actions an owner, deadline and reporting route.

Keep the distinction between current practice and future commitments clear.

If training is scheduled, call it scheduled. If supplier mapping is incomplete, explain the remaining work and its priority. Approval to make a promise must come before submission.

Use your limited word allowance for actions and evidence. Several sentences announcing your commitment leave less room for details the evaluator needs.

Evidence should show that your controls operate. A policy sets expectations, and completed records show those expectations are being met.

Match each claim to an appropriate record.

Claim	Useful evidence
Suppliers are assessed	Completed assessments and follow-up records
Staff receive relevant training	Attendance records and training content
Concerns are escalated	Reporting procedure and anonymised action records
Risks are reviewed	Dated risk register and meeting actions
Improvements are tracked	Corrective-action log and closure evidence

Choose measures relevant to the service. These might include training completion, overdue supplier assessments and outstanding corrective actions.

Follow the buyer’s reporting timetable. Don’t invent a monthly dashboard when the contract requires quarterly reporting.

Protect personal information. Anonymised evidence should demonstrate your process without exposing workers or sensitive investigations.

The Modern Slavery Assessment Tool, or MSAT, supports a supplier risk assessment by identifying gaps and improvement actions.

The Government Commercial Agency’s supplier guidance explains how it fits within modern slavery procurement policy.

MSAT isn’t universally mandatory for bidders. A buyer may invite its use, or an equivalent assessment, depending on the procurement.

If you’ve completed it, explain relevant findings and actions taken. Completion alone doesn’t establish that your supply chain is free from exploitation.

Assessment is useful when it changes decisions, checks or follow-up.

Explain how you handle concerns and exclusion risks

Your answer needs a safe, workable response route.

If someone is in immediate danger, call 999. For non-emergency police reporting, use 101. The Modern Slavery Helpline is 08000 121 700.

Staff should know how to escalate concerns internally without confronting suspected exploiters or conducting an unsafe investigation.

Describe who coordinates the response, records information securely and obtains specialist advice. Keep immediate safety and longer-term corrective action distinct.

The National Referral Mechanism, or NRM, is the UK’s framework for identifying and supporting potential victims. Referrals must be made by designated first responder organisations. An ordinary business cannot make an NRM referral itself.

Adult referrals require informed consent. Children aged 17 and under don’t need to consent to referral.

Ending a supplier relationship immediately can increase risks to exploited workers. Prioritise safety and specialist advice before deciding how to manage the relationship.

Remediation means addressing harm and correcting the conditions that allowed it. Your response may involve supplier corrective actions, recruitment changes and follow-up checks.

Avoid promising automatic termination for every concern. Explain proportionate escalation, while recognising that suspension or termination may be necessary in some circumstances.

Under the Procurement Act 2023, qualifying modern slavery convictions can engage mandatory exclusion grounds.

Specified orders or sufficient evidence of relevant misconduct without a conviction can engage discretionary exclusion grounds. An allegation alone doesn’t automatically determine exclusion.

The assessment also considers whether the circumstances are continuing or likely to recur. Suppliers may present evidence of remedial measures, often called self-cleaning.

For specified Modern Slavery Act offences, including sections 1, 2 and 4, the relevant look-back period is five years. Different grounds and procurement regimes need separate checking.

Treat declarations as a compliance task requiring proper internal confirmation. Get input from the people responsible for legal, governance and supplier matters.

Where there is a relevant history or unresolved concern, obtain procurement legal advice before answering.

Don’t let the writer make a legal judgement because everyone else is busy. Whoever owns the bid may not have the authority to make legal calls, so bring in the person who does.

Avoid common mistakes and check the final draft

“Zero tolerance” gives the buyer little detail about your checks or response arrangements. Follow any commitment with the process supporting it.

Another common problem is treating an attached statement as the complete response. Unless the instructions permit that approach, answer the question within the required field.

Watch for broad claims about every supplier being audited. Check what the organisation actually does, which suppliers are covered and how findings are followed up.

Training claims need the same discipline. “All staff are trained” may conflict with attendance records or the policy’s stated audience.

Reused answers can rely on generic or outdated material. Check the live modern slavery policy, including its references, reporting dates and responsibilities, against the tender requirements.

Finally, don’t promise staffing, audits or reporting activity that your delivery budget cannot support.

The relief of winning lasts longer when mobilisation doesn’t begin with a list of commitments nobody approved.

A credible answer gives the buyer confidence and your delivery team something they can use.

Give the answer a short, separate compliance and evidence check.

• Confirm every part of the question is answered.
• Verify the statement declaration, dates and approval details.
• Match risks to the proposed contract.
• Check claims against available records.
• Confirm owners and approval for future commitments.
• Test attachments, word limits and portal requirements.

Ask a reviewer to identify where the evaluator still has to assume something.

An evaluator-led tender review can help spot unsupported claims, missing detail and inconsistencies before submission.

Your team keeps ownership of the answer, and independent challenge helps you improve what reaches the buyer.

It also gives you a clearer stopping point. That matters when you have read the same paragraph so often it starts looking unfamiliar.

Frequently asked questions

Key takeaways

A strong modern slavery tender response connects the contract’s risks with practical controls and verifiable evidence.

Keep legal reporting duties separate from the buyer’s requirements. Describe current arrangements accurately, give future actions clear ownership and make the reporting route safe.

For smaller organisations, proportionate processes are credible when people understand and use them. Show how you identify gaps, prioritise risks and follow through, even where your visibility is still incomplete.

You can write a stronger answer without carrying every check alone. Your team holds the operational knowledge; independent review helps make it clear and assessable.

At Bidsmithery™, Bid Win Rate Accelerator Training builds that capability. A bid review retainer can provide regular challenge around your pipeline.

Book a free fit call to discuss what would help your team.

An external red review is about protecting energy, confidence and headspace while giving your submission a proper check.