Section 54 of the Modern Slavery Act 2015 requires firms with £36m+ turnover to publish a board-approved annual statement — but for FCA-regulated firms, that's the floor, not the ceiling. PRIN 1 and PRIN 3 extend governance obligations to supply chain labour practices and third-party working conditions, and under SM&CR, the Senior Manager with oversight of operational risk personally owns the modern slavery question. The annual statement is public. The FCA can read it. The FCA doesn't wait.
What's included:
Full legislative mapping: Modern Slavery Act 2015 s.54, FCA PRIN 1 & 3, SM&CR, POCA 2002, Bribery Act 2010, Equality Act, NMW Act, and Working Time Regulations
Three-tier supplier classification: High (enhanced questionnaire, site visits, annual review), Medium (biennial), and Low (triennial) — with mandatory contractual clauses including audit rights and termination provisions
Employment safeguards: recruitment fee prohibition, right to work verification, NLW minimum, direct bank payment, and freedom of movement explicitly protected
Vulnerable worker protections: enhanced safeguards for migrant workers, temporary staff, and young persons — with multilingual support and manager escalation training
Investigation timeline: 24-hour victim safety, 48-hour investigation establishment, 30-day completion — with NCA, police, and FCA reporting obligations
Annual statement requirements: seven mandatory content areas, board approval, director signature, and homepage publication within 6 months of financial year end
Governance accountability matrix: Board, Modern Slavery Lead, Compliance Officer, HR Director, and Procurement Manager — with defined responsibilities
+ much more
Who is this for?
Compliance Officers, Procurement Directors, HR Directors, SMF holders, and Board members at FCA-regulated firms who need a complete, board-approved Modern Slavery Policy that satisfies both Home Office transparency requirements and FCA governance standards.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
Section 54 of the Modern Slavery Act 2015 requires firms with £36m+ turnover to publish a board-approved annual statement — but for FCA-regulated firms, that's the floor, not the ceiling. PRIN 1 and PRIN 3 extend governance obligations to supply chain labour practices and third-party working conditions, and under SM&CR, the Senior Manager with oversight of operational risk personally owns the modern slavery question. The annual statement is public. The FCA can read it. The FCA doesn't wait.
What's included:
Full legislative mapping: Modern Slavery Act 2015 s.54, FCA PRIN 1 & 3, SM&CR, POCA 2002, Bribery Act 2010, Equality Act, NMW Act, and Working Time Regulations
Three-tier supplier classification: High (enhanced questionnaire, site visits, annual review), Medium (biennial), and Low (triennial) — with mandatory contractual clauses including audit rights and termination provisions
Employment safeguards: recruitment fee prohibition, right to work verification, NLW minimum, direct bank payment, and freedom of movement explicitly protected
Vulnerable worker protections: enhanced safeguards for migrant workers, temporary staff, and young persons — with multilingual support and manager escalation training
Investigation timeline: 24-hour victim safety, 48-hour investigation establishment, 30-day completion — with NCA, police, and FCA reporting obligations
Annual statement requirements: seven mandatory content areas, board approval, director signature, and homepage publication within 6 months of financial year end
Governance accountability matrix: Board, Modern Slavery Lead, Compliance Officer, HR Director, and Procurement Manager — with defined responsibilities
+ much more
Who is this for?
Compliance Officers, Procurement Directors, HR Directors, SMF holders, and Board members at FCA-regulated firms who need a complete, board-approved Modern Slavery Policy that satisfies both Home Office transparency requirements and FCA governance standards.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
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