Haulage sits close to modern slavery risk in ways that are not always comfortable to say out loud: agency labour, subcontracted driving, cheap labour supplied into warehouses and cross-docks, and drivers recruited from overseas. Parliament’s answer for larger businesses was not a licence or an inspection but a publication duty - section 54 of the Modern Slavery Act 2015, the Transparency in Supply Chains provision. If your transport business is big enough to be caught, you must publish a statement every year.
The Home Office guidance on publishing an annual modern slavery statement is the starting point. Certain commercial organisations must publish an annual statement setting out the steps they have taken to prevent modern slavery in their own business and in their supply chains. The requirement bites on organisations carrying on a business, or part of a business, in the UK with an annual turnover of £36 million or more.
That threshold matters to haulage in both directions. A regional operator running forty artics may be comfortably below it. A national logistics group, or an operator that has grown by acquisition, may be over it without anyone in the compliance office noticing the year it happened.
The guidance is precise here, and precision matters. “Total turnover” means the turnover of the organisation and any of its subsidiary undertakings, including subsidiaries operating wholly outside the UK. Turnover itself means the amount received from the provision of goods and services falling within the ordinary activities of the organisation or its subsidiaries, after deducting the items the guidance lists.
Two practical consequences follow. First, you cannot duck the threshold by splitting the fleet across group companies - the group number is what counts. Second, an overseas subsidiary still contributes its turnover to the test even though its operations never touch the UK. A group with a modest UK fleet and a large continental arm can be caught on the combined figure.
The statement is an annual public document describing what the organisation does to identify and prevent modern slavery in its operations and supply chains. It is a transparency duty, not a certification: the Act does not prescribe that your policies must reach a particular standard, but the statement must be published, and what it says - or conspicuously fails to say - is visible to customers, employees, journalists and the labour market.
For a transport business, the honest content tends to cover the same ground: how agency and subcontracted drivers are vetted, what right-to-work and recruitment checks run across the supply chain, how drivers can report exploitation, and what happens when a subcontractor’s labour practices raise a flag. The operator with nothing to say in these areas has found its first action list.
Below £36 million the legal duty does not apply, but the commercial shadow of it does. Large shippers and retailers - who are above the threshold - write modern slavery expectations into their carrier tenders and framework agreements, because their own statement must describe their supply chains, and you are their supply chain. The questions arrive as tender appendices: do you audit your agency labour, what training do supervisors get, how do you handle a disclosure from a driver.
An operator of any size that can answer those questions with documents rather than silence is easier to buy from. The small-fleet version of the statement work - vetting agencies, checking subcontractor labour, giving drivers a route to raise concerns - is the same work, scaled down, without the publication duty.
An annual duty means an annual rhythm, and the statement from three years ago describing policies nobody remembers is its own kind of exposure. Each year’s statement should reflect the business as it is - new contracts, new labour sources, new countries of operation - and what changed since the last one. The businesses that treat the statement as a living document tend to be the ones whose underlying checks actually run, because writing honestly about nothing happening is uncomfortable enough to make something happen.
The Home Office guidance walks through whether your organisation needs to publish and what the statement involves. The sensible sequence for a caught business: confirm the turnover test on the group basis the guidance describes, map where labour enters your operation - direct, agency, subcontracted - document the checks already running, close the obvious gaps, then write the statement from reality rather than from a template. A statement that describes real checks is defensible. A template that describes fictional ones is a liability waiting for its audience.