Dame Sara Thornton publishes IASC study on links to the UK Government's Modern Slavery Statement Registry


The Independent Anti-Slavery Commissioner Dame Sara Thornton has today published an analysis of how businesses are using the government’s Modern Slavery Statement Registry. The review looked at a sample of 150 company registrations and found that many did not correctly link their modern slavery statement. Some businesses were giving inaccurate information.


Under section 54 of the Modern Slavery Act, businesses with a turnover of £36 million or more are required to publish an annual statement, setting out the steps that they are taking to address modern slavery risk in their operations and supply chains. A unique aspect of the act is that non-government entities – such as investors, consumers, academics and charities - are encouraged to participate in this exercise, reading statements and holding businesses to account.


By law, statements should be written annually, signed off by a company director and accessible from a prominent link on a company homepage. But many statements fail to meet these basic requirements. The Business and Human Rights Resource Centre’s analysis[1] of company reporting in 2021 estimated that 40% of in-scope businesses had not been compliant in the six years since the act had been introduced.


The government launched the registry in March 2021 as part of measures to increase corporate transparency and strengthen the Modern Slavery Act of 2015. Reporting into to the registry will only become mandatory when proposed legislation takes effect. Nevertheless, prompted by letters from the Home Office, thousands of companies have already signed up and voluntarily provided links.


In September 2021, Dame Sara asked the IASC team to investigate how companies were linking to the registry and whether it was fulfilling its potential as a resource for analysing modern slavery statements at scale.


The IASC team analysed 150 company registrations and found:

  • 45% took users directly to the page of the company’s modern slavery statement which is an important requirement for automated data analysis;
  • 12% took enquirers to policy or compliance-related sections of the website;
  • 31% of links went directly to the company homepage;
  • 7% of links were broken;
  • 5% of companies claimed not to have websites, (3% were claiming this inaccurately).


The team then analysed a separate sample of 33 companies that claimed not to have a website. Such businesses do not have to publish online, but are legally required to submit a statement in writing to anyone who requests it, within 30 days of receiving the request.


The team found:

  • 24 or 73% of the companies in the sample claimed not to have websites but in fact did so;
  • Out of the group of 24 that had websites, 12 companies had published a modern slavery statement. The other half had no visible statement.



Dame Sara Thornton, Independent Anti-Slavery Commissioner, commented:

“The government is to be congratulated for fulfilling its commitment to build a centralised on-line registry. Over the long term, this should become an invaluable resource for researchers and those holding businesses to account. It is encouraging to see more than 23,000 registrations already on the site.

“However, my exploratory study suggests that there are implementation problems with the registry that need to be addressed. Many may be caused by misunderstandings and teething challenges. I am however puzzled that some businesses appear to be suggesting that they do not have a website when they in fact do so. 

“Transparency in supply chains is a central plank of the government’s modern slavery strategy. The registry is potentially a great tool but needs to work effectively to deliver value.

“There should be a concerted push for businesses to use the registry properly so that there is easy access to modern slavery statements. This will enable consumers, investors, NGOS and academics to scrutinise modern slavery statements in the way that the legislators envisaged.”


Sir Bernard Silverman, FRS of University of Nottingham Rights Lab, and one of the report’s authors, commented:

“Even this limited study shows a fascinating variation in the degree to which companies have published accessible Modern Slavery statements. Our intention is very much to encourage best practice and thereby ensure that the online registry can make the strongest possible contribution to the fight against Modern Slavery in all its forms.”


Read the report in full here.


[1] UK Modern Slavery Act: Missed opportunities and urgent lessons - Business & Human Rights Resource Centre (business-humanrights.org)



The Independent Anti-Slavery Commissioner has published an analysis of how businesses are using the Government’s Modern Slavery Statement Registry.