Safe reporting culture

Anti-Slavery Day 2026: would you know if it was happening in your workplace?

23,411 potential victims were referred in 2025, a record. What Section 54, the 2025 guidance and the Fair Work Agency expect, and how a speak-up route helps.


Sunday 18 October is Anti-Slavery Day. It is a good moment to look past the statement on your website and ask a harder question: if one of your workers, or one of your suppliers' workers, were being exploited today, how would you find out?

The scale of the problem in 2025

The Home Office's end-of-year figures for 2025, published in February 2026, show that 23,411 potential victims of modern slavery were referred to the National Referral Mechanism last year. That is a 22% rise on 2024 and the highest number since the system began. Behind the totals:

  • Labour exploitation is the most common form for adults. 45% of adult referrals, 7,341 people, were for labour exploitation: people working in kitchens, car washes, cleaning crews, warehouses, farms, care settings and construction sites, often through an agency or a third party who controls their pay, documents or accommodation.
  • Children make up almost a third. 30% of referrals (7,028) were children, most often referred for criminal exploitation, including county lines.
  • UK nationals are the largest single group. 22% of referrals were UK nationals. Modern slavery is not only something that happens in distant supply chains. It happens on British high streets and in British workplaces.
  • Most referrals come from the state, not from employers. Government agencies made 58% of referrals and police 18%. Very few cases surface because a business spotted the signs and acted.

That last point matters. The people most likely to notice exploitation first are colleagues: the chef who sees a kitchen porter hand his wages to someone else, the housekeeper whose new colleague's passport is "kept safe" by the agency, the site manager who notices six people giving the same address. Whether that observation ever reaches someone who can act depends almost entirely on whether there is a safe way to say it.

What the law expects of organisations

Section 54 of the Modern Slavery Act 2015

Commercial organisations carrying on business in the UK with a turnover of £36 million or more must publish an annual slavery and human trafficking statement, approved by the board and signed by a director. The Home Office's updated statutory guidance, published in March 2025, was the first full overhaul in a decade, and it is notably more practical than the original. It says that audits on their own should not be relied upon to find modern slavery, and that they should be supplemented with worker-centred practices.

Specifically, the guidance encourages organisations to:

  • provide anonymous whistleblowing services, such as a helpline or a mobile phone app;
  • create multiple channels through which workers, including workers at suppliers, can raise concerns, in a language they understand;
  • assess those channels with senior leadership, and protect workers from retaliation;
  • take a victim-centred approach to remediation, avoiding knee-jerk reactions that could cause further harm.

In other words, the government's own guidance treats a working speak-up route as one of the clearest signs that a statement is backed by action.

Public procurement

The Procurement Act 2023, now in force, lists modern slavery and labour market offences among the mandatory grounds for excluding suppliers from public contracts, and allows exclusion on discretionary grounds including serious labour misconduct and evidence of modern slavery even without a conviction. For any organisation that sells to the public sector, how you detect and deal with exploitation is now a commercial question as well as an ethical one.

The Fair Work Agency

Since 7 April 2026, the Fair Work Agency has brought together the Gangmasters and Labour Abuse Authority, the Employment Agency Standards Inspectorate and the Director of Labour Market Enforcement under one roof. Labour exploitation in the UK is now enforced by a single body with a broader remit, which makes it more likely that problems in agency and subcontracted labour will be looked at closely.

Whistleblowing protection

A worker who reasonably believes that a criminal offence is being committed, or that someone's health or safety is in danger, and raises it in the public interest, is making a protected disclosure under the Public Interest Disclosure Act. Modern slavery offences fall squarely within that. Workers who speak up are protected from detriment and dismissal, and organisations need a process that treats their reports accordingly.

Why the usual routes fail

Most organisations already have a whistleblowing policy and a "speak to your manager" process. For modern slavery, both tend to break down in the same places:

  • The route runs through the problem. If the exploitation involves an agency, a gangmaster or a supervisor, telling that person is not an option. Neither, often, is telling their manager.
  • The people who see it are on the edge of the organisation. Agency staff, contractors, seasonal workers and supplier employees rarely have a company email address or access to the intranet where the policy lives.
  • People are not sure. Most concerns start as a feeling that something is wrong rather than evidence of a crime. Few people will call the police on a hunch, and many will not phone a helpline. They will, however, send a short message if it is easy, private and safe.
  • Nothing is joined up. A comment to HR, an email to a site manager and a remark in an exit interview may all point to the same supplier, but nobody sees the pattern.

How a speak-up platform helps

A dedicated reporting platform such as Speak Out Safe is built to close exactly those gaps, and to give your section 54 statement and your safeguarding policies something real to point to.

  • A route outside the hierarchy. Concerns go to a small, trained group of people you choose, not through the line management or agency structure that may be part of the problem.
  • Anonymous, but still a conversation. Reporters can stay anonymous and still answer follow-up questions, so a vague worry can become something you can act on, without the person ever revealing who they are.
  • Open to people outside the payroll. Agency workers, contractors, supplier staff and members of the public can report from their own phone, without needing a company email address or access to your intranet. A QR code on a staff-room noticeboard, a locker or a payslip is often all it takes. That is the "multiple channels" the statutory guidance asks for.
  • In a language they understand. Speak Out Safe works in 29 languages and can turn a voice note into text, so a worker with limited English, or limited confidence writing, can still be heard.
  • A record you can stand behind. Every report, decision and action is captured in one place, which gives you evidence for your annual statement, your board, your auditors and, if it ever comes to it, a regulator or tribunal.
  • Patterns, not just incidents. Reporting across sites and suppliers can show where concerns cluster, so you can direct due diligence where the risk actually is.
  • Protection for the reporter. Clear handling and an audit trail help you show that people who spoke up were treated fairly, which is what the law and your own culture require.

Technology does not replace judgement. When a report suggests someone is in immediate danger, call 999. Concerns about labour exploitation can be reported to the Fair Work Agency, and anyone can contact the Modern Slavery and Exploitation Helpline on 08000 121 700 for advice. A good platform makes sure those concerns reach the people in your organisation who can make those calls quickly.

Five steps for Anti-Slavery Day

  1. Read your own statement. Does it describe how workers, including agency and supplier staff, can raise a concern? If not, that is your first gap.
  2. Test the route. Ask someone on a night shift or an agency contract how they would report a worry about a colleague. Listen to the answer.
  3. Look at your higher-risk areas. Agency labour, cleaning, catering, logistics, construction and seasonal work deserve particular attention.
  4. Brief the people who receive reports. Make sure they know the indicators, the victim-centred response and when to involve the police or the Fair Work Agency.
  5. Put it in front of the board. Section 54 statements are approved by the board. Give them the evidence that your speak-up arrangements work, not just that they exist.

Frequently asked questions

We are under the £36 million threshold. Does any of this apply to us?

The statement requirement does not, but the criminal offences, public procurement rules and whistleblowing protections apply regardless of size. Many larger customers also expect their suppliers to show how they manage modern slavery risk, so smaller organisations are increasingly asked the same questions.

Is a whistleblowing hotline enough?

The statutory guidance encourages multiple channels for exactly this reason. A phone line suits some people. Many others, especially younger workers and people with limited English, are far more comfortable sending a short message or a voice note from their phone, in their own language. Offering both widens the net.

What should we do if a report suggests modern slavery?

Put the safety of the potential victim first. If anyone is in immediate danger, call 999. Otherwise, take advice, involve the police or the Fair Work Agency as appropriate, avoid tipping off anyone who may be involved, and record every step. Do not simply terminate the supplier relationship without thinking through what that would mean for the workers affected.

This article is general information, not legal advice. Take professional advice on your organisation's circumstances.

Speak Out Safe gives your people, and the people who work alongside them, a secure and anonymous way to raise concerns, and gives you a full audit trail of how each one was handled. Book a 30-minute demo to see how it works.

Sources: Home Office, Modern Slavery: National Referral Mechanism and Duty to Notify statistics UK, end of year summary 2025 (published 19 February 2026); Home Office, Transparency in supply chains: a practical guide (statutory guidance, updated March 2025); Procurement Act 2023; GOV.UK, Fair Work Agency.

Similar posts

Get notified on new marketing insights

Be the first to know about new B2B SaaS Marketing insights to build or refine your marketing function with the tools and knowledge of today’s industry.