UK brands are increasingly judged on who makes their clothes. Here's what the Modern Slavery Act expects — and why a short, transparent supply chain makes it straightforward.
The UK Modern Slavery Act 2015 requires any commercial organisation supplying goods or services in the UK with a global annual turnover of £36 million or above to publish an annual transparency statement — setting out the steps they take to ensure that modern slavery and human trafficking are not taking place in their operations or supply chains. But even brands well below that threshold face the same practical questions: UK retail buyers carry out their own supply chain due diligence, and ESG expectations across the fashion industry have made supply chain transparency a commercial requirement as much as a legal one. This guide covers what the Act expects, what constitutes a credible statement, and what to ask a factory for.
Section 54 of the Modern Slavery Act (the "transparency in supply chains" provision) requires qualifying organisations to publish a statement covering, as a minimum, some or all of the following:
A description of your business — what you do, where you operate, and who your suppliers are. For a knitwear brand, this means naming your manufacturing countries, key supply chain tiers, and the nature of those relationships. A brand with a single-factory manufacturing relationship can write this section briefly and accurately; a brand with a multi-tier opaque supply chain in multiple countries faces a harder task.
What policies does your organisation have in place to address modern slavery risk? These might include a supplier code of conduct, a human rights policy, or an ethical trade policy. If you are a small brand without a full compliance department, a clear and honest supplier code of conduct that you share with factories is the starting point.
What steps do you take to assess and address modern slavery risk in your supply chain? For knitwear brands, this typically includes factory visits, audit documentation requests, supplier questionnaires and the approach you take to identifying and addressing issues. The quality of the answer depends entirely on how much visibility you have into your supply chain.
How do you identify the parts of your supply chain that carry the highest modern slavery risk? Fashion and textiles are consistently identified by the Home Office and by academic research as high-risk sectors — particularly where production involves multiple sub-tiers, migrant labour, or operations in lower-income markets. Acknowledging and addressing that risk, rather than simply asserting it doesn't exist, produces a more credible statement.
Reporting on effectiveness — the number of supplier audits conducted, the percentage of supply chain covered by a supplier code, training completed, etc. These are optional elements that strengthen a statement but are not minimum requirements. For a single-factory relationship, the KPI section is straightforward: one named factory, documented relationship, periodic visits.
What training do your staff receive on identifying and responding to modern slavery risk? For small brands, this is often brief. For larger organisations with buying and sourcing teams, the expectation is more substantial. The Home Office's Modern Slavery Statutory Guidance provides examples of appropriate training content.
The most influential factor in a credible Modern Slavery statement is not the quality of the writing — it's the structure of the supply chain itself. A brand whose knitwear is produced in a single, named, visitable factory has a genuinely simpler risk profile than one with a multi-tier chain across multiple countries. This is because:
In a single-site factory, knitting, finishing, QC and despatch happen under one roof. There is no Tier 2 sub-contractor doing the actual knitting in a location you've never visited, no yarn spinner you've never audited, no homework economy doing piece-work finishing in someone's home. The supply chain is visible because it is short. A brand can describe it accurately in its statement because it is knowable.
Social audits (SMETA, BSCI) become exponentially more complex as supply chain tiers multiply. A single-site factory requires one audit, covering one payroll, one set of employment contracts, one working-hours record. The audit burden is proportionate; the results are meaningful because they cover the whole production chain, not just the visible top tier.
A direct relationship with a factory founder — where you communicate directly with the person responsible for employment decisions — creates a different accountability structure than buying through an agent who sources from a factory you've never met. The Modern Slavery Act's due diligence expectations become easier to meet when the relationship is direct.
The UK Home Office has been clear that it expects statements to go beyond boilerplate — a statement that says "we take modern slavery seriously" without demonstrating the supply chain structure that supports that claim is not credible. A statement that names a specific factory, describes the manufacturing relationship and references a factory visit is qualitatively stronger.
The legal name of the manufacturing entity, its full address, the country of registration, and the name of the person responsible for the business. This is the minimum for your supply chain map — you must be able to name your Tier 1 manufacturer accurately. Refusing to provide this information is a significant red flag.
Ask directly: is any part of the production sub-contracted to another facility? A factory that sub-contracts knitting, finishing or embellishment to a third party without your knowledge creates a Tier 2 that is outside your visibility. Confirm that all production occurs in the named facility.
Headcount, employment status (direct employees vs agency workers), and whether the factory uses migrant labour or seasonal workers. This allows you to assess the risk profile and address it in your due diligence process. It does not need to be provided in granular detail — overall workforce structure is sufficient for a supply chain mapping exercise.
If the factory has previously completed a SMETA, BSCI or SA8000 audit, the report can be shared on the Sedex / amfori platform (or directly) to support your due diligence documentation. Not all factories will have standing audits — but awareness of the audit frameworks and willingness to facilitate one on request is a positive signal.
A statement from the factory management describing working hours, wage rates, freedom of association position and health & safety arrangements. Even a short written statement from the factory owner — not a formal audit — provides useful documentation for your due diligence file and the "policies" section of your Modern Slavery statement.
If your retail buyers require it — and some department stores and large retail chains do — a formal SMETA audit commissioned at the factory provides the highest-standard due diligence documentation. We can facilitate a SMETA audit on request (cost: approximately £800–£1,500 borne by the brand). See our guide to ethical trade audits for detail.
The Home Office publishes examples of stronger and weaker Modern Slavery statements. The distinguishing characteristics of a stronger statement for a knitwear brand are:
| Element | Stronger statement | Weaker statement |
|---|---|---|
| Supply chain description | Names the manufacturer, country, factory address | "We work with overseas manufacturers" |
| Risk assessment | Identifies fashion/textiles as high-risk sector; assesses Tier 1 specifically | "We are committed to ethical sourcing" |
| Due diligence | Factory visit(s) referenced; supplier questionnaire completed | "We conduct supplier checks" |
| Policies | Supplier Code of Conduct shared with factory; signed | "We have a code of conduct" |
| Actions taken | Specific steps described; any issues found and remediated | No specific actions described |
If your brand's annual turnover is below £36 million, a published Modern Slavery statement is not legally required. However:
John Lewis, M&S, ASOS and most significant UK retailers operate supplier codes of conduct that apply to all of their suppliers regardless of the supplier's own turnover. If you want to trade with them, you will answer their supply chain questions. Having a good answer ready — based on actual supply chain visibility — is a competitive advantage in retail buying conversations.
UK consumer research consistently shows that a meaningful proportion of UK fashion buyers consider supply chain ethics in purchasing decisions. For premium and mid-market knitwear brands, "made in Turkey, in a factory we visit, from certified yarns" is a positive story that can be told in marketing — but only if it is actually true and documented.
The government has consulted on lowering the £36 million threshold, potentially to £2 million. If enacted, a larger proportion of UK fashion brands would face the legal obligation. Building sound supply chain documentation now — regardless of current threshold — means you are ready if and when the obligation applies to you.
A brand that genuinely knows who makes its products, has visited the factory, and maintains supplier documentation is simply better governed. The Modern Slavery Act framing should not be the only motivation — knowing your supply chain is basic commercial due diligence for any brand building long-term reputation on quality and ethics.
Kiwi Giyim is a single flat-knit factory in Gaziantep — 22 machines, 50+ in-house team, founder-run since 2010, no agency layer, no sub-contracting. You work directly with Mehmet Özbakır — the factory is named, visited and documented. We provide the factory information, workforce details and documentation your Modern Slavery position needs.
Manufacturer Pages