Signed, Not Merely Published: A Board's 180-Minute Evidence Review Before a Modern Slavery Statement

For UK boards within scope of section 54 of the Modern Slavery Act 2015, the slavery and human trafficking statement can too easily become a drafting exercise. The document is prepared, reviewed for tone, approved and published. Yet the signature at the foot of the statement is not a stylistic endorsement. It is a board assertion that the organisation has taken steps during the financial year to ensure slavery and human trafficking are not taking place in its business or supply chains. The 180 minutes before signature should therefore be spent testing evidence, not polishing prose.

The signature is the control

The statutory requirement is straightforward: commercial organisations above the turnover threshold must publish a statement for each financial year, approved and signed by a director or equivalent. The statement must set out the steps taken during the year. Statutory guidance points boards towards structure, policies, due diligence, risk assessment, training, monitoring and remediation. The quality of the prose is secondary. What matters is whether each material claim can be traced to a record, a decision and a responsible owner.

A plain statement supported by contemporaneous evidence is stronger than an eloquent statement resting on management assertion. The board's task in the final three hours is to establish which is which.

A three-hour structure for the board

The review should be proportionate to the organisation's size and risk profile, but it should follow a disciplined sequence. The following structure can be used by the board, the audit committee or a designated committee acting under delegated authority.

0-30 minutes: confirm scope, signatory and approval route

The first half hour establishes the legal and governance perimeter. The board should confirm the reporting year, the entities covered, the approval date and the identity of the signatory. The statement should be consistent with the group structure and the annual report. If the statement is published on the government registry, the publication link and date should be checked.

Document checks include the board resolution or delegated authority, the prior year statement, the group structure chart and the publication confirmation. The minute should record the reporting year, the entities in scope, the approval route and the signatory's authority.

30-75 minutes: test the supplier evidence

The board cannot review every supplier record, nor should it try. A sample should be selected from high-risk categories, new suppliers and any supplier subject to a recent incident. The purpose is to test whether the claims in the statement are supported by evidence that is contemporaneous with the reporting year.

Red-flag questions include: Can this claim be traced to a specific supplier file? Is the evidence dated within the reporting year? Is it a supplier attestation, an audit or independent verification? Who reviewed it, and what did they conclude? Has any business unit failed to provide evidence? A generic policy document supplied by a third party is not the same as evidence of implementation.

The minute should record the sample selected, the exceptions found and management's response. If material gaps are identified, the board should consider whether the statement needs amendment or whether approval should be deferred.

75-120 minutes: interrogate remediation claims

Remediation is often the weakest link in a modern slavery statement. Claims that an organisation is 'working towards' remediation, or that it has 'zero tolerance', are not evidence. The board should ask for case data: how many grievances or incidents were identified, how many were resolved, over what period, and with what outcome. Worker voice evidence is particularly valuable. If the statement refers to remediation, the board should be able to identify the cases and the actions taken.

Red flags include no case data, unexplained changes in metrics, claims that no incidents occurred without supporting assurance, and reliance on supplier self-reporting alone. The minute should record whether the board is satisfied that remediation claims are supportable, and any limitations that should be reflected in the statement.

120-150 minutes: review the approval trail

The board should test the process that produced the statement. Who drafted it? Who reviewed it? Did legal, procurement, human resources and internal audit provide input? Is there a version history? Were challenges recorded, or does the file show only a final draft? Consistency with other published documents, including the annual report and supplier code, should be checked.

The minute should record the review chain and any unresolved disagreements. A statement approved without documented challenge is not necessarily wrong, but the board should know why no challenge was needed.

150-180 minutes: agree conditions and record the decision

The final half hour is for the decision and the minute. If evidence gaps are material, the board may approve subject to specific amendments and the placement of evidence on file, or it may defer. The minute should record the evidence reviewed, the questions asked, the answers received, the exceptions noted and the basis for approval. That record protects the board and improves the following year's review.

Red-flag questions for the chair

• Can we show the supplier evidence behind each material claim?
• Which claims rely on management assertion alone?
• What has changed since the previous statement, and why?
• Are there known incidents that are not reflected in the statement?
• Is the remediation data complete for the reporting year?
• Has any business unit declined to provide evidence?
• Does the statement overstate the maturity of the programme?
• Is the signatory comfortable defending this statement in public?

Document checks before signature

The board should expect to see the prior year statement and action log, supplier risk assessments, due diligence records, training completion data, grievance and whistleblowing logs, internal audit reports on supply chains, relevant board and committee minutes, the version history and the publication confirmation. These are not paperwork for its own sake. They are the evidence base for the signature.

Minute-taking points

The minute should be concise but complete. It should record the date and attendees, the reporting year and scope, the evidence sample and exceptions, management responses and owners, the board's conclusion and any conditions, and the signatory and publication route. A well-drafted minute allows a later reader to understand what the board tested and why it was satisfied.

Conclusion

The 180-minute review is not a substitute for year-round due diligence. It is a proportionate board control before a public assertion is made. The statement should be signed because the evidence supports it, not because the publication deadline has arrived. A board that can trace each material claim to a record, explain the limitations and minute its challenge is better placed to stand behind what it publishes. For clients of 3HR plc, the practical discipline is simple: treat the statement as a board assertion, and test it accordingly.