UK modern slavery reporting for China sourcing
Buying from China alone does not trigger reporting. The duty applies to qualifying companies and partnerships carrying on business in the UK, supplying goods or services, with total annual turnover of £36 million or more. Organise checks, escalation and records around actual production. China-based checks can be coordinated by Cambridge China Bridge.
Check whether your business must report
The reporting test combines legal form, UK business activity, supply of goods or services and total annual turnover of £36 million or more. It applies wherever the company or partnership was formed. Total turnover includes subsidiary undertakings operating overseas, so use the organisation’s total rather than its China purchasing spend or UK sales alone.
Ask finance to document the turnover calculation and a senior owner to record the applicability decision for the financial year. If you are below the threshold, a customer may still request supplier evidence or a statement. Keep that commercial request distinct from your own statutory reporting duty.
Build a map that guides the checks
Keep a supplier register connecting the contracting supplier, production site, product, recruitment agencies, subcontractors and key material sources. Mark unknown links explicitly. Prioritise checks where workers may face recruitment debts, withheld identity documents, restricted movement or threats, and where subcontracting makes working conditions difficult to see.
Assign a buyer to maintain each supplier record and a senior owner to review unresolved concerns. Revisit the assessment when a factory changes site, labour provider or subcontractor. Use the factory audit checklist for the wider site assessment; add worker-focused enquiries rather than treating a capability audit as labour-risk clearance.
Check working conditions beyond the audit
Ask who recruits workers, who pays recruitment costs, whether workers control their identity documents and whether they can leave employment freely. Compare the supplier’s answers with recruitment documents, wage records and confidential worker accounts gathered by competent specialists. Record unavailable evidence and contradictions instead of converting a questionnaire into a clean bill of health.
Our ethical audit guide explains customer audit schemes and report coverage. Use those reports as inputs to your assessment. Link each concern to an action owner, agreed completion date and evidence needed for closure; a supplier’s promise or an uploaded photograph may need independent follow-up.
Escalate concerns without exposing workers
Create a route from the buyer or China visit team to the senior owner and a competent labour-risk specialist. For credible signs of coercion, preserve the original account, restrict access to identifying details and assess worker safety before questioning management. Decide whether to pause new orders while enquiries proceed, and document the reasons.
Agree a response that addresses harm to workers, with safe ways for affected people to contribute. Review whether corrective action is working before closing the case. Avoid automatic termination without considering its effects on workers. If you need another source, the supply-chain resilience guide supports continuity planning alongside the worker-protection response.
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Turn the evidence into an accurate statement
For each financial year, keep a claim-to-evidence register covering supplier assessments, checks completed, unresolved gaps, incident decisions, corrective actions, worker outcomes and staff training. Separate completed work from future plans. Describe what changed after intervention and what remains uncertain; keep confidential case records separate from the public statement.
The statement reports steps taken in your own business and supply chains; it is not a guarantee that every supplier is slavery-free. For a company, confirm the approval and signature requirements with the relevant authority, publish on its website and place a prominent homepage link. Government guidance recommends publication within six months of financial year-end. Uploading to the government registry is voluntary.
Frequently asked questions
Does buying from China mean I need a modern slavery statement?
No. The reporting test concerns your organisation’s legal form, UK business activity, supply of goods or services and total annual turnover of £36 million or more.
Does overseas subsidiary turnover count?
Yes. Total turnover includes the organisation and its subsidiary undertakings, including those operating wholly outside the UK. Ask finance to document the calculation.
Is a factory social audit enough?
Use it as evidence, then check coverage, recruitment arrangements and unresolved findings. An audit report alone does not show whether later subcontracting or worker concerns have been addressed.
Should I cancel orders if forced labour is suspected?
Escalate promptly, protect worker identities and seek specialist support. Consider pausing new orders while investigating. Assess effects on workers before deciding on remediation or responsible disengagement.