By 2019, the U.K. Modern Slavery Act, introduced in 2015, had begun to show more visible signs of traction across industries, particularly in the retail and manufacturing sectors. According to Home Office data released that year, there was a marked 30% increase in modern slavery statements filed by companies—an indication that businesses were not only becoming more aware of their reporting obligations, but also starting to take supply chain risk assessment more seriously. This surge in disclosures coincided with growing public scrutiny, investor pressure, and evolving expectations from regulators, all of which placed modern slavery risks squarely on the corporate governance agenda.
For large retailers, this uptick presented both a challenge and an opportunity. While the rise in published statements reflected a broader commitment to transparency, it also laid bare the inconsistencies in the depth and quality of disclosures. Some companies continued to rely on generic, high-level declarations that offered little insight into actual supply chain practices. Others began experimenting with more detailed risk assessments, supplier engagement strategies, and measurable indicators of progress. The landscape was evolving rapidly, with companies recognizing that a mere statement of intent would no longer suffice in the eyes of stakeholders.
One of the most practical steps retailers could take at this stage was to integrate existing open guidance—such as that provided by the Legal Services Commission (LSC)—into their supplier management processes. The LSC’s materials offered clear, actionable recommendations on legal compliance and best practice in addressing modern slavery risks. By aligning supplier self-assessment questionnaires with this guidance, companies were able to create a more structured, legally robust framework for evaluating supplier conduct. This integration ensured that supplier surveys did more than gather cursory information; they became tools for eliciting meaningful data on policies, procedures, and real-world practices related to labor rights.
The structure of these self-assessment questionnaires evolved to include sections covering recruitment practices, use of labor brokers, grievance mechanisms, and training programs for employees and subcontractors. Companies found that by standardizing these assessments and linking them directly to LSC guidance, they could better benchmark supplier responses and identify red flags early. The process not only supported compliance efforts but also built a culture of dialogue with suppliers, encouraging continuous improvement rather than one-off reporting.
To make sense of the growing volume of data collected through these assessments, the next logical step for many retailers was to develop centralized risk scorecards. These scorecards served as dynamic tools for tracking supplier performance over time, consolidating information from self-assessments, audits, and external risk indices into a single, coherent view. The goal was not merely to categorize suppliers as high, medium, or low risk at a single point in time, but to create a system that could reflect changes in risk levels as new data became available or as circumstances on the ground evolved.
Building such a scorecard required thoughtful design. Core metrics typically included supplier location (with weighting for countries or regions identified as high risk in external reports), sector-specific risk factors, and findings from recent assessments or audits. Additional points were assigned based on supplier responsiveness to remediation requests, participation in training, and the transparency of their own supply chains. Retailers who invested in these systems found that updating the scorecard on a quarterly basis allowed for more agile decision-making, whether in prioritizing audits, allocating supplier development resources, or reporting to boards and investors.
These quarterly updates served another critical function: they demonstrated a company’s commitment to active risk management rather than passive compliance. As regulatory expectations grew and civil society actors began scrutinizing statements more closely, companies that could point to a living risk management process—one informed by real data and regular review—stood out as leaders in the field. For many, this approach also helped future-proof their operations against potential regulatory tightening, as discussions continued in Parliament and among advocacy groups about strengthening the Act’s enforcement provisions.
2019 marked a year when supply chain risk assessments under the U.K. Modern Slavery Act began to shift from formality to substance. The combination of open guidance resources like those from the LSC, thoughtful supplier engagement, and the use of centralized, data-driven risk tools provided large retailers with a clearer path forward. It was a period that revealed both how far companies had come and how much work remained to turn statements into sustained action against modern slavery.