Information note: 009

Previously issued: February 2023

Updated: February 2025

Issue

1. The government is committed to tackling the scourge of modern slavery (an umbrella term that encompasses the offences of slavery, servitude, forced and compulsory labour and human trafficking). Departments must take action to ensure modern slavery risks are identified and managed effectively in government supply chains.

Dissemination and scope

2. This Procurement Policy Note (PPN) applies to all central government departments, their executive agencies and non-departmental public bodies when awarding public contracts^{[footnote 1]} for goods and/or services and/or works, other than special regime contracts.^{[footnote 2]} Such bodies are referred to as ‘in-scope organisations’.

3. Please circulate this PPN within your organisation, particularly to those with a commercial procurement and/or contract management role. It may also be relevant to those in finance, operational and sustainability roles.

4. Other public sector contracting authorities may wish to apply the approach set out in this PPN.

5. This PPN has been updated to reflect new terminology introduced by the Procurement Act 2023 and the Procurement Regulations 2024. The Procurement Act 2023 and the Procurement Regulations 2024 apply to procurements commenced on or after 24 February 2025. For more detail on the meaning of ‘commenced’ please refer to the Procurement Act 2023 Guidance on Transitional and Savings Arrangements.

6. The Procurement Act 2023 does not apply to procurements commenced before 24 February 2025 or to contracts awarded prior to this date (including via frameworks, dynamic purchasing systems or qualification systems established under the previous legislation). For procurements commenced and contracts awarded before this date, please refer to PPN 02/23 (PDF, 110KB).

7. This update does not constitute a change in policy or a new call for action but in-scope organisations should continue to apply any ongoing obligations set out in the provisions of this PPN. In-scope organisations do not need to repeat actions which were required upon this PPN’s initial publication.

Timing

8. In-scope organisations should note the provisions of this PPN from 24 February 2025.

Action

9. In-scope organisations must use PPN 009 Guidance - Tackling Modern Slavery in Government Supply Chains, to identify and manage risks in both new procurement activity and existing contracts.

10. In-scope organisations should note the characteristics used for assessing the risk of modern slavery in procurements, have been updated to include current global modern slavery risks in key sectors of concern such as cotton, PPE and polysilicon.

11. In-scope organisations should note there is a requirement for supply chain information to be provided for new procurements designated as having a high risk of modern slavery.

12. In-scope organisations should note there is additional guidance on enhanced due diligence activities and on using existing exclusion grounds more effectively.

Background

13. In 2021 the International Labour Organisation estimated that there were 50 million people living in modern slavery across the world. Modern slavery is thought to be prevalent across the UK and can occur in any business sector. To tackle these crimes, the Modern Slavery Act 2015 was introduced. The Act consolidates and clarifies modern slavery offences, toughens penalties and prosecution, and introduces greater support and protection for victims.

14. While there are laws in place which punish instances of modern slavery, the government has the opportunity to use its extensive buying power to help mitigate the risks of it occurring in its supply chain by adopting effective processes and procedures, in both procurement and supplier management.

Contact

15. Commercial and procurement enquiries should be directed to the Crown Commercial Service Helpdesk on 0345 410 2222 or info@crowncommercial.gov.uk