What this is
What is a modern slavery and labour standards assessment?
What is a modern slavery and labour standards assessment?
A structured check of a site's direct workforce and its agency labour supply against the recognised indicators of forced labour: document retention, deductions, hours, freedom to leave, third-party control of transport and accommodation, and provider licensing. It is broader than a right to work check, which confirms legal entitlement to work but not whether the person entered that work freely.
Who should carry it out?
HR, working with procurement where agency or contracted labour is in scope. HR holds employment records and can interview workers directly; procurement holds the labour provider contracts and can see licensing and fee arrangements HR would not otherwise see.
Why does agency labour in food processing get called out specifically?
It is the setting most repeatedly identified in enforcement action: high churn, third-country recruitment, and shift patterns that make direct observation harder. The recognised indicators there will not surface by accident.
Scope
When is a modern slavery and labour standards assessment required?
This assessment sits inside the ethics and labour programme, bounded by the individual right to work check on one side and the published transparency statement on the other. It informs the statement; it is not the statement.
Use this template when
- The annual assessment cycle for the site is due
- A new labour provider or agency is being brought onto the site
- Agency labour is being used in a recognised high-risk setting, such as food processing
- A raised concern touches on pay, hours, documents or freedom of movement
- The workforce mix at the site has changed materially, in size or reliance on agency labour
Do not use it for
- Code of Conduct Acknowledgement, which records that a worker has read and accepted the code, not whether the workforce shows indicators of exploitation.
- Whistleblowing Report Record, which documents a concern already raised and how it was handled, not the proactive assessment that might have surfaced it first.
- Anti-Bribery Risk Assessment (CMP-043), the related but distinct ethical risk record for corruption exposure, linked from this one but not a substitute.
- A standalone right to work check, an immigration compliance record that does not ask about debt, documents, transport or fees.
- Assessing the labour provider purely as a commercial supplier, without the licensing and worker-treatment questions this template asks.
Compliance mapping
Which ISO 37301 cl.6.1 requirements does this satisfy?
No single instrument prescribes this assessment's format. ISO 37301 sets the risk-based expectation, transparency laws set the reporting duty, and the indicators come from ILO conventions and licensing bodies.
| Clause | Requirement | Where it lands |
|---|---|---|
| ISO 37301 cl.6.1 | Determine and address the compliance risks relevant to the organisation's activities, including labour and ethical risk | Outcome |
| ILO Forced Labour Convention, 1930 (No. 29) | Defines forced or compulsory labour and its indicators, including retained identity documents and debt bondage | Direct workforce |
| ILO indicators of forced labour | Recognised indicator set: withheld wages, excessive overtime, abuse of vulnerability, isolation | Awareness and reporting |
| Gangmasters (Licensing) Act 2004 (UK, GLAA) | Labour providers supplying workers into licensable sectors must hold and maintain a licence | Agency and labour providers |
| UK Modern Slavery Act 2015, s.54 | Qualifying organisations must publish an annual statement on steps taken against modern slavery | Outcome |
| ISO 37301 cl.6.1 | Consider the extended supply chain, not only the organisation's own operations, when identifying compliance risk | Related records |
What it does not cover
- Individual right to work check, a per-worker immigration compliance record kept alongside, not inside, this assessment.
- Anti-Bribery Risk Assessment (CMP-043), the related ethical risk record for corruption exposure, cross-referenced here but completed separately.
- Agency Labour Provider Assessment, which approves the provider commercially; this assessment covers treatment of the workers it supplies, and the two findings can differ.
- Whistleblowing investigation record, which documents handling of a specific concern once raised, not the proactive review this assessment performs.
- The published modern slavery statement itself, a separate statutory document this assessment's findings feed into, not a record this template produces.
Global
Modern Slavery and Labour Standards Assessment requirements by country
The duty to look for forced labour indicators is close to universal. What differs is whether a statement is legally required, at what threshold, and how enforcement bites.
Uyghur Forced Labor Prevention Act 2021; California Transparency in Supply Chains Act
No general federal duty to assess, but a rebuttable presumption bars import of goods linked to forced labour from a designated region; California requires due diligence disclosure from larger retailers.
The exposure is commercial, not reporting-based: goods can be detained, and the burden falls on the importer to prove otherwise.
Modern Slavery Act 2015, s.54; Gangmasters (Licensing) Act 2004
Qualifying organisations above the turnover threshold must publish an annual statement; labour providers in licensable sectors must hold a GLAA licence.
The statement duty is to disclose steps taken, not achieve an outcome, but a provider's licensing failure is a strict breach with no defence.
ILO Forced Labour Convention (No. 29) and its 2014 Protocol
Defines forced labour and sets out the indicator framework national laws and audit standards draw on.
Where no domestic statute names the indicators, the ILO framework is the reference point auditors and NGOs use to judge adequacy.
How to complete it
How to complete a modern slavery and labour standards assessment, step by step
The form asks yes, partly or no questions easy to answer generously. What makes the assessment worth doing is how those answers are obtained.
A worker asked in front of whoever controls their transport or employment will not disclose a fee paid for the job or a withheld document. The interview needs to happen away from the agency's own staff, ideally with an independent interpreter.
A copied certificate proves the provider can produce a document, not that the licence is current. Checking the licensing register directly closes a gap a supplied copy cannot.
Most assessments stop at the provider contracted directly. Asking who that provider in turn uses, and whether that sub-provider has been assessed, is where the assessment either reaches the actual risk or stops short of it.
A provider operating without a required licence, or workers who paid a fee for the job, are not findings to average into a risk band. They should trigger immediate concern and referral regardless of the overall score.
What auditors find
Most common modern slavery and labour standards assessment findings
These findings recur because the questions look answerable from records alone, when the answer that matters is usually not in the records.
| Finding | Clause | What fixes it |
|---|---|---|
| Assessment relies on right to work checks and treats them as covering labour standards. | ILO Forced Labour Convention, 1930 (No. 29) | Ask the document retention, deduction, hours and freedom-to-leave questions separately. |
| Agency worker interviews conducted through or in front of the provider's own staff. | ILO indicators of forced labour | Interview away from the provider and site supervisor, with an independent interpreter. |
| Provider licensing accepted from a supplied certificate without a register check. | Gangmasters (Licensing) Act 2004 | Check the current licensing register directly, not a copy the provider supplies. |
| Assessment does not ask about sub-providers beyond the first tier. | ISO 37301 cl.6.1 | Ask the tier-one provider who they in turn use, and whether that sub-provider was assessed. |
| A licensing gap or fee-payment finding is scored and averaged rather than escalated. | UK Modern Slavery Act 2015, s.54 | Route a licensing failure or fee payment to immediate concern and referral. |
| Confidential reporting channel exists but is not available in the languages the workforce speaks. | ILO indicators of forced labour | Confirm the channel is usable in the languages present on site. |
Case in point
Case in point: the assessment that stopped at the contract
A food processing site assessed its direct workforce and scored well: right to work checks complete, pay at minimum wage, hours within limits. The agency provider supplying seasonal packing staff was licensed, and its own paperwork showed no outstanding issues. The assessment recorded low risk and moved to the following year.
A worker's concern raised the following spring found the licensed provider was sub-contracting shifts to a second, unlicensed supplier during peak weeks, whose workers were housed together and transported in vehicles that supplier controlled. None of it reached the original assessment, because it had asked the licensed provider about its own workers and never who else supplied labour into the same shifts.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
6 sections
- Reference
- CMP-042
- Archetype
- Assessment
- Record ID
- MSL-2026-000
- Scoring
- Risk indicators
- Direction
- Low is good
- Singleton
- No
- Basis
- ISO 37301 cl.6.1
- Links
- Links Agency assessment, Supplier assessment
- Tags
- Ethics, Labour
- Sections
- 6
- Fields
- 45
- Follow up fields
- 3
- Repeating sections
- 0
- Links out
- 4
Header
10 fieldsAssessment ID*
Auto sequence. Format MSL-2026-000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Date and Time*
Completed By*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Period Assessed*
Assessed By*
Agency Workers In Scope*
Agency Labour In Food Processing Is High Risk
The recognised indicators are debt bondage, withheld documents, shared transport controlled by a third party, and several workers paid into one bank account.
Direct workforce
6 fieldsRight To Work Checks Performed*
- Yes3 pts
- No0 pts
Documents Held By Workers Themselves*
- Yes3 pts
- Partly1 pt
- No0 pts
Pay At Or Above Legal Minimum*
- Yes3 pts
- Partly1 pt
- No0 pts
Deductions Lawful And Explained*
- Yes3 pts
- Partly1 pt
- No0 pts
Hours Within Legal Limits*
- Yes3 pts
- Marginal1 pt
- No0 pts
Freedom To Leave Employment*
- Yes3 pts
- Partly1 pt
- No0 pts
Agency and labour providers
6 fieldsProviders Licensed Where Required*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Provider Assessed By Us*
- Yes3 pts
- Partly1 pt
- No0 pts
Workers Pay No Fees For Work*
- Yes3 pts
- Partly1 pt
- No0 pts
Transport Not Controlled By A Third Party*
- Yes3 pts
- Partly1 pt
- No0 pts
Multiple Workers Not Paid To One Account*
- Yes3 pts
- Partly1 pt
- No0 pts
Accommodation Not Tied To The Job*
- Yes3 pts
- Partly1 pt
- No0 pts
Awareness and reporting
6 fieldsManagers Trained On Indicators*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Workers Told How To Raise Concerns*
- Yes3 pts
- Partly1 pt
- No0 pts
Confidential Reporting Available In Their Language*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Concerns Received And Handled*
- Yes3 pts
- Partly1 pt
- No0 pts
Supplier Statements Obtained*
- Yes3 pts
- Partly1 pt
- No0 pts
Supply Chain Beyond Tier One Considered*
- Yes3 pts
- Partly1 pt
- No0 pts
Related records
1 fieldAnti-Bribery Assessment ID
The related ethical risk assessment.
Links to CMP-043 Assessment ID
Outcome
16 fieldsIndicators Present*
Risk Level*
- Low3 pts
- Medium1 pt
- High0 pts
- Very high0 pts
Immediate Concern Identified*
- No3 pts
- Yes0 pts
Referral Made Where Required*
- Not required3 pts
- Yes3 pts
- No0 pts
Statement Published Where Required*
- Yes3 pts
- Not required3 pts
- No0 pts
Next Assessment Due*
Risk Assessment
Risk ID
Format RSK-2026-00000.
Links to FDN-012 Risk ID
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
HR*
Signature*
Site Manager*
Second Signature*
CMP-042 · record IDs look like MSL-2026-000 · Links Agency assessment, Supplier assessment
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The assessment depends on someone asking the harder questions away from people with an interest in a clean answer, and a licensing lapse reaching a referral rather than a score.
Holds the assessment against the site and provider registers, flags a provider whose licence has lapsed, and keeps the evidence trail for the transparency statement together.
Watches for an immediate concern or a failed referral left open, and raises it rather than letting the annual cycle carry it forward unresolved.
Extends the check past the tier-one provider, prompting for sub-contracted labour arrangements the direct contract does not disclose.
Tracks whether managers due to be trained on the recognised indicators actually complete it.
This template lives in KnowComply — audit and governance. Audit programmes, legal register, management review, risk and certification.
Meet KnowComply→Glossary
Modern Slavery and Labour Standards Assessment definitions and key terms
- Debt bondage
- Work demanded to repay a debt, often a recruitment fee, where the debt is never fairly assessed against the work and the worker cannot leave until it is repaid.
- Forced labour indicator
- One of a recognised set of conditions, such as withheld wages, retained documents or debt bondage, used to identify forced labour when no single condition alone proves it.
- Labour provider licensing
- A statutory licence required in specified sectors before a business may supply workers to a third party, screening out exploitative operators.
- Tier one supplier
- The supplier or labour provider an organisation contracts with directly. Risk further down the chain is not visible unless asked about.
- Transparency statement
- A published annual statement, required in several jurisdictions above a size threshold, setting out steps taken against modern slavery in operations and supply chains.
FAQ
Frequently asked questions about modern slavery and labour standards assessment
Isn't a right to work check enough to show due diligence?+
No. It confirms legal entitlement to work, not whether the person paid a fee to get the job, holds their own documents, can leave freely, or controls their own transport. A workforce can pass every check and still show recognised indicators of forced labour.
Why does agency labour need different questions from direct employees?+
The mechanisms of exploitation differ. A direct employee is paid by the organisation and usually holds their own documents. An agency worker's pay, transport and documents can all run through the provider, which is where third-party control sits.
What if the labour provider's licence has lapsed?+
That is a fail condition, not a risk factor to monitor. It should trigger an immediate concern and referral, not be scored as though licensing were a matter of degree.
Do we need to look beyond the provider we contract with directly?+
Yes, where practical. Asking the tier-one provider whether they use sub-contractors, and whether those have been assessed, is the question most likely to surface a risk direct enquiry would miss.
Does a low risk score mean no further action?+
Only if no indicator was found. A single confirmed indicator, a fee paid for the job, a withheld document, controlled transport, should raise a concern regardless of the overall score, because indicators do not average out.
How does this connect to the published modern slavery statement?+
This assessment is the evidence base for the statement, not the statement itself. A statement asserting diligence that no underlying assessment supports is the gap regulators look for first.
Keep going
Related templates and programmes
Industries this is written for
Programmes this belongs to
Supplier Quality Assurance
Approved suppliers with evidence, and rejections that actually change behaviour.
Ethics, Labour and Anti-Bribery
A reporting channel people trust, and labour risk assessed where it actually sits.
Contracts and Purchasing
Nothing renewing by default, and no supplier trading before onboarding completes.
Used together in Supplier Quality Assurance
Transport Provider Assessment
Assesses a haulier for licensing, driver management, vehicle standards, temperature capability and load security
Supplier Environmental Assessment
Assesses a supplier's environmental performance and certifications
Vendor and Contractor Register
Holds every supplier, contractor and service provider you work with, including their status and approval level
Material Rejection Report
Rejects incoming material that fails inspection
Supplier Approval Record
Records the decision to approve a new supplier, with the evidence behind it
Supplier Questionnaire
Collects information about a supplier's systems, certifications and controls
More in Ethics and Conduct
Code of Conduct Acknowledgement
Records that a worker has read and accepted the code of conduct, at hire and on revision
Whistleblowing Report Record
Records a concern raised confidentially about wrongdoing, and how it was handled
Conflict of Interest Declaration
Records a declared interest that could affect a business decision, and how it will be managed
Anti-Bribery Risk Assessment
Assesses exposure to bribery and improper payments across procurement, permits, inspections and customer relationships
Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- ISO 37301:2021 clause 6.1, Compliance management systems
- UK Modern Slavery Act 2015, section 54
- ILO Forced Labour Convention, 1930 (No. 29), and the 2014 Protocol
- Gangmasters (Licensing) Act 2004 and the GLAA public register (UK)
- US Uyghur Forced Labor Prevention Act 2021; California Transparency in Supply Chains Act
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.