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UK Modern Slavery and Human Trafficking Statement

Publish your UK annual modern slavery and human trafficking statement under section 54 of the Modern Slavery Act 2015. Covers the six mandatory reporting areas, board approval and signatory clauses, the March 2025 Home Office Transparency in Supply Chains (TISC) Level 1 baseline + Level 2 best-practice framework, alignment with UN Guiding Principles and OECD Due Diligence Guidance, Modern Slavery Helpline integration, Gangmasters and Labour Abuse Authority (GLAA) licensing checks, and Procurement Act 2023 public-sector compliance linkage.

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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
Riverside Manufacturing Group Limited  ·  Financial Year Ending 31 March 2026  ·  Section 54 Modern Slavery Act 2015
Riverside Manufacturing Group Limited (Company No. 07823541)
Published 30 September 2026 · Mandatory s.54
This statement is made by Riverside Manufacturing Group Limited (Company No. 07823541) of Unit 14, Beckton Industrial Park, London E16 1AA, United Kingdom, a limited company operating in the Manufacturing of consumer electronics and small appliances sector (the "Organisation"), pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the Organisation's slavery and human trafficking statement for the financial year ending 31 March 2026. It sets out the steps taken by the Organisation during the relevant financial year to ensure that slavery and human trafficking are not taking place in any part of its own business or in any of its supply chains. The Organisation is a commercial organisation with a total annual turnover (including subsidiary undertakings) of £36 million or more carrying on business in the United Kingdom, and is therefore within the scope of the section 54 reporting duty.
1.
ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS
1.1 Business model and structure. Riverside Manufacturing Group designs, manufactures, and distributes consumer electronics and small kitchen appliances across the United Kingdom and the European Union. The Group operates four UK manufacturing sites (London, Birmingham, Manchester, Newcastle) and three regional distribution warehouses.

1.2 Workforce. 1,240 employees (UK), 380 contractors (UK and offshore).

1.3 Geographic footprint. United Kingdom (HQ and four manufacturing sites), Republic of Ireland (one distribution warehouse), Poland (sourcing office for European component suppliers), Vietnam and Bangladesh (Tier-2 component manufacturing partners).

1.4 Supply chains. Tier-1 suppliers: 87 (UK 42; EU 28; Asia 17). Procurement is concentrated in electronics components (PCB assemblies, semiconductors, plastics) and packaging materials. The Organisation also engages contract logistics, cleaning, security, and IT support providers across its UK sites. Direct procurement spend during the reporting year: £142,000,000.

1.5 Supply-chain visibility gaps. Limited visibility below Tier 2 in the electronics components supply chain (raw materials extraction, smelter sourcing). The Organisation has engaged with suppliers and the Responsible Minerals Initiative to map down to Tier 3 by end of FY26.
2.
POLICIES IN RELATION TO MODERN SLAVERY AND HUMAN TRAFFICKING
2.1 Policies in scope. The Organisation operates the following policies that address modern slavery, human trafficking and broader human-rights risks:

Modern Slavery and Ethical Trading Policy; Group Code of Business Conduct; Supplier Code of Conduct (incorporating ETI Base Code); Whistleblowing Policy (Protect-aligned); Procurement Policy; Equal Opportunities and Anti-Discrimination Policy; Recruitment Policy (with right-to-work checks under IANA 2006 s.15); Human Rights Policy aligned to the UN Guiding Principles

2.2 Senior management oversight. These policies are owned at senior management level and are subject to periodic review. They are communicated to all employees through induction, training and the Organisation's intranet, and to suppliers through the Supplier Code of Conduct or equivalent contractual terms.

2.3 Whistleblowing channel. Concerns about modern slavery or human trafficking can be raised confidentially through the Organisation's whistleblowing channel. Reports are investigated promptly and no detriment is suffered by any person raising a concern in good faith (Public Interest Disclosure Act 1998 protection where applicable).
3.
DUE DILIGENCE PROCESSES
3.1 Due-diligence framework. The Organisation operates a documented due-diligence framework covering prevention, detection, and remediation of modern slavery and human-trafficking risks across its own operations and Tier-1 supply chain.

3.2 Implementation. Prevention: all new suppliers complete a self-assessment questionnaire on labour standards, recruitment practices, and supply-chain transparency before onboarding. Detection: annual ethical audits on 40% of Tier-1 suppliers using SMETA 4-pillar methodology (labour, health and safety, environment, business ethics). Remediation: where issues are identified, we work with the supplier to develop a corrective action plan with timelines, KPIs, and escalation routes to senior management; persistent non-compliance triggers exit under our Supplier Code.

3.3 Worker engagement. Workplace Wellness Hotline (operated independently by Protect, the UK whistleblowing charity) available 24/7 in 8 languages with anonymity guarantee. Confidential reporting channel routes directly to the Modern Slavery Lead within the Group. Annual confidential worker survey distributed through Trades Union Congress methodology. On-site supplier visits include private worker interviews where practicable.

3.4 Audit activity. 12 SMETA audits completed FY25 (vs 9 FY24); 4 unannounced site visits to high-risk suppliers in Asia; 2 corrective action plans active at year end (both progressing on schedule); 1 supplier relationship discontinued for refusal to remediate excessive overtime.
4.
RISK ASSESSMENT AND MANAGEMENT
4.1 Risk assessment approach. The Organisation conducts an annual modern-slavery risk assessment focused on (a) sectoral risk indicators published by the UK Anti-Slavery Commissioner and the US State Department TVPRA reports; (b) geographic risk indicators from the Global Slavery Index; and (c) supply-chain category risk (electronics, garments, agriculture, construction, hospitality, cleaning, security).

4.2 Salient risks identified. Highest risk concentrations: (1) electronics assembly contractors in South-East Asia (Vietnam, Bangladesh — risk of forced labour, recruitment-fee debt bondage, excessive overtime in component supply); (2) UK warehouse temporary labour (risk of labour exploitation via unlicensed or non-compliant gangmasters); (3) cleaning and security contractors (industry-wide modern-slavery risk per the UK Anti-Slavery Commissioner annual report).

4.3 Mitigating actions. For each salient risk, the Organisation has documented mitigating actions, ownership, and review cadence. High-risk supplier categories are subject to enhanced due diligence including unannounced site visits and worker-voice surveys.
5.
KEY PERFORMANCE INDICATORS — EFFECTIVENESS OF STEPS TAKEN
5.1 Effectiveness measurement. The Organisation measures the effectiveness of the steps taken to combat modern slavery through key performance indicators (KPIs) tracked on a continuous basis.

5.2 KPIs and targets. (1) Percentage of Tier-1 suppliers with active SMETA audit: 78% FY25 (target 90% FY26); (2) Hotline contacts received: 23 FY25 (3 modern-slavery indicators investigated, none substantiated); (3) Supplier corrective action plans closed within 90 days: 100% FY25; (4) Manager training completion rate: 96% FY25 (target 100%); (5) Tier-2 supplier mapping coverage: 34% FY25 (target 60% FY26); (6) Number of modern-slavery briefings delivered to Board and Audit Committee: 2 FY25.

5.3 Year-on-year progress. FY25 progress vs FY24: SMETA audit coverage 78% (up from 65%); hotline contacts up 23% (interpreted as improved worker awareness rather than greater risk); 2 new high-risk suppliers added to enhanced monitoring; Tier-2 mapping initiated for electronics components (34% coverage achieved); Board-level briefings increased from annual to bi-annual; first cross-industry information-sharing pilot launched with Stronger2gether.
6.
TRAINING ON MODERN SLAVERY AND HUMAN TRAFFICKING
6.1 Training framework. The Organisation provides modern-slavery awareness training to staff with role-specific content reflecting the level of exposure to modern-slavery risk indicators.

6.2 Audience and content. All employees: 30-minute annual e-learning on modern-slavery awareness and indicators (completion tracked via HRIS). Procurement, recruitment and HR teams: 4-hour Stronger2gether specialist workshop on supply-chain risk and responsible recruitment. Site managers: 2-hour workshop on labour-rights monitoring and worker-voice channels. Senior leaders and Board: annual briefing from external counsel on regulatory developments and case studies.

6.3 Supplier training. Top 30 Tier-1 suppliers (representing 85% of procurement spend) receive an annual briefing on our Supplier Code and modern-slavery expectations. The Group procurement team conducts in-person training during audit visits and shares the Stronger2gether supplier-engagement materials. FY25 attendance: 28 of top 30 suppliers (93%).
7.
LEVEL 2 BEST-PRACTICE DISCLOSURES (TISC GUIDANCE 2025)
7.1 Beyond Tier-1 — supply-chain mapping. Mapped 34% of Tier-2 suppliers across the electronics components category (target 60% by end FY26). Engaged with Stronger2gether and the Responsible Business Alliance to share supplier intelligence and audit findings. Where Tier-2 supplier identity is commercially confidential, the Organisation has obtained binding undertakings from Tier-1 suppliers that they will conduct equivalent due diligence on their own supply chain.

7.2 International framework alignment. The Organisation aligns its modern-slavery programme with the following international frameworks: United Nations Guiding Principles on Business and Human Rights (2011) — Pillar 2 (Corporate Responsibility to Respect); OECD Due Diligence Guidance for Responsible Business Conduct (2018); ILO Conventions Nos. 29 (Forced Labour), 105 (Abolition of Forced Labour), 138 (Minimum Age), 182 (Worst Forms of Child Labour); ETI Base Code (9 principles); Stronger2gether collaborative initiative; UK Government Procurement Policy Note (PPN) compliance.

7.3 Modern Slavery Helpline. The Organisation displays the Modern Slavery Helpline number 0800 0121 700 in workplaces and on supplier sites where practicable, alongside the QR code linking to the gov.uk reporting page. Workers may report concerns directly to the Helpline confidentially and in multiple languages.

7.4 GLAA licensing. Where the Organisation procures labour from third parties in licensable sectors (agriculture, shellfish gathering, food processing and packaging), it verifies that the labour provider holds a valid licence issued by the Gangmasters and Labour Abuse Authority under the Gangmasters (Licensing) Act 2004. Unlicensed supply is prohibited and reported to the GLAA.

7.5 Case studies and lessons learned. FY25 case study — Excessive overtime at a Vietnamese components supplier: a SMETA audit at one of our Tier-1 component manufacturers in Vietnam identified excessive overtime exceeding 44 hours weekly for production workers, in breach of the ETI Base Code. We worked with the supplier and a local labour-rights NGO (Vietnam Workers Initiative) to develop a workforce-management plan, including production-line capacity expansion, additional recruitment, and overtime monitoring tied to KPI reporting. After nine months, overtime levels were within ETI limits and the commercial relationship was maintained. The plan is now used as a template for other Tier-1 manufacturing suppliers.

7.6 Continuous improvement. Consistent with the March 2025 Home Office Transparency in Supply Chains (TISC) Statutory Guidance, the Organisation is progressing from Level 1 baseline to Level 2 best-practice disclosures year on year. Areas of planned improvement are recorded in the next-steps register.
8.
GOVERNING LAW AND COMPLIANCE FRAMEWORK
This statement is published in accordance with section 54 of the Modern Slavery Act 2015 and is governed by the laws of England and Wales. The Organisation will publish this statement on its UK website with a prominent link from the homepage (section 54(7)) and submit it to the Government Modern Slavery Statement Registry at modern-slavery-statement-registry.service.gov.uk. Where the Organisation is in scope of the Companies Act 2006 strategic-report duty, an equivalent summary is included in the Strategic Report under section 414CA Companies Act 2006. Where the Organisation supplies the public sector, this statement supports compliance with the Procurement Act 2023 (commenced 24 February 2025) exclusion grounds for modern-slavery non-compliance.
9.
BOARD APPROVAL AND SIGNATORY DECLARATION
This statement has been approved by the Board of Directors of Riverside Manufacturing Group Limited on 15 September 2026 in accordance with section 54(6) of the Modern Slavery Act 2015. It is signed below by Catherine Margaret Whitfield, Group Chief Executive Officer (director of the body corporate, in accordance with section 54(7)(a) MSA 2015), on behalf of the Organisation. The Organisation will renew this statement for each subsequent financial year and will publish the renewed statement on its UK website within six months of the relevant year-end.
SIGNED FOR AND ON BEHALF OF THE ORGANISATION
Catherine Margaret Whitfield
Group Chief Executive Officer · Board approval 15 September 2026
Date: ____________________

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What Is a UK Modern Slavery Statement?

A Modern Slavery Statement is the annual transparency disclosure required of any commercial organisation that carries on business in the United Kingdom and has a total annual turnover (including subsidiaries) of £36 million or more. Section 54 of the Modern Slavery Act 2015 — the centrepiece of British anti-slavery legislation — obliges such organisations to publish, for each financial year, a statement of the steps taken to ensure that slavery and human trafficking are not taking place in any of their supply chains or in any part of their own business. The Act lists six recommended reporting areas: organisational structure and supply chains, policies, due diligence, risk assessment, key performance indicators, and training. Each statement must be approved by the board of directors (or equivalent governing body) and signed by a director — or by a designated member for a UK limited liability partnership, or by a partner for an unincorporated UK partnership.

In March 2025, the UK Home Office issued updated statutory guidance (Transparency in Supply Chains: a practical guide) introducing a two-tier Level 1 baseline vs Level 2 best-practice disclosure framework. The updated guidance — applicable to financial-year-2025 reporting cycles onward — raises the bar on monitoring and effectiveness disclosures, expects clearer evidence of implementation rather than mere policy statements, and aligns British corporate reporting with the UN Guiding Principles on Business and Human Rights, the OECD Due Diligence Guidance, and the relevant International Labour Organization Conventions. The Home Office also encourages all reporting organisations to submit their statement to the Government Modern Slavery Statement Registry at modern-slavery-statement-registry.service.gov.uk so that it is discoverable by procurement counterparties and stakeholders across the UK and beyond.

A UK Modern Slavery Statement is also a procurement-readiness document. The Procurement Act 2023 (commenced 24 February 2025) requires UK contracting authorities to consider modern-slavery compliance when applying the exclusion grounds for major public-sector contracts. FTSE-listed groups, financial institutions, and other large British buyers increasingly require Tier-1 suppliers to publish a current statement as a precondition of contracting. A well-drafted statement is therefore not only a section 54 statutory duty but a commercial necessity in the United Kingdom market.

What's Covered in This Template

Our UK Modern Slavery Statement template generates a fully compliant section 54 statement with all six recommended reporting areas, board approval clauses, and the March 2025 TISC Level 2 best-practice disclosures expected of British FTSE and procurement-facing organisations.

Organisation Identity (s.54 scope)

Full legal name, Companies House number, registered office, organisation type (Ltd, plc, LLP, partnership), turnover band, financial year, publication date, and the British business sector.

£36m Turnover Threshold Logic

Mandatory disclosure for total turnover (UK + worldwide subsidiaries) of £36 million or more; below-threshold organisations can publish on a voluntary basis with adapted wording.

Reporting Area 1 — Structure and Supply Chains

Business model, geographic footprint, workforce size, Tier-1 supplier overview, procurement spend, and supply-chain visibility gaps (MSA 2015 s.54(5)(a)).

Reporting Area 2 — Policies

Modern Slavery Policy, Code of Business Conduct, Supplier Code of Conduct, Whistleblowing, Procurement, Recruitment with IANA 2006 s.15 right-to-work checks (s.54(5)(b)).

Reporting Area 3 — Due Diligence (Expert)

Prevention, detection and remediation framework; SMETA audit programme; worker-voice channels; supplier corrective-action plans (s.54(5)(c)).

Reporting Area 4 — Risk Assessment (Expert)

Salient-risk identification by category and geography; likelihood vs worker-severity prioritisation; UK Anti-Slavery Commissioner sectoral indicators (s.54(5)(d)).

Reporting Area 5 — KPIs (Expert)

Measurable performance indicators with targets and year-on-year progress narrative — the area where the March 2025 TISC guidance signals the greatest uplift (s.54(5)(e)).

Reporting Area 6 — Training (Expert)

Role-specific training audiences (frontline, HR, procurement, leadership) plus supplier training, with completion metrics (s.54(5)(f)).

Board Approval & Director Signatory

Section 54(6) board approval clause with the dated approval, plus the section 54(7) signatory rules — director, LLP designated member, or partnership partner.

March 2025 TISC Level 2 Disclosures (Expert)

Tier-2 / Tier-3 supply-chain mapping, UN Guiding Principles + OECD Due Diligence + ILO Conventions alignment, Modern Slavery Helpline 0800 0121 700, GLAA licensing verification, and lessons-learned case studies.

Procurement Act 2023 Compliance Linkage

Cross-reference to the UK Procurement Act 2023 (commenced 24 February 2025) exclusion grounds for modern-slavery non-compliance affecting public-sector tenders.

Modern Slavery Statement Registry

Built-in reference to the Government registry at modern-slavery-statement-registry.service.gov.uk for British best-practice publication.

How to Create a UK Modern Slavery Statement

Follow these steps to publish a section 54 compliant statement on your UK website.

  1. 1

    Confirm Your Reporting Scope

    Enter your organisation's full legal name, Companies House number, registered office address in the United Kingdom, organisation type (Ltd, plc, LLP, partnership), and confirm whether total turnover (including UK and overseas subsidiary undertakings) is at or above the £36 million threshold under section 54 MSA 2015. Below threshold, you can still publish a voluntary statement — increasingly expected by British procurement counterparties.

  2. 2

    Describe Your Structure and Supply Chains

    Set out the business model, geographic footprint (UK headquarters, manufacturing or sourcing locations), workforce size, and the Tier-1 supplier base (number, geography, procurement categories). Be explicit about supply-chain visibility gaps below Tier 1 and the steps being taken in the United Kingdom and overseas to close them. The March 2025 Home Office TISC guidance treats supply-chain mapping as the foundation of every other disclosure.

  3. 3

    List Your Policies and Confirm Board Approval

    Identify the modern slavery, whistleblowing, recruitment, procurement, supplier-code and human-rights policies in scope, then enter the board approval date (mandatory under s.54(6)) and the name and title of the director signing the statement. For a UK LLP, the signatory is a designated member; for an unincorporated UK partnership, a partner. Select the governing jurisdiction (England & Wales / Scotland / Northern Ireland / UK-wide group).

  4. 4

    Add Due Diligence, Risk and Training Detail (Expert)

    In Expert mode, expand sections 3-6 with the detail expected by the March 2025 TISC guidance: prevention/detection/remediation framework, SMETA audit programme metrics, worker-voice channels (Protect, Stronger2gether, internal hotline), salient-risk identification with sectoral / geographic prioritisation, measurable KPIs with year-on-year trends, and role-specific training for frontline, HR, procurement and senior leadership audiences in the UK and across overseas subsidiaries.

  5. 5

    Unlock Level 2 Best-Practice Disclosures (Expert)

    In Expert mode, add the March 2025 TISC Level 2 disclosures: Tier-2 / Tier-3 supply-chain mapping progress, alignment with the UN Guiding Principles on Business and Human Rights, OECD Due Diligence Guidance, ILO Conventions Nos. 29/105/138/182, ETI Base Code, Modern Slavery Helpline (0800 0121 700) workplace display, Gangmasters and Labour Abuse Authority (GLAA) licensing verification for applicable British sectors (agriculture, shellfish gathering, food processing and packaging), and case studies with lessons learned. Publish on your UK website with a prominent homepage link and submit to the Government Modern Slavery Statement Registry.

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Legal Considerations

A UK Modern Slavery Statement sits at the intersection of British corporate-governance, supply-chain and public-procurement law. Get the formalities right and the statement also doubles as a procurement-readiness document.

This template is for informational purposes only and does not constitute legal advice. Modern-slavery compliance is a fast-evolving area of British law — consult a qualified UK solicitor or anti-slavery specialist for advice tailored to your organisation's circumstances.

Reviewed for England & Wales corporate law and 2025 Home Office TISC guidance

Section 54 MSA 2015 — Core Duty and Scope

Section 54 of the Modern Slavery Act 2015 applies to any "commercial organisation" supplying goods or services that carries on a business (or part of a business) in any part of the United Kingdom and has a total annual turnover of £36 million or more. "Total turnover" is defined in The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 (SI 2015/1833) reg. 2 and includes the worldwide turnover of subsidiary undertakings. The duty is to prepare a slavery and human trafficking statement for each financial year, approved by the board (s.54(6)) and signed by a director or equivalent (s.54(7)), and published on the organisation's UK website with a prominent homepage link.

March 2025 Home Office TISC Statutory Guidance

On 26 March 2025 the UK Home Office issued updated statutory guidance titled "Transparency in Supply Chains: a practical guide", introducing a Level 1 baseline vs Level 2 best-practice disclosure framework. The guidance does not change the underlying statute but raises expectations of monitoring and effectiveness disclosure, supply-chain mapping below Tier 1, and alignment with the UN Guiding Principles on Business and Human Rights, the OECD Due Diligence Guidance for Responsible Business Conduct, and the relevant International Labour Organization Conventions. The guidance is applicable to British financial-year-2025 reports onward. Organisations are expected to progress from Level 1 to Level 2 disclosures year on year.

Procurement Act 2023 and Public-Sector Exposure

The Procurement Act 2023 (commenced 24 February 2025) consolidated UK public-procurement law and built modern-slavery non-compliance into the discretionary exclusion grounds for major public-sector contracts. Contracting authorities across England, Wales, Scotland and Northern Ireland are now empowered to exclude suppliers from public tenders where evidence of modern-slavery non-compliance exists. For a British organisation supplying the UK public sector, the modern slavery statement is therefore a tender-readiness document as well as a statutory duty. Failure to publish — or publication of a thin, unsigned, or undated statement — risks exclusion from public-sector contract opportunities.

GLAA, Helpline and Strategic Report Integration

The Gangmasters and Labour Abuse Authority (GLAA), operating under the Gangmasters (Licensing) Act 2004 and the Immigration Act 2016 Part 1, licenses British labour providers in agriculture, horticulture, shellfish gathering, food processing and packaging. Engaging an unlicensed gangmaster in a licensable UK sector is a criminal offence — verification of GLAA licence status should appear in every Level 2 disclosure. The Modern Slavery Helpline (0800 0121 700, operated by Unseen UK) is the British confidential worker-voice channel and should be displayed in UK workplaces and supplier sites. Listed groups within scope of the Companies Act 2006 s.414CA strategic-report duty may also publish an integrated summary in the Strategic Report — supported by the same underlying disclosures.

Frequently Asked Questions

Publish Your UK Modern Slavery Statement Now

Use our free template to draft a UK Modern Slavery and Human Trafficking Statement compliant with section 54 of the Modern Slavery Act 2015 and the March 2025 Home Office TISC statutory guidance. All six mandatory reporting areas, board approval clauses, Level 1 baseline + Level 2 best-practice disclosures, and Procurement Act 2023 alignment included — ready for publication on your UK website and submission to the Government Modern Slavery Statement Registry.

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