PPN 009: Tackling modern slavery in government supply chains · first published 17 February 2025
PPN 009 requires central government departments, executive agencies, non-departmental public bodies (NDPBs), and NHS bodies to identify and manage modern slavery risks in all public contracts for goods, services and works (except special regime contracts). This is an updated version of a 2023 note — the policy itself has not changed, but it now uses terminology from the Procurement Act 2023 and the Procurement Regulations 2024, which apply to procurements that started on or after 24 February 2025. If you are bidding on contracts that started before that date, the old rules (PPN 02/23) still apply. For small businesses, the key practical change is that if your contract is assessed as high-risk for modern slavery, you will be required to provide supply chain information. Sectors flagged as particular areas of concern include cotton, personal protective equipment (PPE), and polysilicon.
WHO THIS APPLIES TO
THE ENKII VIEW
SMEs supplying goods in flagged high-risk sectors — cotton, PPE, and polysilicon — face the most direct impact: buyers are now required to ask for supply chain information on high-risk contracts, meaning you must be able to map and disclose your supply chain. Even outside those sectors, modern slavery due diligence is now a formal part of the evaluation and contract management process, so having a clear, documented approach to this risk is increasingly a bidding differentiator. The use of exclusion grounds is also being strengthened, which means firms that cannot demonstrate adequate controls are at genuine risk of being ruled out at the selection stage.
1. Map your supply chain at least one tier down and document it — buyers are now required to ask for supply chain information on contracts assessed as high-risk, and these sectors are explicitly flagged.
SMEs supplying cotton, PPE or polysilicon products to central government — The PPN states 'there is a requirement for supply chain information to be provided for new procurements designated as having a high risk of modern slavery' and lists cotton, PPE and polysilicon as key sectors of concern.
2. Write or update a short modern slavery statement and internal procedure that covers how you assess and manage risks in your supply chain — this can be used as evidence at selection and due diligence stages.
All SMEs bidding for central government contracts commenced on or after 24 February 2025 — The PPN requires in-scope buyers to use the guidance to identify and manage risks across 'both new procurement activity and existing contracts', and strengthens use of exclusion grounds against suppliers who cannot demonstrate adequate controls.
3. Check which version of the rules applies: if the procurement or framework was established before 24 February 2025, the old PPN 02/23 still governs — do not assume the new terminology and requirements apply.
SMEs bidding on contracts that started before 24 February 2025 (including framework call-offs) — The PPN states 'For procurements commenced and contracts awarded before this date, please refer to PPN 02/23' and explicitly excludes pre-24 February 2025 frameworks and dynamic purchasing systems.
4. Download and read the PPN 009 Guidance document (referenced in paragraph 9) so you understand the risk assessment characteristics buyers will apply to your contract — and can prepare your bid accordingly.
SMEs in any sector bidding for central government work — Buyers 'must use PPN 009 Guidance - Tackling Modern Slavery in Government Supply Chains, to identify and manage risks', meaning the criteria in that guidance directly shape how your contract will be assessed.
5. Note that this PPN is not mandatory for non-central-government buyers, but be aware they 'may wish to apply the approach' — proactively having modern slavery documentation ready reduces friction if they do adopt it.
SMEs supplying other public sector bodies (councils, NHS trusts, etc.) — The PPN states 'Other public sector contracting authorities may wish to apply the approach set out in this PPN', indicating voluntary but possible wider adoption.
Every rule below quotes the official document verbatim.
The PPN applies to all central government departments, executive agencies, NDPBs and NHS bodies awarding public contracts for goods, services and works, except special regime contracts. (All in-scope organisations, all contract values, all sectors except special regime contracts)
“This Procurement Policy Note (PPN) applies to all central government departments, their executive agencies, and non-departmental public bodies and NHS bodies when awarding public contracts for goods and/or services and/or works, other than special regime contracts.”
The Procurement Act 2023 and Procurement Regulations 2024 apply to procurements commenced on or after 24 February 2025. (All in-scope organisations, procurements commenced on or after 24 February 2025)
“The Procurement Act 2023 and the Procurement Regulations 2024 apply to procurements commenced on or after 24 February 2025.”
For procurements commenced and contracts awarded before 24 February 2025, the previous rules (PPN 02/23) continue to apply. (All in-scope organisations, procurements and contracts pre-dating 24 February 2025)
“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).”
In-scope organisations must use the PPN 009 Guidance to identify and manage modern slavery risks in both new procurement activity and existing contracts. (All in-scope organisations, all procurements and existing contracts from 24 February 2025)
“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.”
The characteristics used to assess modern slavery risk in procurements have been updated to include current global risks in key sectors: cotton, PPE, and polysilicon. (All in-scope organisations, new procurements from 24 February 2025)
“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.”
Suppliers on new procurements designated as high-risk for modern slavery must provide supply chain information. (Suppliers on new procurements assessed as high-risk for modern slavery, from 24 February 2025)
“there is a requirement for supply chain information to be provided for new procurements designated as having a high risk of modern slavery.”
The updated guidance includes additional guidance on enhanced due diligence and on using existing exclusion grounds more effectively against suppliers who cannot demonstrate adequate modern slavery controls. (All in-scope organisations, all procurements from 24 February 2025)
“there is additional guidance on enhanced due diligence activities and on using existing exclusion grounds more effectively.”
Other public sector contracting authorities (outside central government) are encouraged but not required to apply the approach in this PPN. (Public sector bodies outside central government — voluntary adoption only)
“Other public sector contracting authorities may wish to apply the approach set out in this PPN.”
This briefing is enkii's interpretation of the official document — the official text always governs.
Source document © Crown copyright, reused under the Open Government Licence v3.0 via the GOV.UK Content API. enkii tracks every Procurement Policy Note and briefs changes the day they land — see all briefings.