PPN 02/23: Tackling Modern Slavery in Government Supply Chains · first published 10 February 2023
PPN 02/23 requires central government departments, their agencies, Non-Departmental Public Bodies (NDPBs), and NHS bodies to actively identify and manage modern slavery risks in their supply chains. From 1 April 2023, this applies to both new procurement activity and existing contracts. The biggest new change for suppliers is that if a procurement is designated as high risk for modern slavery, you will now be asked to provide supply chain information at the selection stage — meaning you need this information ready before you are awarded a contract. The risk assessment table used by buyers has also been updated to cover sectors such as cotton, PPE (Personal Protective Equipment), and polysilicon. Other public sector bodies are encouraged, but not required, to follow the same approach.
WHO THIS APPLIES TO
THE ENKII VIEW
The new supply chain transparency requirement at selection stage is the sharpest edge for SMEs: if you operate in or source from a high-risk sector (cotton, PPE, polysilicon are named), you could be screened out early if you cannot map your supply chain. SMEs who have already done modern slavery due diligence and can evidence it will have a genuine competitive advantage at shortlisting. Smaller firms with simpler, more visible supply chains can turn that into a strength — but only if they document it proactively.
1. Map your supply chain now — know who your Tier 1 and, where possible, Tier 2 suppliers are, what they produce, and where. Have this documented and ready to submit at selection (shortlisting) stage.
All SMEs bidding for central government, NHS or NDPB contracts — The PPN introduces a new requirement for suppliers to provide supply chain information at the selection stage on procurements designated as high risk of modern slavery — arriving unprepared could cost you the bid before it starts.
2. Review your supply chain specifically against modern slavery risks in these sectors and obtain evidence (e.g. supplier declarations, audit certificates) that you can include in a selection-stage response.
SMEs supplying or sourcing from cotton, PPE or polysilicon sectors — The risk assessment table has been updated to flag cotton, PPE and polysilicon as 'key sectors of concern', meaning buyers are more likely to designate your contract as high risk and request supply chain transparency.
3. Read the 'Tackling Modern Slavery in Government Supply Chains' guidance (available on GOV.UK) and check whether your existing modern slavery policy and due diligence processes meet its standards.
All SMEs bidding for central government contracts — In-scope buyers are required to use this guidance to assess risks — aligning your own policies to the same framework signals readiness and reduces the chance of being screened out or flagged during contract management.
4. Don't wait for renewal — the PPN applies to existing contracts from 1 April 2023. Contact your contract manager proactively to confirm you can meet any modern slavery information requests if your contract is in a high-risk category.
SMEs with existing public sector contracts (central government, NHS, NDPBs) — In-scope organisations are required to apply the PPN to existing contracts, not just new ones, so you may receive requests mid-contract without much warning.
5. Prepare your modern slavery supply chain evidence anyway — even though these buyers are not required to follow PPN 02/23, the document encourages them to do so, and many will adopt the same approach.
SMEs bidding for wider public sector contracts (local authorities, housing associations, etc.) — The PPN explicitly states that 'other public sector contracting authorities may wish to apply the approach', so demand for supply chain transparency is likely to spread beyond the mandatory scope.
Every rule below quotes the official document verbatim.
The PPN applies to all central government departments, their Executive Agencies, NDPBs, and NHS bodies (collectively 'In-Scope Organisations'); other public sector bodies are encouraged but not required to follow it. (Central government departments, Executive Agencies, NDPBs and NHS bodies from 1 April 2023)
“The contents of this Procurement Policy Note (PPN) apply to all Central Government Departments, their Executive Agencies and Non-Departmental Public Bodies, and NHS bodies... Other public sector contracting authorities may wish to apply the approach set out in this PPN.”
In-Scope Organisations must begin applying this PPN to existing contracts and new procurement activity from 1 April 2023. (All in-scope organisations, all contract values, from 1 April 2023)
“In-Scope Organisations should begin to take action to apply this PPN to existing contracts, and to new procurement activity from 1 April 2023.”
In-Scope Organisations must use the guidance 'Tackling Modern Slavery in Government Supply Chains' to identify and manage modern slavery risks in new procurements and existing contracts. (All in-scope organisations, all contract values, from 1 April 2023)
“In-Scope Organisations must use the guidance 'Tackling Modern Slavery in Government Supply Chains' to identify and manage risks in both new procurement activity and existing contracts.”
The modern slavery risk assessment table has been updated to include current global risks in key sectors of concern, specifically cotton, PPE and polysilicon. (All in-scope organisations conducting risk assessments, from 1 April 2023)
“the table used for assessing the risk of modern slavery has been updated to include current global modern slavery risks in key sectors of concern such as cotton, PPE and polysilicon.”
For new procurements designated as high risk of modern slavery, suppliers must now provide supply chain information at the selection stage. (Suppliers bidding for new procurements that in-scope organisations have designated as high risk of modern slavery, from 1 April 2023)
“there is a new requirement for supply chain information to be provided at the selection stage of new procurements designated as high risk of modern slavery.”
Additional guidance has been issued on enhanced due diligence activities and on using existing exclusion grounds more effectively. (All in-scope organisations, from 1 April 2023)
“there is additional guidance on enhanced due diligence activities and on using existing exclusion grounds more effectively.”
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.