Procurement Policy Note 05/19: Tackling Modern Slavery in Government Supply Chains · first published 18 September 2019
This Procurement Policy Note (PPN 05/19), published in September 2019, requires all central government departments, executive agencies, and non-departmental public bodies (NDPBs) to identify and manage modern slavery risks across both existing contracts and new procurement activity. Modern slavery covers forced labour, human trafficking, and related exploitation in supply chains. In practice, this means buyers are expected to assess suppliers — including small businesses — for modern slavery risks, and small firms bidding for central government work may be asked to demonstrate what steps they take to prevent it. Other public sector bodies (such as local councils or NHS trusts) are encouraged but not formally required to follow the same approach. Because we only have the summary text of this document, specific thresholds, scoring criteria, or detailed requirements are not confirmed here.
WHO THIS APPLIES TO
THE ENKII VIEW
For SMEs bidding on central government contracts, this PPN signals that modern slavery due diligence is no longer just a large-company compliance exercise — buyers are now obliged to look down the supply chain, including at smaller suppliers. SMEs that can demonstrate clear, proportionate anti-slavery policies and supply chain awareness will be better placed than those who treat this as irrelevant to their size. The encouragement for wider public sector adoption means this may increasingly appear in local authority and NHS tenders too.
1. Write or update a short, proportionate modern slavery policy statement for your business, covering your own operations and any sub-contractors or suppliers you use.
All SMEs bidding for central government contracts — Buyers are now required to identify and manage modern slavery risks in their supply chains — having a clear policy means you can answer due-diligence questions quickly and credibly.
2. Map your supply chain at least one tier down and be ready to name the steps you take to check for labour exploitation risks (e.g. use of reputable labour agencies, site visits, supplier questionnaires).
All SMEs bidding for central government contracts — The PPN covers risks in supply chains, not just direct suppliers — buyers may ask how you manage risk beyond your own firm.
3. Apply the same modern slavery due-diligence approach to non-central-government bids, as other public sector bodies are actively encouraged to adopt this PPN.
SMEs bidding for wider public sector contracts (local authorities, NHS, etc.) — The document explicitly notes that other public sector contracting authorities 'may also wish to apply the approach', so similar questions may appear in any public sector tender.
Every rule below quotes the official document verbatim.
The PPN applies to all central government departments, executive agencies, and non-departmental public bodies (NDPBs). (All central government departments, executive agencies and NDPBs — all contract values, all sectors.)
“It applies to all central government departments, executive agencies and non-departmental public bodies.”
Other public sector contracting authorities (e.g. local councils, NHS) are encouraged but not required to apply the same approach. (Wider public sector — voluntary adoption only.)
“Other public sector contracting authorities may also wish to apply the approach.”
Buyers must identify and manage modern slavery risks in both existing contracts and new procurement activity. (All central government departments, executive agencies and NDPBs — existing and new contracts.)
“This Procurement Policy Note (PPN) and guidance sets out how to identify and manage modern slavery risks in both existing contracts and new procurement activity.”
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.