Pillar 1 · Supplier Risk · Supporting Article
Modern Slavery Risk in FM Supply Chains: What Procurement Should Monitor Across Cleaning, Security and Catering
By Alexander Jaiyesimi MSc MCIPS, Founder, SupplierSense
Published: SupplierSense Knowledge Centre · Read time: 7 minutes · Last Updated: June 2026
Cleaning, security and catering are the categories where FM procurement spends the most operational time and the most monitoring effort. They are also the categories where modern slavery risk is most acute.
These are labour-intensive supply chains with thin margins, multi-tier subcontracting, transient workforces, and significant reliance on agency and migrant labour. They are exactly the operational profile in which exploitation risk is highest and the gap between compliance documentation and actual risk monitoring is widest.
This article is a practical guide for FM procurement leaders on what to monitor, why traditional supplier due diligence fails to detect modern slavery, and how to build a continuous monitoring framework that withstands scrutiny under the Modern Slavery Act 2015, the Procurement Act 2023 supplier exclusion regime, and rising client ESG expectations.
It is written from the perspective of 14 years in enterprise procurement, including supplier governance across architecture, real estate, engineering, and infrastructure portfolios, where FM categories sat alongside core trade supply chains.
Key takeaway
Compliance is not the same as risk monitoring. An annual slavery and human trafficking statement is a compliance artefact. Detecting modern slavery in your supplier base requires continuous monitoring of signals that lie outside the supplier.
Why FM Categories Carry Structurally Higher Modern Slavery Risk
Four characteristics of FM supply chains concentrate exposure to modern slavery.
Labour intensity. Cleaning, security and catering are not capital-intensive sectors. Labour is the largest component of supplier costs, frequently 60 to 80 per cent of the price you pay. When tender pressure squeezes prices, labour costs are the first to be squeezed.
Thin margins. Net margins in cleaning and security typically range from 2% to 5%. Suppliers operating at these margins have limited capacity to invest in workforce protections, compliance infrastructure, or sub-tier monitoring of their own supply chain.
Multi-tier subcontracting. A national cleaning contract may be subcontracted to a regional operator, then to a local provider, and then to agencies that source individual workers. Each tier reduces visibility. By the time a worker is on your site, the audit trail of how they got there may span three or four parties.
Workforce composition. FM categories rely heavily on migrant labour, agency placements and short-tenure roles. These workforce profiles are not problematic in themselves, but they coincide with the operational conditions in which exploitation is most likely to go unreported.
The Gangmasters and Labour Abuse Authority (GLAA) is the UK regulator responsible for tackling labour exploitation. Its licensing regime covers agriculture, horticulture, shellfish gathering and food processing. Its broader labour-abuse jurisdiction extends across all sectors. The Home Office Modern Slavery Strategy and the Independent Anti-Slavery Commissioner have consistently identified cleaning, security, hospitality, construction and care as sectors with elevated risk of labour exploitation.
The Regulatory Picture in 2026
Three regulatory regimes now intersect with risk for FM suppliers.
The Modern Slavery Act 2015 (UK) requires qualifying organisations, defined as commercial entities with an annual turnover of £36 million or more carrying on business in the UK, to publish an annual slavery and human trafficking statement, approved by the board (or equivalent), describing the steps taken to ensure that modern slavery is not occurring in their business or supply chains. The statement must be published in a prominent place on the organisation's website. The Act does not prescribe what those steps must be, but it does require the organisation to disclose what it actually does.
Procurement Act 2023 (UK). In force from 24 February 2025. Contracting authorities must consider both mandatory and discretionary grounds for exclusion when assessing public-sector suppliers. Under this regime, modern slavery and labour-related misconduct are increasingly central to supplier exclusion and due diligence, particularly for suppliers in higher-risk sectors.
The EU Corporate Sustainability Due Diligence Directive (CSDDD) introduces additional expectations for identifying, preventing and addressing human rights and environmental impacts within value chains. Implementation timelines and detailed requirements continue to evolve.
For FM procurement leaders, the practical implication is consistent: the regulatory expectation is no longer just disclosure. It is due diligence.
What Modern Slavery Monitoring Actually Requires (and Where Most Teams Fall Short)
Most FM procurement functions treat the Modern Slavery Act as a compliance exercise. The annual slavery and human trafficking statement is drafted, board-approved, and published on the website, and the supplier onboarding pack is updated to include a modern slavery clause.
That is compliance, not risk monitoring.
Compliance is what an organisation publishes about itself. Risk monitoring is what the organisation does to detect, escalate and respond to indicators of modern slavery in its supplier base. These are distinct activities with different outputs.
The honest test: over the past 12 months, has your modern slavery monitoring process produced a single trigger event that led to a supplier conversation, a contract review, or an escalation to senior leadership? If the answer is no, and for most FM procurement functions it is, the monitoring process is generating visibility into compliance documentation, not into operational risk.
The gap matters because the failure mode is asymmetric. A supplier using forced labour does not disclose it in a questionnaire. A subcontractor with a GLAA enforcement history may not surface in the standard PQQ workflow. A sub-tier supplier with an opaque beneficial ownership structure may be the actual labour provider, three layers below the contractual relationship.
The signals that indicate modern slavery exposure do not come from the supplier. They come from outside.
Seven Outside-In Signals FM Procurement Should Monitor
Across the FM supplier base, seven external signals carry disproportionate weight in assessing modern slavery risk.
Modern slavery statement currency and content. A supplier with turnover above the £36 million threshold without a current annual statement is a flag. So is a statement that has not been updated in 18 months or more, or one that contains generic boilerplate language with no specific actions identified.
GLAA enforcement records. The GLAA publishes a register of licence holders and licence actions (revocations apply to GLAA-licensed sectors, primarily agriculture and food). Across all sectors, the GLAA publishes prosecution outcomes, Slavery and Trafficking Prevention or Risk Order applications, and notable labour-abuse enforcement actions. A supplier, or a supplier's directors, associated with a GLAA enforcement action warrants enhanced review.
Adverse media and tribunal findings. Employment tribunal judgments, workplace fatality reports, immigration-related enforcement actions, and trade-press coverage of labour disputes all feature in adverse media monitoring. The procurement function should not be the last to know.
Beneficial ownership opacity. A UK supplier whose Persons with Significant Control (PSC) register shows opaque ownership chains, recent restructuring, or concealed PSCs may indicate efforts to obscure labour-supply relationships, particularly in multi-tier subcontracting arrangements.
Sub-tier disclosure. Does the supplier disclose its own subcontractors? In cleaning, security and catering, the operational workforce is frequently delivered by sub-tier providers. A supplier unable or unwilling to name its sub-tier providers is operating without the visibility it claims to deliver.
Sector-specific licensing. Security suppliers engaged in regulated activities must deploy SIA-licensed operatives (mandatory for door supervision, manned guarding, close protection, cash and valuables in transit, and other licensable activities). The SIA Approved Contractor Scheme (ACS) is a voluntary business-level recognition standard; its absence is not disqualifying, but its presence is a meaningful positive signal. Catering suppliers handling food should hold appropriate food hygiene ratings. Cleaning suppliers in regulated sectors may require specific accreditation. Missing, lapsed, or downgraded licensing is a meaningful signal.
Workforce signals. Suppliers reporting wage rates significantly below market rates, particularly in geographies with known elevated risk, and those with very limited or anomalous worker-review presence in the public domain, may be operating in ways that warrant scrutiny.
None of these signals is conclusive on its own. Together, they form a monitoring discipline that captures what the questionnaire misses.
Why Questionnaires Miss Modern Slavery
The standard procurement due diligence model, comprising supplier-completed questionnaires at onboarding, annual reassessments, and a modern slavery clause in the contract, rests on three assumptions that do not hold in the modern slavery context.
First, the suppliers knows. In a four-tier subcontracting chain, the prime contractor frequently lacks visibility into how the workforce is sourced at tier three or tier four.
Second, the supplier would tell you if they did. A supplier with material modern slavery exposure has every commercial incentive to keep that exposure off the contractual record.
Third, the assessment is current. A modern slavery questionnaire completed at onboarding 18 months ago and refreshed annually is not a monitoring process. It is a historical artefact.
Continuous outside-in monitoring inverts these assumptions. It does not depend on the supplier knowing, disclosing, or being assessed on a cycle. It depends on signals found in public records, regulatory disclosures, and news data, signals that the supplier cannot redact.
A Practical Four-Step Modern Slavery Monitoring Framework for FM Procurement
The framework that holds up to scrutiny has four steps.
Segment your FM supplier base by labour intensity. Identify suppliers operating in labour-intensive, low-margin, multi-tier categories with concentrated exposure, such as cleaning, security, catering, waste handling, and ground maintenance. These suppliers warrant continuous monitoring; lower-risk FM suppliers warrant periodic refresh.
Continuously monitor the four highest-leverage signals. These are GLAA enforcement records, adverse media, modern slavery statement currency, and beneficial ownership changes. These should be monitored on an ongoing basis, not at refresh cycles.
Define escalation triggers and responses. A new GLAA enforcement action against a supplier is a trigger event. A modern slavery statement that has lapsed for more than 18 months is a trigger event. A material PSC change is a trigger event. Each trigger should map to a defined response, not an email that sits in someone's inbox.
Report at the portfolio level. The most useful modern slavery reporting metric for procurement leadership is not the number of completed questionnaires. It is the shape of the supplier base, the number of suppliers in the labour-intensive categories, the current monitoring status, and the trigger events that have occurred this quarter.
This framework integrates with existing PQQ and onboarding processes. It complements supplier self-disclosure by identifying external signals that may warrant further review, including regulatory enforcement actions, adverse media and corporate registry indicators.
Modern slavery risk sits at the intersection of supplier risk, sustainability and governance. Organisations that assess these areas separately often miss the signals that matter most.
Key Takeaways
• Cleaning, security and catering are FM's structurally highest-risk supply chains for modern slavery, labour-intensive, low-margin, multi-tier, with workforce profiles where exploitation is most likely to go unreported.
• The regulatory expectation in 2026 is no longer limited to disclosure under section 54 of the Modern Slavery Act. It is now evidenced by due diligence across UK and EU regimes and is increasingly part of public-sector supplier exclusion conversations under the Procurement Act 2023.
• Compliance and risk monitoring are distinct. An annual slavery and human trafficking statement is a compliance artefact, not a monitoring process.
• The signals that indicate modern slavery exposure come from outside the supplier, GLAA records, adverse media, statement currency, beneficial ownership data, and sector licensing.
• A practical FM monitoring framework has four steps: segment by labour intensity, monitor continuously on the highest-leverage signals, define escalation triggers, and report at portfolio level.
• Outside-in supplier intelligence runs in parallel with PQQs and supplier portals, complementing what supplier self-disclosure cannot deliver.
Sources
Primary sources consulted in the preparation of this article.
Modern Slavery Act 2015
UK Public General Acts, c.30. Section 54 (Transparency in supply chains).
UK Government - Transparency in supply chains: a practical guide
Home Office statutory guidance on section 54 of the Modern Slavery Act 2015.
UK Cabinet Office - Transforming Public Procurement
Procurement Act 2023 guidance, including exclusion and debarment regime.
Gangmasters and Labour Abuse Authority (GLAA)
UK regulator for labour exploitation. Licensing applies to agriculture, horticulture, shellfish and food processing; labour-abuse jurisdiction extends across all sectors.
Home Office - Modern Slavery Statement Registry
UK government registry for modern slavery statements published under section 54 of the Modern Slavery Act 2015.
Independent Anti-Slavery Commissioner
Independent UK office providing strategic leadership on the response to modern slavery, including sector risk analysis.
Security Industry Authority (SIA)
UK regulator for the private security industry. Operative licensing is mandatory for door supervision, manned guarding, close protection, cash and valuables in transit and other regulated activities. The Approved Contractor Scheme is a voluntary business-level standard.
European Council - Corporate Sustainability Due Diligence Directive
Directive (EU) 2024/1760, adopted 2024.
Companies House - Persons with Significant Control guidance
UK Government guidance on PSC requirements.
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