Modern slavery statements and cup orders: who must publish one under section 54

A national venue group, a brewer or a corporate that buys printed cups in volume may be within section 54 of the Modern Slavery Act 2015 if it meets the tests below. Section 54 asks some organisations to say publicly what they do about modern slavery in their supply chains. This article sets out who section 54 covers, what GOV.UK says the statement has to do, and what that means when the goods are cups. It is general information, not legal advice.

Who has to publish

Section 54(1) and (2) say a commercial organisation within the section must prepare a slavery and human trafficking statement for each financial year, and that an organisation is within the section if it supplies goods or services and has a total turnover of not less than an amount prescribed by regulations. Section 54(12) defines a commercial organisation as a body corporate, wherever incorporated, or a partnership, wherever formed, which carries on a business, or part of a business, in any part of the United Kingdom.

As checked on 28 October 2026, GOV.UK states the four conditions as follows: the organisation is a body corporate or a partnership wherever incorporated or formed, it carries on a business or part of a business in the UK, it supplies goods or services, and it has an annual turnover of £36 million or more. We did not read the regulations that set the amount. GOV.UK says total turnover means the turnover of the organisation and any of its subsidiary undertakings, including those operating wholly outside the UK, after deduction of trade discounts, value added tax and any other taxes. It says organisations are responsible for determining whether the legislation applies to them and that they may wish to take legal advice. It also says charities must publish a statement if they meet the criteria, counting income from business activities but generally not donations, legacies and grants where the donor receives no service or benefit.

What the statement is

Section 54(4) says the statement is a statement of the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its own business, or a statement that the organisation has taken no such steps. Section 54(5) lists what it may include, from the organisation's structure and supply chains to its policies, due diligence processes, risk assessment, effectiveness measures and staff training. GOV.UK says the Act recommends six areas, which in our reading match that list, and that if the organisation has taken no steps it must still publish a statement saying so.

GOV.UK also says that organisations are not expected to promise that all their supply chains are 'slavery free', but that statements must describe the steps taken during the financial year to deal with modern slavery risks in the supply chains and in the business itself. The Act itself asks for a statement of steps, as section 54(4) shows.

How it is approved and published

Section 54(6) says the statement of a body corporate other than a limited liability partnership must be approved by the board of directors, or equivalent, and signed by a director, or equivalent. It sets different rules for limited liability partnerships, limited partnerships and other partnerships. Section 54(7) says an organisation with a website must publish the statement on it and include a link in a prominent place on the homepage. Section 54(8) says an organisation without a website must provide a copy to anyone who makes a written request within 30 days of receiving it. GOV.UK adds that statutory guidance states that the statement should be published within six months of the financial year-end, and encourages organisations to add their most recent statement to the government modern slavery statement registry. Section 54(11) says the duties are enforceable by the Secretary of State bringing civil proceedings in the High Court for an injunction or, in Scotland, for specific performance of a statutory duty.

GOV.UK states that the government has announced future changes to the reporting requirements, that these have not yet come into effect, and that organisations should continue to report under the current requirements. We did not read the consultation response it links, and the legislation.gov.uk page for section 54 lists changes yet to be applied, which we did not examine.

What it means when the goods are cups

In our reading, printed cups bought in volume are goods in the buyer's supply chain, and an organisation above the threshold that buys cups for its venues, hospitality or merchandise has the cup supply chain among the chains its statement is about, and a buyer who wants to say something concrete in that part of the statement may ask the supplier for the information. In our reading, section 54 does not make the supplier produce anything for the buyer. The duty falls on an organisation that meets the tests in section 54(2), so a supplier below the turnover threshold has no duty under the section, in our reading.

Branded Cups is a cup supplier, and the pages we read say nothing about modern slavery statements. This article does not say whether the duty applies to Branded Cups or to any other supplier. A buyer that wants supply chain information should ask the supplier directly, for example when it asks for a volume quote for the wholesale cups range, and can raise it before the order is placed.

Where this stands

This was checked on 28 October 2026. The Act and GOV.UK guidance are revised from time to time, and an organisation unsure whether it is within section 54 should take advice. Our guide to VAT invoices for a bulk cup order and our guide to late payment between businesses cover two other points a business buyer may meet on a cup order.