UK Modern Slavery Act and Pakistan: What British Buyers Must Document

The UK government's transparency in supply chains guidance, last substantially updated in 2021, specifies clearly what a good MSA statement covers. Independent organizations, notably the Business and Human Rights Resource Centre, the Modern Slavery Registry (previously hosted by CBSR), and academic institutions publishing annual analyses of UK MSA statements, have raised the bar on what constitutes a credible statement. And from 2023, the Home Office has begun quality-assessing submitted statements and publishing the results, creating additional incentive for substantive compliance over box-checking. For British buyers sourcing from Pakistan, the Act creates specific obligations that go beyond having a supplier code of conduct and doing an annual SMETA audit.

What the statement must address: the six areas

The Home Office guidance specifies six areas a statement should cover. Let's examine what each actually requires in the Pakistan sourcing context.

Area one: organisational structure, its business, and its supply chains

This isn't just a company description. It requires enough supply chain mapping that a reader can understand where in the supply chain the risks might sit. For Pakistan, this means identifying at minimum: which product categories are sourced from Pakistan, which regions within Pakistan (Lahore, Faisalabad, Karachi, Sialkot), and whether production goes through factory-to-garment in a single facility or involves sub-contracted processing.

A statement that says "we source from multiple countries including Pakistan" without describing what is sourced from Pakistan, from which types of facilities, and what the supply chain structure looks like is not providing the organisational transparency the guidance requires.

Area two: policies in relation to slavery and human trafficking

Policies are only as meaningful as their operationalization. A statement should describe not just that a policy exists, but how it applies to Pakistan-specific risks. Does the policy specifically address sub-contracting? Does it address home-based work? Does it apply to Tier 2 suppliers, or only Tier 1?

A policy that requires all Tier 1 suppliers to sign a supplier code of conduct is a starting point. A policy that additionally requires Tier 1 suppliers to flow down those requirements to their sub- contractors, and to disclose sub-contractors to the buyer, addresses a layer of the Pakistan- specific risk that a Tier-1-only policy misses.

Area three: due diligence processes

This is where MSA statements most commonly have the weakest documentation. "We conduct third-party social audits" is what most statements say. The guidance is looking for more.

Effective due diligence for Pakistan sourcing includes: the frequency and coverage of audits (which facilities, how often, announced or unannounced?), what happens when findings are identified (corrective action process, timeline, verification of resolution), whether due diligence extends to Tier 2 suppliers, whether any Pakistan-specific risk factors have been identified and specifically addressed, and what data sources inform the due diligence assessment (not just the formal audit, but worker surveys, grievance mechanism data, media monitoring, NGO reports). A statement that describes a complete due diligence system, with named audit frameworks, remediation processes, and evidence of continuous improvement, is in a different category from one that mentions "we work with our suppliers to improve conditions."

Area four: risk assessment

The guidance asks specifically about which parts of the supply chain carry higher risk. For Pakistan sourcing, an honest risk assessment identifies: cotton farming in Sindh and Punjab as a documented higher-risk area for child labor in certain contexts; home-based embellishment work as a structurally invisible and higher-risk tier; certain Tier 2 sub-contractors in regions with less effective labor law enforcement as higher-risk than Tier 1 formal export factories.

A risk assessment that says "our risk level is low because our Tier 1 suppliers have passed SMETA audits" is not an honest risk assessment of Pakistan sourcing. It's a risk assessment of Tier 1 factories, which is one tier in a multi-tier supply chain.

Area five: effectiveness

The guidance asks companies to describe key performance indicators for measuring effectiveness. What are you measuring? What does the data show?

Possible KPIs for Pakistan specifically: percentage of production by volume covered by Tier 1 social audits; percentage of Tier 2 wet processors with ZDHC ClearStream environmental compliance data; percentage of Tier 1 suppliers with disclosed sub-contractor lists; number of grievances reported through worker channels; resolution rate and timeline for identified non- conformances.

None of these are perfect indicators. All of them are more meaningful than "zero incidents reported," which is what many statements report, and which is often a function of not having any reporting mechanisms that workers can access.

Area six: training

Training requirements are often addressed with a brief mention. The guidance is looking for specificity: who receives training (is it just the CSR team, or does it extend to the buying team, the logistics team, the finance team?), what does the training cover (is it generic awareness or Pakistan-specific risk context?), and how is training effectiveness assessed?

Buying teams that understand Pakistan's specific modern slavery risk profile (where the risk is concentrated by sector and supply chain tier, what the documented patterns are, what due diligence looks most effective) make better sourcing decisions than buying teams who've received only generic supplier code of conduct training.

The Home Office quality assessment: what's being scrutinized From 2023, the UK Home Office has published quality assessments of MSA statements submitted to the government's registry. Statements are reviewed against a compliance criteria checklist. The published results show that a significant proportion of statements fail to meet basic compliance criteria, often because they don't address all six mandatory areas, because they're not signed by an appropriate director-level individual, or because they're not published within the required timeframe.

Beyond basic compliance, the Home Office assessment doesn't yet rate statement quality on the depth of the content. But the NGO community that monitors these statements does. Organizations including the Business and Human Rights Resource Centre and University research groups have published analyses ranking statements by quality and publicly identifying brands whose statements are substantially below the standard.

Being identified in a negative analysis of MSA statement quality is a reputational risk that many brands haven't fully factored into their approach to the Act.

The 2025 and forward trajectory: what's changing

The UK government has been considering, for several years, whether to strengthen the MSA through mandatory due diligence requirements similar to the EU's CSDDD. Proposals for an "HRDD" (Human Rights Due Diligence) obligation would go beyond transparency statements to require actual due diligence processes with accountability for outcomes.

While this legislation hasn't passed as of mid-2026, the direction of travel in international supply chain regulation is clearly toward mandatory due diligence. Buyers who have built robust supply chain due diligence programmes now will be ahead of that regulatory trajectory rather than scrambling to catch up when it arrives.

For supply chain documentation and environmental compliance testing that strengthens due diligence programmes, contact Tti Labs at customerservices@ttilabs.net.