The Modern Slavery Act 2015 is a United Kingdom statute that, among other provisions, requires commercial organisations carrying on business in the UK with annual turnover of at least GBP 36 million to publish an annual statement on the steps they have taken to ensure that slavery and human trafficking are not taking place in their own operations or in their supply chains. The Act was the first major legislation of its kind in Europe and has subsequently influenced comparable laws in Australia, France, Canada, and elsewhere. For the jewellery and gemstone trade, the Act has driven a significant change in supply-chain disclosure practice, particularly for the larger groups operating in or supplying the British market.

Section 54 and what the statement must cover

Section 54 of the Act, the transparency-in-supply-chains provision, requires the annual statement to be approved by the board, signed by a director, published on the organisation's website with a prominent link from the homepage, and submitted to the UK government's modern slavery statement registry. The statement should describe the organisation's structure, business, and supply chains; its policies on slavery and trafficking; its due diligence processes; the parts of its business and supply chains where the risk is most acute; the steps taken to assess and manage that risk; relevant performance indicators; and the training provided to staff.

The statute does not prescribe the content of the statement in detail — there is no statutory minimum standard — but it does require that the statement be honest. An organisation that has done little can publish a statement saying so, and that statement satisfies the legal requirement. The implicit pressure is reputational: investors, customers, and journalists scrutinise the statements, and an organisation publishing a thin or evasive statement risks serious damage even though it has technically complied.

Application to the jewellery and gemstone supply chain

The jewellery and gemstone trade was identified by Home Office guidance as a sector with elevated risk for forced and child labour, particularly in upstream artisanal and small-scale mining operations. Coloured-stone mining in parts of Africa and Asia, diamond mining in alluvial settings, gold mining in informal sectors, and downstream cutting and polishing operations in regions with weak labour protections are all areas where the risk of exploitation is significant.

For UK jewellery groups above the turnover threshold, compliance has involved establishing supplier codes of conduct, mapping the upstream supply chain to the extent possible, requiring supplier self-certification or third-party audits, joining sector initiatives such as the Responsible Jewellery Council and the Responsible Minerals Initiative, and incorporating modern slavery clauses into supplier contracts. For smaller specialist dealers below the turnover threshold, the legal obligation does not apply, but increasingly clients and partners require equivalent assurances regardless.

Enforcement and gaps

The 2015 Act has been criticised for weak enforcement. There are no penalties for non-compliance with Section 54 beyond the reputational; there is no central enforcement agency; and while the central registry now publishes statements, comparison and accountability are largely left to civil society. The independent review by Frank Field and others in 2019 recommended strengthening enforcement, introducing penalties, and requiring more substantive content; the UK government has periodically committed to such reforms but had not implemented them as a substantial package by the time of writing.

The practical effect is that the Act sets a baseline expectation rather than a binding standard. Leading jewellery groups have moved well beyond the minimum, publishing detailed statements with specific risk assessments and concrete remediation programmes. Less rigorous organisations publish boilerplate statements that satisfy the law but communicate little.

International context

Australia's Modern Slavery Act 2018 introduced a broadly similar reporting requirement with a lower turnover threshold (AUD 100 million). France's Devoir de Vigilance law of 2017 went further, imposing a positive duty of vigilance on large French companies with civil liability for failures. Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act came into force in January 2024, with annual reporting requirements. The EU Corporate Sustainability Due Diligence Directive, adopted in 2024, brings a more demanding harmonised regime across the EU member states. Globally, the trend is toward more stringent and more enforceable supply-chain transparency, and jewellery businesses operating internationally now face a patchwork of comparable but non-identical regimes.

Implications for sourcing practice

The cumulative effect of these laws on gemstone sourcing is real if uneven. Major retailers have pushed disclosure requirements down their supply chains, and origin-traceability initiatives — Gemfields' producer-direct model, the Responsible Jewellery Council's chain of custody standard, and various blockchain pilots — have grown in part in response. For Skyjems and other coloured-stone specialists, the practical posture is to maintain documented sourcing records, work with suppliers willing to provide chain-of-custody information, and be prepared to answer questions from clients about where their stones come from. The trade still has significant gaps in upstream traceability, particularly for stones from small-scale mining, but the trajectory of the legal regime is unambiguously toward more disclosure and more accountability over time.

Further reading

• UK Government — Modern Slavery Act 2015 full text
• UK Home Office — modern slavery resources and statutory guidance
• Responsible Jewellery Council — chain of custody standard
• Responsible Minerals Initiative — RMAP framework