Category: Social risk · Reviewed by Mark Fox, Broker · Renewals · Last reviewed 2026-06-10
Modern slavery insurance is not a standalone UK policy but a constellation of cover — primarily D&O, EPLI and crisis management — responding to investigations, claims and reputational harm arising under the Modern Slavery Act 2015.
Category: Social risk Also known as: MSA insurance, Modern Slavery Act insurance, Anti-slavery liability cover Typical UK market form: D&O endorsement, crisis management add-on, EPLI extension Related concepts: Modern Slavery Act 2015, Supply chain due diligence insurance, Forced labour insurance, Directors and officers insurance
Modern slavery insurance is a portfolio of insurance responses that addresses the exposures arising from the Modern Slavery Act 2015 and equivalent international legislation. There is no single UK policy badged “modern slavery insurance”; instead, the relevant cover sits within Directors’ and Officers’ (D&O) liability, Employment Practices Liability Insurance (EPLI), crisis management, reputational risk and supply chain endorsements.
The exposure is twofold. First, statutory and regulatory: directors and senior managers of in-scope organisations face investigation costs, civil proceedings and reputational consequences if the Section 54 transparency statement is absent, misleading or contradicted by subsequent findings. Second, civil and reputational: victims, NGOs, customers and investors can bring or threaten action where forced labour, debt bondage or human trafficking is alleged in the operations or supply chain.
The principal statute is the Modern Slavery Act 2015 (c. 30), which received Royal Assent on 26 March 2015. Section 54 requires commercial organisations carrying on a business in the UK with an annual turnover of £36 million or more to publish an annual slavery and human trafficking statement. The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 (SI 2015/1833) set the turnover threshold. The statement must be approved at board level (or equivalent) and signed by a director, member or partner.
Adjacent statutes overlap. The National Minimum Wage Act 1998 covers wage underpayment, frequently a feature of labour exploitation cases. The Public Interest Disclosure Act 1998 protects whistleblowers who expose modern slavery practices. The Equality Act 2010 may engage where exploitation aligns with protected characteristics. UK financial sanctions under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) can apply where designated persons are implicated in trafficking networks, and OFSI guidance requires reporting of suspected breaches.
Enforcement is shared between the Home Office, the Gangmasters and Labour Abuse Authority (GLAA), HMRC’s National Minimum Wage team and, for serious organised crime, the National Crime Agency. The Independent Anti-Slavery Commissioner publishes guidance and reports. Directors face personal exposure under the Companies Act 2006 s.172 duty to have regard to the impact of operations on the community, which courts and regulators increasingly read alongside ESG disclosure obligations.
D&O policies (Side A, B and C) are the principal vehicle. Standard ABC wordings respond to investigation costs, defence costs and, where civil damages are awarded, indemnify directors and the company for non-criminal liabilities. Side A cover for individual directors is critical because indemnification by the company may be unavailable in insolvency or where the company itself is the subject of investigation. Most London market D&O wordings (AIG, Chubb, Allianz, Beazley, CFC) now expressly contemplate ESG investigation costs, although coverage for fines and penalties is restricted to where insurable as a matter of UK law.
EPLI sits alongside D&O and responds to employment-related allegations such as harassment, discrimination and unlawful deductions from wages — frequent companions to modern slavery findings. Crisis management and reputational risk products (e.g. Munich Re Reputational Risk, Aon ReputationCoverage, Howden Crisis Management) fund PR consultants, forensic accountants and legal counsel. Trade credit and supply chain endorsements may indemnify the cost of disengaging from an exposed supplier. Sanctions exclusions are universal: the LMA 3100 Sanctions Limitation and Exclusion Clause and the older NMA 2918 sit on virtually every policy.
Exclusions to watch include conduct exclusions (deliberate, dishonest or fraudulent acts), prior known circumstances, criminal fines, and bodily injury carve-outs that may bite where victims allege personal injury. Brokers should confirm investigation cover is triggered by formal regulatory action and not limited to post-charge defence.
The UK D&O market hardened sharply between 2019 and 2022 then softened from late 2023. By 2026 capacity is again abundant but underwriters scrutinise ESG governance carefully. Lloyd’s syndicates and London company markets (Chubb, AIG, Allianz, Travelers, Beazley) routinely request the latest s.54 statement, board minutes evidencing approval, supplier audit programmes and any media coverage of allegations.
Premiums for FTSE 250 corporates typically range from £25,000 to £150,000 per £5m of D&O limit depending on sector exposure (apparel, construction, agriculture and hospitality attract loadings). SME premiums for in-scope businesses (turnover £36m to £200m) generally start around £8,000 to £25,000 for £5m primary D&O.
A UK clothing wholesaler with turnover of £85m purchased garments from a Leicester subcontractor later linked to wage and labour breaches. An NGO investigation prompted a Sunday newspaper exposé. The Independent Anti-Slavery Commissioner opened correspondence; HMRC’s NMW team launched an inquiry. The wholesaler’s D&O insurer funded specialist solicitors and a corporate PR firm under the crisis management extension. EPLI responded to claims by directly employed warehouse workers. Total defence and crisis spend reached £620,000 over fourteen months; no criminal charges followed but the company restructured its supply chain audit programme.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-10. Next review: 2026-12-10.
Apex Insurance Brokers Limited. Authorised and regulated by the Financial Conduct Authority, FRN 724952. Registered in England and Wales, Companies House 07014570. This entry provides general information about UK insurance concepts and is not regulated advice. Consult your insurance broker on your specific position.
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