BFI makes Modern Slavery compliance mandatory for suppliers

The British Film Institute (BFI) has updated how it governs suppliers by making expectations linked to the Modern Slavery Act 2015 a mandatory part of its supplier code of conduct. The organisation said meeting the revised code is now required for any organisation that wants to contract with BFI, positioning compliance as a condition of procurement rather than an optional commitment.

BFI said the updated approach is designed to strengthen controls over risks connected to forced labour, human trafficking and broader labour exploitation within its procurement network. It described the move as a governance measure intended to reduce legal and reputational exposure linked to labour exploitation in procurement activity.

Modern Slavery standards tied directly to contracting eligibility Modern Slavery standards tied directly to contracting eligibility Under the revised code Under the revised code, BFI said contractors must satisfy specified requirements to be considered for work. The organisation said it is applying the standards across its contracting relationships, meaning eligibility to supply services depends on adherence to the code. BFI framed the change as a procurement compliance and risk-management model. It said suppliers must be able to meet the stated expectations to remain eligible for BFI work, making the code central to how procurement decisions will be taken. Due diligence, audits and training set out as supplier requirements BFI said the updated code requires contractors to maintain due diligence processes aimed at identifying and addressing risks related to human trafficking. The organisation also stated that suppliers must run internal audits and provide staff training connected to those risks. These measures are presented by BFI as the These measures are presented by BFI as the operational tools it expects suppliers to have in place in order to manage exploitation risks associated with procurement activity. The organisation’s position is that these requirements will now be part of how it assesses suppliers for contracting purposes.

Responsibilities extend through subcontracting and multi-tier supply chains

BFI said the governance framework is not confined to firms that contract directly with the organisation. The updated model places responsibility on primary suppliers to ensure subcontractors meet the same standards, extending expectations through downstream relationships. The British Film Institute The organisation said it is seeking to address risk areas that can emerge through subcontracting, including vulnerabilities that may appear further down multi-tier supply arrangements. By linking subcontractor obligations to the primary supplier relationship, BFI said the framework is intended to apply consistent expectations across different tiers of supply.

However, BFI has not provided additional detail on how compliance will be verified across complex supply chains beyond the requirements described in the code. That leaves open questions around how checks will operate in practice where supply arrangements involve multiple layers.

£36 million turnover threshold links reporting to eligibility

BFI said the revised eligibility standards also incorporate reporting expectations under the Modern Slavery Act 2015 that apply to larger organisations. Suppliers with a global turnover exceeding £36 million must publish annual statements in line with statutory requirements to remain eligible for BFI contracts.

According to BFI, the policy connects that reporting obligation directly to contracting decisions. It said suppliers above the £36 million threshold must be able to demonstrate that the required annual statement has been produced as part of maintaining eligibility.

Board oversight and annual review, with enforcement detail still unclear BFI said oversight of the updated framework sits with the BFI board, and that supplier standards will be reviewed annually to stay aligned with regulatory expectations over time. While adherence is set as a condition of procurement, the organisation has not set out further enforcement detail on how compliance will be checked across complex supply chains.

Even so, BFI’s stated position is that meeting the updated supplier code of conduct is now required for organisations seeking to work with the institute.