PPN 02/23 is still live: the modern slavery note that governs your older contracts
There is a comfortable assumption in public procurement that when a policy note is replaced, the old one stops mattering. PPN 02/23 on tackling modern slavery in government supply chains is a good example of why that assumption is wrong. Its successor tells readers plainly that for procurements commenced and contracts awarded before 24 February 2025, PPN 02/23 is the reference point. Frameworks and dynamic purchasing systems set up under the old rules fall in the same bucket. That is a large, long lived population of contracts, and the obligations attached to it did not expire.
An action note, with a must in it
PPN 02/23 is not advisory for in-scope bodies. It says in-scope organisations must use the guidance Tackling Modern Slavery in Government Supply Chains to identify and manage risks in both new procurement activity and existing contracts, and it set the start date at 1 April 2023.
The scope covers central government departments, their executive agencies, non-departmental public bodies and NHS bodies. Other public sector contracting authorities are invited to apply the same approach. In practice, many of the highest risk categories, textiles, PPE, electronics, are bought heavily outside central government, which is why voluntary adoption is common.
The word that gets skipped is existing. Applying a modern slavery policy to new competitions is straightforward. Applying it to contracts already in flight requires somebody to own it after award, and that ownership is the thing that most often does not exist.
The selection stage requirement, and what happens to the answers
The headline change in PPN 02/23 was a new requirement for supply chain information to be provided at the selection stage of new procurements designated as high risk of modern slavery. Two conditions have to be met before it does anything: a procurement has to be designated high risk, and the information has to be genuinely evaluated.
The first condition fails when risk designation is applied mechanically. If the process never labels anything high risk, the requirement never fires. The updated risk table, which explicitly names cotton, PPE and polysilicon among sectors of concern, exists to stop that happening.
The second condition fails more quietly. Supply chain information arrives, gets filed, and nobody records a view on it. When a concern later emerges, the organisation has documents but no assessment, which is the worst of both worlds: the cost of collection without the protection of a recorded decision.
Exclusion grounds are only as good as your evidence
PPN 02/23 added guidance on using existing exclusion grounds more effectively. Note the word existing. The tools were already there. What was missing was the discipline of building an evidence base capable of supporting their use.
Excluding a supplier is a consequential act and will be tested. The practical question to ask of your own process is whether, if you needed to exclude on modern slavery grounds tomorrow, you could produce a contemporaneous record of what was asked, what was answered, what was independently checked and who concluded what. If the answer involves reconstructing it from email, you do not have an evidence base.
The same records serve a less dramatic but more common purpose: engaging a supplier constructively about a problem in their supply chain. Most modern slavery findings are better resolved through remediation than removal, and both routes need the same underlying facts.
The takeaways
- PPN 02/23 still governs procurements commenced and contracts awarded before 24 February 2025.
- It is an action note: using the accompanying guidance is a must for in-scope organisations.
- Its requirements cover existing contracts as well as new procurement activity.
- High risk procurements must seek supply chain information at selection stage.
- Exclusion grounds were already available, the gap was evidence, not powers.
Want the full breakdown?
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