PPN 02/23 Tackling Modern Slavery in Government Supply Chains: what the 2023 action note required

The key facts

• PPN 02/23 is an action note issued in February 2023 on tackling modern slavery in government supply chains.
• It applies to all central government departments, their executive agencies, non-departmental public bodies and NHS bodies, referred to as in-scope organisations.
• Other public sector contracting authorities may wish to apply the same approach.
• In-scope organisations should begin applying it to existing contracts and to new procurement activity from 1 April 2023.
• In-scope organisations must use the guidance Tackling Modern Slavery in Government Supply Chains to identify and manage risks in new procurement activity and existing contracts.
• The risk assessment table was updated to include current global risks in key sectors of concern such as cotton, PPE and polysilicon.
• It introduced a new requirement for supply chain information to be provided at the selection stage of new procurements designated as high risk of modern slavery.
• It added guidance on enhanced due diligence activities and on using existing exclusion grounds more effectively.
• The International Labour Organisation estimates 50 million people are living in modern slavery worldwide, and the Modern Slavery Act 2015 consolidates offences, toughens penalties and prosecution and improves victim support.

What PPN 02/23 is and who it applies to

PPN 02/23 is the February 2023 action note on tackling modern slavery in government supply chains. Modern slavery is used as an umbrella term covering slavery, servitude, forced and compulsory labour and human trafficking. The note opens from the position that departments must take action so that modern slavery risks are identified and managed effectively in government supply chains.

It applies to all central government departments, their executive agencies and non-departmental public bodies, and to NHS bodies. These are referred to as in-scope organisations. Other public sector contracting authorities may wish to apply the same approach, and the note asks that it be circulated internally, particularly to those with a commercial, procurement or contract management role.

This is an action note rather than an information note, which is significant. It contains a must: in-scope organisations must use the accompanying guidance, Tackling Modern Slavery in Government Supply Chains, to identify and manage risks in both new procurement activity and existing contracts.

What the note required

The central obligation is to apply the accompanying guidance to two populations at once: new procurement activity, and existing contracts. That dual scope is what distinguishes this from a tendering only policy. A department cannot satisfy the note simply by adding a question to its selection questionnaire.

The note highlighted that the table used for assessing the risk of modern slavery had been updated to include current global modern slavery risks in key sectors of concern, naming cotton, PPE and polysilicon. Those categories reflect known concentrations of forced labour risk in international supply chains, and they set the direction for how organisations should target their effort.

It also introduced a new requirement for supply chain information to be provided at the selection stage of new procurements designated as high risk of modern slavery. The placement at selection stage matters: it puts the information in front of buyers early enough to influence whether a supplier proceeds, rather than surfacing it after award.

Finally, the note flagged additional guidance on enhanced due diligence activities and on using existing exclusion grounds more effectively. No new exclusion power was created. The point was that the grounds already available were being underused, largely because organisations were not gathering the evidence needed to rely on them.

Why it mattered

The background section sets out the rationale plainly. The International Labour Organisation estimates that 50 million people are living in modern slavery across the world. It is thought to be prevalent across the UK and can occur in any business sector. The Modern Slavery Act 2015 was introduced to tackle these crimes, consolidating and clarifying offences, toughening penalties and prosecution, and introducing greater support and protection for victims.

The note then makes the procurement argument: while laws exist to punish instances of modern slavery, government has the opportunity to use its extensive buying power to mitigate the risk of it occurring in its supply chain, by adopting new processes and procedures in both procurement and supplier management. Buying power is framed as a preventive tool, not just a compliance obligation.

That framing explains why the note reaches into supplier management as well as procurement. Prevention happens over the life of a contract, through the relationship, the information flow and the willingness to act on what is found.

Where PPN 02/23 sits today

PPN 02/23 has been succeeded on this topic by PPN 009, the information note previously issued in February 2023 and updated in February 2025 to reflect the terminology of the Procurement Act 2023 and the Procurement Regulations 2024. PPN 009 states that for procurements commenced and contracts awarded before 24 February 2025, readers should refer to PPN 02/23.

That means PPN 02/23 is not historical trivia. It remains the reference point for a large live population of contracts: anything commenced before 24 February 2025, including awards made through frameworks, dynamic purchasing systems or qualification systems established under the previous legislation. Those contracts can run for years.

Practically, organisations need to know which note governs which contract, and to keep applying the ongoing obligations for the older population. The substance of the two notes is closely aligned, so the operational answer is usually a single consistent process with the correct legislative references applied to each cohort.

How eSourcing Data helps

PPN 02/23 places its new requirement at selection stage, which is precisely where a structured eSourcing process earns its keep. eSourcing Data lets buying teams attach the supply chain information requirement to procurements designated as high risk, capture responses in a consistent format and record the assessment against each one, so the selection decision has a visible basis.

Because the note also covers existing contracts, the supplier and contract records held on the platform matter as much as the competition itself. Keeping questionnaire responses, correspondence and contract documentation together gives contract managers something to revisit, and gives reporting a base to work from when leadership asks where the organisation's exposure to sectors of concern actually sits.

The exclusion point comes down to evidence quality. A recorded, timestamped trail of what was asked, what was answered and what was checked is what makes a decision defensible. That audit trail is a by-product of running the process in one place rather than an extra task bolted on afterwards.

What to do about it

1. 1Identify which of your live contracts were commenced or awarded before 24 February 2025 and therefore sit with PPN 02/23.
2. 2Apply the Tackling Modern Slavery in Government Supply Chains guidance to those existing contracts, not just to new competitions.
3. 3Use the updated risk assessment approach, including sectors of concern such as cotton, PPE and polysilicon.
4. 4Ensure procurements designated as high risk request supply chain information at selection stage.
5. 5Assess and record the responses rather than simply collecting them.
6. 6Set out an enhanced due diligence route for cases where responses raise concerns.
7. 7Review how existing exclusion grounds are evidenced so they can actually be relied on.