Time to rethink the UK’s approach to modern slavery? Parliamentary inquiry into forced labour in international supply chains

On 21 January, the UK Parliamentary Joint Committee on Human Rights (“the Joint Committee”) launched an inquiry into the UK’s legal and voluntary frameworks that address forced labour in international supply chains.[1] The Joint Committee's findings and conclusions could prompt substantial reform to the existing legislative framework, including the corporate reporting requirements under the Modern Slavery Act 2015. 

Growing scrutiny of the UK’s anti-modern slavery approach

The Terms of Reference[2] for the inquiry highlight a potential incongruence between the Government’s expectation that “no company in the UK … should have any forced labour whatsoever in its supply chain”[3] and the legislative and regulatory frameworks currently in place to identify and avoid forced labour. This builds on recent criticism of the UK’s anti-modern slavery regime, with the publication in October 2024 of a report by a House of Lords Select Committee suggesting that the Modern Slavery Act 2015 has fallen behind global developments. In response, the Government reaffirmed its commitment to tackling the broader issue of modern slavery but did not outline any significant legislative changes.

Similar concerns about the UK’s current anti-modern slavery regime were raised on 11 February in a publication by the Independent Anti-Slavery Commissioner (the “IASC”) (whose role is to work collaboratively with the Government and its partners to ensure modern slavery is effectively tackled in the UK) of its strategic plan for 2024-2026.[4] The plan states that “whilst the registry [for modern slavery statements launched in 2021] is a welcome step, there is disparity amongst the Statements and their quality, there is little evidence of the downstream outcomes and there is a case for needing to improve section 54’s enforceability”. It also notes that the UK has neither introduced mandatory human rights due diligence legislation, nor forced labour trade import bans and other sanctions, such as asset freezing – measures that have been introduced in some other countries. 

In encouraging the Government to strengthen its policy framework, pushing for mandatory human rights due diligence legislation, and committing to work to improve compliance with existing regulations and best practice, the IASC’s report is broadly aligned with the recommendations made by the House of Lords Select Committee in October 2024. The scope of the more recent inquiry is, however, seemingly wider than that of the earlier House of Lords report, as the Joint Committee will focus on the broader legislative framework, consumer behaviour and procurement, rather than just the Modern Slavery Act 2015.

Corporate activity in the spotlight

Of most interest to companies will be the Joint Committee’s focus on corporate activity and its role in tackling forced labour in international supply chains. The inquiry will focus on companies’ obligations when it comes to forced labour in their supply chains, and whether these are effective. The Joint Committee is seeking to understand what can be done to improve the ability of companies to identify forced labour risks in their supply chains, and what level of due diligence is proportionate and can reasonably be expected before contracting with suppliers.

International approaches may inform the development of the UK’s framework to tackle modern slavery

The inquiry will also review international legislative developments to consider whether these measures may be appropriate for the UK. These include import bans focusing on certain regions (such as the U.S.’ Uyghur Forced Labor Prevention Act), general import bans (such as the EU’s recently passed Forced Labour Regulation) and due diligence regimes (such as the EU’s Corporate Sustainability Due Diligence Directive). 

Next steps

It is unclear when the report will be published. When it is finalised, it is likely to be influential in shaping any future legislative and regulatory changes.

[1] New inquiry: Forced Labour in UK Supply Chains - Committees - UK Parliament

[2] https://committees.parliament.uk/call-for-evidence/3541/

[3] UK Supply Chains: Uyghur Forced Labour - Hansard - UK Parliament

[4] Independent Anti-Slavery Commissioner Strategic Plan 2024-2026