Joint Committee publishes its report on Forced Labour in UK Supply Chains

On 24 July 2025, the Joint Committee on Human Rights[1] (the “Joint Committee”) published its Report on Forced Labour in UK Supply Chains (the “Report”). The publication of the Report follows the inquiry launched by the Joint Committee on 21 January 2025 exploring the UK’s legal and voluntary frameworks that address forced labour in international supply chains (see our previous blog post here).

The inquiry found evidence that goods which have been made, in full or in part, using forced labour are entering the UK market despite the Government’s stated position that no company operating in the UK should have any forced labour in its supply chain. The Report states that the UK is now falling behind international trading partners in its approach to addressing forced labour in supply chains.

The Report’s overarching recommendation is to strengthen existing legislation and its enforcement, as well as create new laws to establish corporate responsibility (including mandatory human rights due diligence), an import ban on goods linked to forced labour, and a “duty to prevent” to establish civil liability for companies who do not take adequate steps to prevent forced labour in their supply chains. 

The Report’s themes 

The Report explores six different themes: corporate responsibility; import bans and restrictions; enforcement mechanisms; free trade agreements; public procurement; and access to justice for survivors. In reviewing the evidence received, the Joint Committee compared the existing framework in the UK with examples of frameworks from other countries. 

Main recommendations

• Changes to existing legislation: The report states that there is currently a patchwork of domestic legislation, which does not prevent goods made with forced labour from entering the UK market. It recommends that the reporting duty under s.54 Modern Slavery Act 2015 (the “MSA”) be strengthened by establishing accountability mechanisms for non-compliance and removing the option for companies to state that they have not taken any steps to address the risk of modern slavery in their supply chain. Additionally, the Report suggests that MSA reporting should be extended to public organisations.
• Mandatory human rights due diligence: The Report finds that the UK is not currently keeping pace with other states and should impose mandatory supply chain due diligence, regulatory oversight and accountability measures with financial penalties for non-compliance. Evidence from the business sector showed a willingness for mandatory due diligence which would create a level playing field and consistency across markets, with some relief to be offered to SMEs where appropriate. The report acknowledged that the UK should be mindful of the outcome of negotiations on the EU’s Corporate Sustainability Due Diligence Directive to avoid creating conflicting regulatory burdens for international businesses.
• Import bans: The Joint Committee reviewed the effectiveness of both forthcoming and existing import bans in the EU and USA (respectively) and highlighted the risk of the UK becoming a “dumping ground” for goods that can’t be sold elsewhere. The Report recommends introducing an import ban to prevent goods produced using forced labour from entering the UK market, based on a rebuttable presumption, inspired by the USA’s Uyghur Forced Labour Prevent Act. This presumption would assume that all goods produced by or in certain countries are considered to be made with forced labour unless proven otherwise with “clear and convincing evidence”.
• Better use of existing powers: The Report found that there are powers available under the Proceeds of Crime Act 2002 (“POCA”[2]) which are underused by enforcement agencies in respect of goods linked to forced labour. The Report recommends overcoming barriers to enforcement so that agencies can use their powers under POCA to prevent goods, and seize goods, linked to forced labour being sold in the UK.
• Free trade agreements: The analysis found that, while the UK does implement human rights clauses to a degree in international trade agreements, it does not have a stated policy regarding their inclusion nor a mechanism to assess their effectiveness. The Report recommends that the Government replicates the EU’s systemic approach of including human rights clauses in its international trade agreements to demonstrate its strong stance against forced labour and human rights abuses. 
• Public procurement: The evidence found that public procurement has a higher risk of exposure to forced labour compared to the private sector owing to, among other reasons, complex supply chains and the drive to prioritise lower costs. It expressed concern around how the green transition will affect forced labour in supply chains given the reliance on critical minerals sourced outside of the UK. The Report strongly encourages the inclusion of a clear approach to managing the risks of forced labour when revising the Critical Minerals Strategy.
• Access to justice for survivors: The Report found that, currently, it is too difficult for survivors of forced labour to access justice in the UK after being subject to forced labour abroad in the supply chains of UK companies. The Report recommends establishing a civil cause of action for failure to prevent forced labour, with the burden placed on the relevant corporation to prove that they had adequate procedures in place to prevent such forced labour. 

Next steps

The publication of the Report builds on the current momentum in the UK to strengthen the approach to responsible business conduct, as recently signalled by the Department for Business and Trade (“DBT”) in June, when it published the UK’s Trade Strategy. It announced a review of its approach to ensuring responsible business conduct, focusing on the global supply chains of businesses operating in the UK. The DBT also announced plans to establish a Supply Chain Centre, which the Report recommends should support companies to conduct effective human rights due diligence by providing a single point of access to verified information and resources.

The Joint Committee calls on the Government to introduce legislation to implement its recommendations within one year of the Report’s publication to protect the UK’s market from goods tainted by forced labour, and the Government is expected to reply to the Report within two months of its publication.

[1] The Joint Committee on Human Rights is made up of twelve members, appointed from both the House of Commons and the House of Lords. Its role is to examine matters relating to human rights within the UK and scrutinise every Government Bill for its compatibility with human rights.

[2] The Report considers the case of R (World Uyghur Congress) v National Crime Agent in which, in 2024, the Court of Appeal found that money laundering offences can be committed under POCA even where adequate consideration has been paid for the criminal property (see our blog on the case here), but the Report found mixed evidence on what this would mean in practices for businesses.