Modern slavery | UK Regulatory Outlook February 2025

Joint Committee on Human Rights run inquiry into forced labour in global supply chains  

The House of Commons Joint Committee on Human Rights held a new inquiry into forced labour in global supply chains. This follows on from the UK Parliament's Modern Slavery Act Committee report on the Modern Slavery Act 2015 which found the UK to be falling behind other nations. This new inquiry follows on from the government's response to the previous report where it recognised that it needed to conduct a review of both legislative and non-legislative measures to tackle forced labour and increase transparency in global supply chains. The inquiry will review whether these measures are effective or if changes are required. 

Questions put forward by the inquiry included whether the obligations created by the Modern Slavery Act 2015 are effective in preventing goods with international supply chains linked to forced labour being sold on the UK market. It asked whether public procurement attracts a higher risk of exposure to forced labour. It also raised questions around enforcement and whether the UK should consider implementing elements of other international legislation, such as the EU's Forced Labour Regulation and the Corporate Sustainability Due Diligence Directive. The inquiry closed on Friday 14 February. 

While the government's previous response to the report on the effectiveness of the Modern Slavery Act 2015 indicated that reform was not a short-term priority, this new inquiry demonstrates a commitment to exploring necessary changes in this area. It will be interesting to see the evidence gathered from stakeholders and how the government plans to address the findings of the inquiry. 

Independent Anti-Slavery Commissioner Strategic Plan 2024-2026 published 

On 11 February 2205, the Independent Anti-Slavery Commissioner (IASC) published its Strategic Plan for 2024-2026. The plan highlights that in 2023 there were 17,0004 potential modern slavery victims in the UK, which is the highest ever number of potential victims identified.  

The plan sets out three primary objectives which guide its actions: preventing modern slavery and re-victimisation, protecting victims, and prosecuting offenders and supporting victims through the criminal justice system. As part of the first objective, the IASC plans to "make prevention everyone's business" and push for mandatory human rights in supply chain due-diligence obligations to be implemented in the UK, as well as pressing the government to strengthen its policy response to forced labour in domestic and global supply chains. The plan refers to the recommendations made in last autumn's House of Lords select committee report, which stated that the current government should revisit the previous government's Modern Slavery Bill, which would mandate the content of statements and introduce proportionate sanctions for non-compliance, and would introduce mandatory due diligence for human rights in supply chains.  

The plan also covers provisions for the supply chains of public bodies. The IASC states that it will "encourage public bodies to voluntarily emulate the transparency of supply chain provisions that modern slavery legislation across the UK requires of businesses" as well as supporting and monitoring the implementation of the December 2023 review into risk of modern slavery and human trafficking in NHS supply chains. 

Given recent Parliamentary committees examining the effectiveness of the Modern Slavery Act (see our previous Regulatory Outlook)  and the recent inquiry into forced labour in global supply chains, it will be interesting to see whether the government considers these recommendations. 

Competitiveness Compass for the EU aims to simplify ESG regulation

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