Perspectives

In April 2025, the UK Government published updated guidance on the reporting obligations set out in the Modern Slavery Act, providing “practical advice to support businesses to undertake meaningful action to tackle modern slavery.”

The UK has pledged to review its approach to supply chain due diligence in light of ongoing pressure, including from a recent Parliamentary inquiry on forced labour in international supply chains and a report from the Business and Trade Select Committee warning that the UK could become a “dumping ground” for forced labour. Increasingly, there are calls to introduce mandatory human rights due diligence to align the UK with other key markets like the EU, avoiding the need for duplicated and burdensome obligations on businesses.

UK Legislative Framework:

The UK currently regulates supply chain forced labour through multiple Acts:

• The Modern Slavery Act 2015 sets out offences of slavery, forced labour and human trafficking while requiring businesses over a certain size to disclose their actions on tackling modern slavery. While the updated guidance aims to clarify reporting obligations set out in section 54 of the Act, this guidance is not mandatory and does not change the Act’s scope or legal requirements.
• The Health and Care Act 2022 introduced duties relating to modern slavery in supply chains within the health service.
• The Procurement Act 2023 aims to deliver world leading standards of transparency, while introducing powers to exclude suppliers where there is clear evidence of their involvement in modern slavery practices.

EU Legislative Framework:

The Business and Trade Select Committee report highlighted the efforts by the European Union (EU) in advancing its 2024 Forced Labour Regulation (FLR) which aims to prohibit the sale and import of goods made with forced labour into the EU, irrespective of the country of origin. The FLR will apply to the entire lifecycle of a product, including any stage involved in the production, manufacture, harvesting or extraction of a product or its components and raw materials. The Act also makes reference to information sharing on forced labour between EU authorities and “third countries” with closer coordination with the UK, and potentially the U.S. also likely to continue in line with shared priorities to combat forced labour globally. Failing to comply could result in the prohibition of the sale of the product, as well as its disposal. Further noncompliance could also result in financial penalties under Member State national law.

Technology and Forced Labour

The tech sector is particularly vulnerable to supply chain forced labour due to its reliance on rare earth minerals, the international nature of supply chains, and the widely used just in time production model. The concentration of manufacturing further raises the risk of forced labour across the supply chain, with implications for the stability of the global tech industry.

However, new technology and innovation also has the potential to help eliminate forced labour. In line with the UN Sustainable Development Goal to eradicate forced labour by 2030, the Global Data Partnership Against Forced Labour was launched at the World Economic Forum in January 2025, with the aim of advancing new approaches for accelerating data and accountability into action against forced labour. The partnership aims to accelerate efforts towards effective data sharing, bridging critical data gaps and utilising new technologies like AI and earth-orbit imagery to further examine the root causes of forced labour. Crucially, it demonstrates how technology is increasingly being deployed to tackle forced labour and improve due diligence across global supply chains.

Navigating obligations

In light of the new obligations set out by the EU’s Forced Labour Regulation, UK businesses should start identifying and addressing forced labour risks across their operations and supply chains before December 2027. Furthermore, and in line with existing obligations under the Modern Slavery Act, companies should start documenting their compliance efforts while monitoring the ongoing developments:

• Reform of the Modern Slavery Act 2015: In its response to a report by the House of Lords in 2024, the Government acknowledged the need for proportionate penalties for non-compliance with the Act, while committing to a review of legislative and non-legislative measures that that will be done in “due course“.
• The Great British Energy Bill: The Government proposed a new amendment to the Bill to ensure forced labour does not take place in the company or its supply chains.
• Employment Rights Bill: The UK’s proposed Employment Rights Bill is set to establish a Fair Works Agency, strengthening enforcement in sectors deemed to be at high risk of forced labour.
• NHS Procurement: The Government recently ran a consultation on tackling modern slavery in NHS procurement aiming to consider the implementation of regulations to ensure NHS supply chains and business activities are free from ethical and labour standards abuses.

Navigating Next Steps

Companies that fail to address forced labour risks face increasing legal consequences, financial penalties and reputational damage, meaning monitoring ongoing legislative and geopolitical developments is crucial. Trilligent can help you navigate the overlapping regulatory frameworks and obligations, proactively engage with policymakers to shape legislative developments, and communicate your commitment to supply chain due diligence.