The UK Parliament's Joint Committee on Human Rights has launched a new inquiry into forced labour in UK supply chains. This review will assess the effectiveness of the UK's legal and voluntary frameworks, including the Modern Slavery Act 2015, in addressing forced labour risks in international supply chains. The inquiry – open until 14 February - provides an opportunity for businesses to shape the future of UK policy and highlight practical challenges in managing forced labour risks. The inquiry comes at a pivotal time, with the UK government reviewing its approach to modern slavery and responding to mounting pressures to strengthen protections against forced labour.
Parliamentary Committee's Call for Evidence
The Joint Committee on Human Rights, consisting of members from both the House of Commons and Lords, is seeking input on topics relating to human rights in supply chains, including:
- Legislative gaps: Whether the Modern Slavery Act 2015 still effective or whether the UK needs stronger measures to prevent forced labour-linked goods from entering the market.
- Corporate responsibilities: Considering whether businesses should face mandatory due diligence obligations to manage forced labour risks and how these requirements could be proportionately tailored based on company size and risk exposure.
- International comparisons: Exploring the potential benefits of adopting elements of the US Uyghur Forced Labor Prevention Act or the EU's Corporate Sustainability Due Diligence Directive to enhance the UK's framework and promote a level playing field.
- Enforcement: Whether public bodies, such as the Anti-Slavery Commissioner and Border Force, have sufficient powers and resources to effectively tackle forced labour.1
Why Engage?
It is estimated that 27.6 million people globally are subject to forced labour, including 3.3 million children. Evidence suggests that goods produced under such conditions are available in the UK, allowing business practices that violate human rights to profit from UK consumers. While the Modern Slavery Act 2015 criminalises forced labour and enhances victim protections, there are growing concerns that the UK is falling behind other jurisdictions, such as the US and EU, which have introduced more stringent human rights due diligence laws.
As scrutiny over global supply chains intensifies, businesses are facing growing pressure to address forced labour and broader human rights risks. Potential changes to UK legislation could significantly impact compliance obligations, introduce additional or stricter due diligence requirements and alter enforcement risks.
UK Focus on Forced Labour
This inquiry comes at a pivotal time, with the UK government reviewing its approach to modern slavery and responding to mounting pressures to strengthen protections against forced labour:
- UK Government review of the Modern Slavery Act: In its response to the House of Lords' 2024 report2 on 16 December 2024, the government acknowledged the need for stronger enforcement mechanisms and proportionate penalties for non-compliance. It has also committed to consulting on mandatory due diligence requirements for businesses.
- Employment Rights Bill: The UK's proposed Employment Rights Bill3, which includes the creation of the Fair Work Agency, aims to consolidate labour enforcement and bolster worker protections, particularly in sectors at higher risk of forced labour. The Public Bill Committee reported to Parliament in January 2025.4
- Industry evidence: Parliamentary sessions5 in January 2025 have spotlighted challenges faced by businesses with complex global supply chains. Testimonies have not only underscored the difficulties of identifying and mitigating forced labour risks but have also highlighted growing scrutiny of companies' practices.
While the UK's approach has historically relied on transparency measures under the Modern Slavery Act, the government's recent responses indicate a willingness to consider stricter enforcement and mandatory due diligence requirements, aligning more closely with global trends.
A Global Shift in Tackling Forced Labour
The UK's review of its approach to forced labour takes place against a backdrop of stricter regulation in the US and EU to combat labour exploitation.
In 2022, the United States enacted their Uyghur Forced Labor Prevention Act6, which put in place a rebuttable presumption for goods produced in the Xinjiang Uyghur Autonomous Region of China, or by certain identified entities, are made with forced labour, and therefore subject to an import prohibition in the United States.
The EU has adopted a more prescriptive and enforceable approach to forced labour through its new Forced Labour Regulation, effective from late 2027.7 This prohibits the import, sale, and export of goods made with forced labour, regardless of origin or sector. This comprehensive ban covers products linked to forced labour at any stage of their production or supply chain and aligns with International Labour Organization standards, prioritising risk-based investigations by member state authorities. This regulation complements a broader suite of EU laws requiring transparency and supply chain due diligence, including the Corporate Sustainability Due Diligence Directive8.
For businesses with an international footprint, the increasingly complex and stringent regulatory landscape demonstrates the growing global expectation for robust oversight of supply chain risks, and they must align their compliance strategies accordingly.
Next Steps
The deadline for written submissions to the Joint Committee is 14 February 2025. Businesses, industry groups and other stakeholders are encouraged to respond to the inquiry's terms of reference and provide evidence or share practical challenges and insights via Parliament's website to inform the Committee's recommendations. Contributions will play a key role in ensuring a robust regulatory framework that is proportionate and workable.
Dominic Oben (Trainee, London) and Ruth Benbow (Knowledge Manager, London) contributed to the development of this publication.
1 UK Parliament-Joint Committee on Human Rights, "New inquiry: Forced Labour in UK Supply Chains", 21 January 2025, available here.
2 UK Home Office, "Government response to House of Lords Modern Slavery Act 2015 Committee report, 'The Modern Slavery Act 2015: becoming world-leading again'" 16 December 2024, available here.
3 UK Parliamentary Bills, "Employment Rights Bill", available here.
4 Employment Rights Bill publications - Parliamentary Bills - UK Parliament
5 See UK Parliament-Business and Trade Committee, "Make Work Pay: Employment Rights Bill Inquiry", available here.
6 See our client alert on the US' Uyghur Forced Labor Prevention Act, " US Authorities Begin Enforcement of Uyghur Forced Labor Prevention Act and Issue Guidance for Importers", available here.
7 See our client alert on the EU's Forced Labour Ban, "EU Adopts Forced Labour Ban: 8 Things to Know", available here.
8 See our client alert on the Corporate Sustainability Due Diligence Directive, "Time to get to know your supply chain: EU adopts Corporate Sustainability Due Diligence Directive", available here.
White & Case means the international legal practice comprising White & Case LLP, a New York State registered limited liability partnership, White & Case LLP, a limited liability partnership incorporated under English law and all other affiliated partnerships, companies and entities.
This article is prepared for the general information of interested persons. It is not, and does not attempt to be, comprehensive in nature. Due to the general nature of its content, it should not be regarded as legal advice.
© 2025 White & Case LLP
