UK Supply Chain Due Diligence

The UK Parliament’s Joint Committee on Human Rights has issued a report which includes a stark warning that the current UK Modern Slavery Act (MSA) transparency requirements are failing to prevent forced labour in UK business’ supply chains. Walk Free analysis cited in the report suggests $26bn worth of goods linked to forced labour risks are entering the UK annually. The committee is urging the government to move from a voluntary approach to mandatory human rights due diligence. 

Whilst further legislation in the UK may be over the horizon, it’s a good time for UK companies to improve their approach to supply chain due diligence.

Findings

The UK’s Modern Slavery Act was designed to improve transparency and prevent UK businesses supporting forced labour in supply chains, but the parliamentary committee finds that it lacks enforcement and reach. Forty percent of in-scope companies do not report at all, while many that do, publish vague, superficial statements.

Section 54 of the Act allows firms to legally declare that they have taken no action. Whilst injunctions for non-compliance are applicable, so far none have been issued. The result is limited accountability and a weak business response to the real risk of forced labour in global supply chains.

The Joint Committee references findings from Walk Free that products worth over $26bn linked to forced labour are entering the UK each year. Many business leaders agree that most UK companies with international supply chains are exposed and that legislation in this area must improve.

Recommendations

The Committee has recommended that the government introduce a new legal duty on businesses to conduct human rights due diligence. This would move the UK closer to the European Union’s CSDDD, expected to come into force from 2026.

Key proposals include:

  • Replacing voluntary statements with mandatory, evidence-based reporting
  • Expanding the scope to cover more companies and public bodies
  • Removing the option to report no action taken
  • Introducing penalties for non-compliance
  • Creating a centralised registry of disclosures
  • Establishing a Supply Chain Centre to support business implementation

 

Policymakers are also considering lighter requirements for SMEs and phased implementation aligned with the EU approach.

Improving Due Diligence

Companies can act now to adopt due diligence practices which address the risks identified in the committees report.

Focus areas include:

  • Mapping supplier networks and identifying high-risk categories
  • Embedding risk screening and control mechanisms in procurement
  • Engaging suppliers to strengthen governance and traceability
  • Aligning internal practices with international standards such as the UNGPs and OECD Guidelines
  • Preparing to evidence decisions and disclose outcomes

This is not a task for compliance teams alone. The requirements will affect procurement, legal, operations and sustainability teams. Clear ownership, defined responsibilities and integrated processes will be critical.

The direction of travel for regulations globally is towards more responsible supply chains. UK companies should act early to reduce the risk and position themselves as leaders.

How Jordisk can help

We work with businesses to integrate sustainability into their operations while ensuring compliance with evolving global supply chain legislation. We help organisations:

  • Identify and address human rights risks in global supply chains.
  • Design and implement due diligence frameworks aligned with MSA guidance, UN principles, OECD guidelines, and EU regulations.
  • Enhance transparency and reporting to successfully engage with external stakeholders on human rights.
  • Prepare for mandatory due diligence legislation by embedding robust, evidence-based processes before they become a legal necessity.

In a regulatory landscape that is shifting toward stricter requirements and higher expectations, Jordisk ensures that businesses are not just compliant but are leaders in responsible and transparent supply chain management.

Suppliers looking to improve your position with your customers? Read our previous post on ESG for suppliers

Contact our team today for expert guidance on ESG management.

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