Forced labour in supply chains

A light is currently being shone on the issue of forced labour in UK supply chains, with significant public interest.

In addition to debates and written questions by MPs and peers, the Business and Trade Committee has questioned retailers such as Shein and Temu as part of its Making Work Pay: The Employment Rights Bill inquiry, and in January the Joint Committee on Human Rights launched a new inquiry on forced labour in UK supply chains. An increase in scrutiny means that companies should take additional care to protect against forced labour featuring in their supply chains.

Over and above this increased interest, what is legally required of companies is also developing.

Domestic legal requirements

In the UK, forced labour in supply chains is addressed in section 54 of the Modern Slavery Act 2015 (‘MSA’). This requires commercial organisations carrying out business in the UK to produce a statement each year, setting out steps taken to ensure that slavery and human trafficking is not taking place in its supply chains or business. At the time of its introduction, the MSA was considered groundbreaking; however, the House of Lords MSA Committee published a report in October 2024 indicating that the UK has fallen behind.

On 27 March 2025, updated statutory guidance was issued for modern slavery statements under section 54 of the MSA. Key updates include:

• Due diligence – increased emphasis on the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct, more clearly signposting businesses to these frameworks to support work to tackle modern slavery

• Continuous improvement – highlighting the need for companies to show continuous improvement year-on-year, including by retaining old modern slavery statements online and introducing new goals and KPIs so that progress can be tracked

• Stakeholder engagement and collaboration – focusing on the importance of collaborative working to eradicate modern slavery internally and externally, particularly by taking a worker-focused approach

• Reputation – the updated guidance makes note of the reputational risk that non-compliant companies face, and highlights the benefits of increased transparency. For example, the guidance encourages the voluntary uploading of statements to the modern slavery statement registry

International legal requirements

The international regulatory landscape is also changing. For example, the EU Forced Labour Regulation (‘FLR’) was published in December 2024 and will come into full force in December 2027.

While an EU instrument, the FLR applies to all companies operating in the EU, and could lead to products being prohibited or seized if deemed to have been produced using forced labour. Companies placing non-compliant products on the market must be able to demonstrate that their due diligence processes mitigate the risk of and prevent forced labour in supply chains to avoid enforcement action.

Organisations should take steps to map out and assess their existing supply chains and conduct a gap analysis of existing processes and procedures to prepare. Keeping a record of any steps taken to guard against forced labour will help to ensure there is evidence that can be provided in the event of an investigation for non-compliance with the FLR.

If you would like to discuss any of the topics in this article and how your business could be affected, get in touch with our team at info@forge-esg.com. 

Jonathan Chibafa

Founder & Chief Legal Officer