It is time the law changed to prevent forced labour in UK supply chains 

There are a number of frameworks underpinning the UK’s response to forced labour in supply chains and with high-profile forced labour cases against UK companies currently ongoing, they are rightly being called into question.

As an expert witness called to give evidence to the Joint Committee on Human Rights (JCHR) on 5 March 2025, my primary recommendation to the Committee was unequivocal: the UK’s reliance on outdated and ineffective legislation entrenches forced labour issues, and new legislation is needed to provide redress for victims.

My view is grounded in extensive experience of representing some of the most vulnerable victims of forced labour who often have very little access to justice. From my experience, the UK’s existing legal framework has systemic shortcomings that interweave forced labour practices in the UK market.  

The issue of forced labour and human rights abuses in supply chains raises significant legal questions about corporate accountability. It is a question that we at Leigh Day have grappled with and sought to develop through many years of hard-fought cases to establish parent company liability.

Typically, cases of this nature involve UK-based companies sourcing or manufacturing products through third-party suppliers abroad. The claims we have brought on behalf of victims set out to establish a company’s liability which can often be evidenced by corporate policies, auditing practices, or public statements.

At the time the Modern Slavery Act 2015 (MSA) was enacted it represented a pivotal step in addressing forced labour within UK supply chains by mandating transparency and requiring large multinational corporations (MNCs) to produce annual modern slavery statements. 

The MSA was world leading legislation and the first of its kind. However, the UK has now fallen far behind neighbouring countries who have brought in more effective legislation. The MSA is now outdated and several key limitations undermine the MSA’s effectiveness in tackling forced labour.  

Section 54(4) of the MSA mandates companies to publish statements each financial year to state what steps, if any, have been taken to ensure that slavery and human trafficking are not taking place in any of its supply chain, or in any part of its business. The statements that are made by a large majority of MNCs often reflect vague, boilerplate statements that do little to improve supply chain transparency and even less to ensure accountability for failures in addressing forced labour.

Besides being limited in scope and lacking in enforcement power domestically, the MSA has also fallen behind stricter human rights due diligence laws that have been enacted in the EU, its member states and jurisdictions further afield. Legislative developments such as the EU Corporate Sustainability Due Diligence Directive, the EU Forced Labour Regulation, the French Duty of Vigilance Law and the German Supply Chain Act, represent higher standards for corporate accountability, requiring businesses to proactively identify, prevent, and be accountable for human rights abuses throughout their supply chains.

One of the starkest failings of the MSA or any other legislative framework in the UK is the failure to provide meaningful legal avenues for legal redress by victims of modern slavery or forced labour. 

I was able to highlight this to the JCHR and recommended to them that: 

• There is an urgent need for mandatory human rights due diligence legislation that imposes a statutory duty of care and duty to prevent harm on businesses, including parent companies, to hold them accountable for forced labour in their supply chains.  The failure to prevent mechanism must create civil liability which should at a minimum provide for a right to civil action by those affected for compensation for damages suffered as a result of the failure to prevent human rights harms. 
• The UK should shift the burden of proof away from potential victims of forced labour and on to businesses, requiring them to prove they were not responsible if faced with allegations of labour abuses in their supply chains. A shifting of the burden of proof has been shown to be effective in companies addressing bribery issues since the introduction of the Bribery Act 2010 and any new legislation could be modelled on this. 
• There should be mandatory, more detailed, and enforceable modern slavery statements, shifting from voluntary disclosures to meaningful transparency and corporate accountability. 
• There should be legally binding, independent, and unannounced auditing requirements to prevent ineffective or deceptive audits in supply chains.