Are UK Supply Chains Failing on Human Rights?
Forced labour unfortunately remains embedded in global supply chains and the UK is failing to keep tainted goods out of its market.
In its report, the Joint Committee on Human Rights (JCHR) warns that products made using forced labour are being sold to UK consumers, undermining the Government’s own commitment that "no company operating in the UK should have any forced labour whatsoever in its supply chain."
The International Labour Organisation defines forced labour as “all work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.”
It is a form of modern slavery, along with forced marriage. The ILO estimates that 27.6 million people were trapped in forced labour as of 2021, with around two-thirds of these cases linked to global supply chains.
In its findings, the JCHR points to major flaws in the UK’s current legal and policy framework.
Although the UK has ratified international agreements on forced labour, these obligations only apply within UK jurisdiction.
Transparency laws not delivering
The UK’s primary legislation on forced labour is the Modern Slavery Act 2015.
Section 54, on Transparency in Supply Chains (TISC), requires large commercial organisations - those with a turnover of £36m or more - to publish a yearly statement outlining the steps taken to prevent slavery and human trafficking in their operations or supply chains.
However, the law also allows companies to state that no such steps have been taken.
In its report, the JCHR explains: “The shortfalls in the UK’s voluntary reporting regime have led to calls for reform.” It finds that “transparency has not worked” and that the Modern Slavery Act is “not fit for purpose because it focuses purely on reporting.”
This view is echoed in evidence from Katherine Bryant of Walk Free, who told the Committee: “So far we have seen that transparency has not worked.”
Even the original architect of the legislation, Theresa May, agrees. Baroness May of Maidenhead, who was Prime Minister when the Act was passed, writes: “When the Act was introduced, there were those who were concerned about the impact on business.
"It is now clear that in order to have an impact on modern slavery and human trafficking we need to go further.”
Poor quality reports, limited enforcement and the ability to comply by doing nothing all weaken the Act’s effectiveness.
International pressure
The JCHR highlights how international trading partners are taking stronger action.
The United States enacted the Uyghur Forced Labour Prevention Act in 2021, which blocks imports linked to China’s Xinjiang region unless businesses can prove they are free of forced labour.
The European Union is also moving ahead with forced labour regulations that impose due diligence obligations on companies and enable authorities to ban tainted imports.
In contrast, the UK lacks a functioning import ban mechanism. The report argues that this “outdated” framework puts the UK behind other countries and exposes its market to forced labour risks.
The Committee concludes: “Import bans for goods linked to forced labour can send a strong message that forced labour in supply chains will not be tolerated.”
The reality is that most British companies with international supply chains will have a risk of forced labour somewhere in their supply chains.
A call for stronger enforcement
The JCHR calls for new legislation within a year. This should make it unlawful to import or sell goods linked to forced labour and introduce mandatory human rights due diligence duties for businesses.
It also recommends a new legal route for survivors to bring civil claims against companies that fail to prevent forced labour in their supply chains.
The report notes that some survivors are already taking legal action under tort law, but these cases are “protracted, complex and expensive.”
A dedicated civil liability route would place the burden on companies to show they have taken proper steps to avoid using forced labour, and offer greater access to justice for victims.
The Committee further recommends clear regulatory arrangements to monitor company compliance and proper resourcing for enforcement. Without this, it warns, businesses will lack the clarity and confidence needed to change their practices.
The Government’s own 2025 Trade Strategy had promised to review how the UK promotes responsible business conduct.
Could the energy transition bring added risk?
The green energy sector could also pose particular forced labour risks due to its reliance on critical minerals and components such as polysilicon. These are often sourced from high-risk regions.
The report notes that the Procurement Act 2023 and the Great British Energy Act 2025 begin to address these concerns, but finds the Solar Roadmap "not sufficient to tackle the supply chain risks."
As a result, the Committee is urging targeted action to ensure the green transition does not deepen dependency on exploitative labour practices abroad.
