Ten years on, the UK must step up on modern slavery & supply chain abuses

On 18 October, the EU observes Anti-Trafficking Day, coinciding with the UK’s Anti-Slavery Day.  This year also marks a decade since the UK’s Modern Slavery Act came into force. As the European Parliament considers new corporate sustainability due diligence legislation and how to implement its forced labour ban, and the UK considers how to strengthen its own approach, it’s a moment to reflect: what has worked, and what still needs to change?

Necessary and insufficient

The UK’s Modern Slavery Act was ground-breaking when introduced.  At the time, it felt both bold and overdue.  Building on similar supply chain transparency legislation introduced in California, it included a clause requiring medium and large companies to report transparently on their activities to address modern slavery in their supply chains. This built unprecedented awareness that modern slavery can be deeply embedded in global supply chains and led some companies to develop their approaches significantly.

But the Act was minimal in its actual requirements. All companies in scope actually had to do was produce an annual statement on what they were doing; even companies doing nothing could comply simply by saying so. And, critically, there was no enforcement of these obligations. By 2019, it was estimated that 40% of companies in scope weren’t producing any statement at all, and there were no consequences. The absence of enforcement didn’t just weaken compliance; it signalled that transparency alone isn’t enough.

Since 2015, other countries have overtaken the UK’s relative leadership, developing more demanding requirements for transparency and progress. The US has introduced a Forced Labour ban requiring importers to prove that, where their products come from areas such as Xinjiang province in China, they have not been produced with forced labour. In the 9 months to June 2025, 6,947 shipments were stopped by US authorities for forced labour enforcement actions. The EU has decided to implement something similar by 2027 and is also introducing a broader-ranging Corporate Sustainability Due Diligence Directive (though it’s still working through the details). 

Is the US Forced Labour ban already making the UK a hotbed for slavery-tainted products?

Meanwhile, France has introduced its Duty of Vigilance Law; Germany its Supply Chain Due Diligence Act, Norway it’s Transparency Act… This growing international momentum risks leaving the UK behind. Not only disappointing consumers who expect ethical products but also risking the UK becoming a dumping-ground for products barred elsewhere. This isn’t idle rhetoric, by the way: reporting from the i Paper suggests that imports of goods into the UK from Xinjiang have surged to more than £800m worth over the last year. Is the US Forced Labour ban already making the UK a hotbed for slavery-tainted products?

The cost of inaction

The UK Modern Slavery Act was important at the time. But its limitations have been severely exposed over the last 10 years. Voluntary measures have not prevented serious abuses in global supply chains and new severe threats have emerged. 

In China, evidence has now emerged of labour transfer schemes moving Uyghur workers from Xinjiang province into various production sectors around the country, against their will – showing that forced labour risks extend well beyond that region. In many countries in south-east Asia, migrant workers face unsafe conditions and debt bondage arising from fees paid to get their jobs that risks locking them into exploitation.  In the southern Mediterranean, migrant workers from Africa too often labour in extremely poor conditions picking the fruit and veg we eat.  In the UK, post Brexit, most migrant farm workers now come from Central Asian countries on temporary visas; having paid significant deposits to secure their jobs, they can be left in precarious situations when work falls through, or conditions are poor, unable to recoup their outgoings.

These are systemic problems, not isolated cases.

Overall, it’s estimated that 50 million people around the world are in modern slavery; 28 million of these in forced labour; and two-thirds of these in turn in supply chains.  These are systemic problems, not isolated cases. Voluntary measures are not enough to support those at risk - and they are also not fair on the relatively small number of responsible companies, including ETI members, who seek to take genuine action to address modern slavery and other human rights risks in their supply chains.

A strategic moment for the UK                               

Less than 12 months after the Modern Slavery Act was introduced, the UK voted for Brexit. It has taken several years to implement that decision and navigate new arrangements with former EU partners. Only now is the wider post-Brexit trade environment coming into focus.

What companies want is consistent requirements across key markets, minimising the inefficiencies and costs of responding to different regimes.

It’s a big opportunity to reflect on what kind of future supply chains the UK wants – how it can reward businesses doing the right thing, build resilience in its supply networks, and take a proactive approach to both human rights and environmental risks. This, in turn, can lessen the burden on Government and taxpayers caused over time when companies fail to consider their impacts – whether that’s needing to support exploited workers through housing and rehabilitation, cleaning up polluted waterways, or having to build flood defences against rising seas.

For larger companies that trade beyond UK borders there is another powerful factor often referred to as ‘regulatory divergence’. What companies want is consistent requirements across key markets, minimising the inefficiencies and costs of responding to different regimes. By following the example of other countries and rooting due diligence requirements in the same ‘source code’ of the UN Guiding Principles on Business and Human Rights, the UK can both minimise regulatory divergence and help newly exporting UK businesses to be ‘oven-ready’ for the requirements they will face in key export markets.

All this adds up to a clear opportunity for the UK to lead again.  By introducing mandatory Human Rights and Environmental Due Diligence (mHREDD) legislation, it can rebuild global leadership, level the playing-field for responsible companies, prepare UK businesses for forthcoming EU requirements, and help ensure that UK consumers don’t have the stain of slavery on their products. Most importantly, it can help millions of people around the world move out of exploitation.

ETI’s position on mHREDD

We’re proud of this position. It challenges the notion that businesses, in particular, are always anti-regulation in this area. In fact, for most of our members it feels a bit of a no-brainer

This summer ETI consulted its members to establish a common position on what effective legislation should look like.  Across our business, trade union and NGO members, the outcome was straightforward: clear support for mandatory due diligence for businesses, with ten clear principles our members recommend legislators follow in all markets, with more detailed guidance provided for each.

We’re proud of this position. It challenges the notion that businesses, in particular, are always anti-regulation in this area. In fact, for most of our members it feels a bit of a no-brainer: through our Member Charter, they are already committed to conducting meaningful due diligence. So why wouldn’t you want other companies to follow suit? It means more shoulders to the wheel in addressing complex challenges, and a level playing-field on which it becomes harder for competitors to cheat on their responsibilities.

Some critics argue that it’s unsurprising that ETI member businesses support mHREDD, given that many operate in the retail and consumer-facing sectors, where protecting brand reputation is a key concern – pressures not faced by businesses in other industries. But this interpretation misses the point. It is precisely these businesses, those most attuned to consumer expectations, that have historically led the way on ethical practices. Notably, support for mHREDD isn’t limited to ETI’s tripartite membership. The British Retail Consortium, a business-only organisation, has also endorsed the legislation. This reinforces the idea that responsible business is not just a niche concern, but a mainstream expectation.  Rather than dismissing this support, we should recognise it as a signal of what society demands from all sectors. Mandatory due diligence is not only the right thing to do, it’s a shared standard that levels the playing field and strengthens trust in business. 

ETI’s global perspective 

Due diligence has been at the core of ETI’s approach since we were founded in 1998.  More recently, we led research with a consortium of civil society organisations to understand the potential impacts of mHREDD on suppliers and workers in key production countries: Bangladesh, Cambodia, India, Indonesia. 

[T]his can be an opportunity to improve existing due diligence efforts...

This research has followed ETI’s longstanding approach: engaging local NGOs, trade unions and suppliers to ensure workers’ voices are central to identifying risks, shaping effective solutions and informing responsible business practices. Key takeaways have included the importance of building early awareness among both buyers and suppliers of the enhanced obligations they will need to address, and how this can be an opportunity to improve existing due diligence efforts; too often limited to audits (which have low ability to identify more serious abuses) and weak grievance mechanisms (which are little trusted or even known about by workers).

This research also revealed strong interest in training and guidance on mHREDD. As part of this work, we have produced helpful comparative tables of EU vs local laws, case studies of what is effective, practical recommendations on risk assessment, remediation, and grievance mechanisms due to be published in the coming months.

The future

Today is a moment to reflect on our progress. And the prospect of new legislation is a moment not only to ensure more businesses become responsible, but also to ensure this work becomes more effective and meaningful.  Like the EU, the UK has the experience, networks, institutional knowledge to develop a credible mHREDD law. ETI is ready to support that process, drawing on our global experience and and collaborative approach with business, government, and civil society.