10th anniversary of the UK Modern Slavery Act: Withers contributes to parliament's enquiry into forced labour in UK supply chains

The UK Modern Slavery Act (the "Act"), which consolidates offences of modern slavery and forced labour and puts in place a corporate reporting regime, received Royal Assent on 26 March 2015. To mark this anniversary, the House of Commons debated a general motion on the Act on 27 March 2025 and on 28 March 2025, the House of Lords debated a motion regarding a report titled "The Modern Slavery Act 2015: Becoming world-leading again". 

These debates are taking place at a time when the UK Parliamentary Joint Committee on Human Rights is reviewing submissions received in response to its Call for Evidence on Forced Labour in UK Supply Chains (the 'Call'), which ended in February 2025. The Call is part of a broader review of the Act to examine the efficacy of the Act and to consider the modernisation of the Act. Last month, Withers made submissions in response to the Joint Committee's Call. With the submissions, our Sustainability team has sought to assist Parliament as the Joint Committee on Human Rights considers the UK's framework for forced labour in supply chains. This involved, examining the international legal obligations of States and the impacts on corporations, as well as looking at international best practices. As part of the evidence presented, we noted that the current UK legislation on forced labour offers more limited protections than some other jurisdictions, such as France and Germany. Some countries' legal frameworks for instance provide for the use of direct enforcement mechanisms for the breach of due diligence obligations (such as fines, restrictions on imports, and civil liability and/or criminal liability), which is not currently part of the UK framework. 

We also presented evidence on how the international legal (and soft law) landscape has evolved over the years since the introductions of the Act. Key examples of instruments and guidance addressing forced labour and modern slavery are: 

• Ethical Trading Initiative Base Code 2016 (and ETI Base Code Guidance on Modern Slavery 2017);
• OECD Due Diligence Guidance for Responsible Business Conduct 2018;
• Ten Principles of the UN Global Compact 2018;
• European Union Corporate Sustainability Reporting Directive 2022 (EU CSRD); and
• European Union Corporate Sustainability Due Diligence Directive 2024 (EU CSDDD).

As we see further expansion of legal and regulatory frameworks on sustainability, alongside potential political and corporate pushbacks, our Sustainability team continues to advise clients on these developments globally in order to navigate the evolving landscape. 

Our sustainability team can navigate this landscape and help deliver sustainable success  

We have a dedicated, multi-disciplinary team specialising in all aspects of sustainability work, supporting individuals and businesses to grow responsibly and navigate this increasingly complex area of law. Our team works with clients around the world to advise on regulatory, compliance and environmental and human rights risks across a wide range of sectors including banking and finance, energy, natural resources, renewables, construction, manufacturing, clothing, food and beverage, health, infrastructure, technology and asset management. 

We act as strategic advisors, counsel and advocates, and our work covers all aspect of sustainability, including: 

• advising on environmental, social impact, modern slavery and sustainability policies and procedures;
• advising on sustainability and supply chain due diligence, including reporting requirements under the EU Corporate Sustainability Reporting Directive (CSRD);
• advising funds and financial institutions on sustainable investment and reporting obligations;
• representing clients in environmental, social, and human rights litigation and arbitration;
• conducting internal investigations into allegations of misconduct;
• representing clients in law enforcement led investigations into allegations of misconduct;
• advising on transactions involving climate change, energy or environmental issues/clauses;
• advising on corporate governance issues related to environment and social matters; and
• advising on reputation management.