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Government should remove s.54(4)(b) of the Modern Slavery Act 2015, which enables companies to comply...

Conclusion
Government should remove s.54(4)(b) of the Modern Slavery Act 2015, which enables companies to comply by reporting that no action has been taken. (Recommendation, Paragraph 61)
Government Response
Acknowledged
HM Government Acknowledged
The RBC review will consider the best way to promote a coordinated approach to responsible business that minimises costs to businesses, including SMEs. This will be consistent with the Prime Minister’s commitment to reduce the administrative cost of complying with regulation by 25% over the Parliament. Through the review process we will engage with SMEs to harness their insights and expertise. Alongside this, the new Small Business Plan is the most comprehensive package of support for small and medium sized businesses in a generation, designed to support the UK’s 5.5 million SMEs to achieve growth and reach their full potential. The plan contains a number of new measures which will make a real difference to the day-to-day trading operations of small businesses and give them the right support to grow. The measures include cutting the administrative costs of regulation for business by 25% to save businesses time and money so they can focus on running successful businesses; and the launch of our new Business Growth Service, a new national service making it easier and quicker for businesses across the UK to get the help, support and advice they need to start, scale and succeed. 6 Implementing mandatory Human Rights Due Diligence (mHRDD) JCHR Recommendation 9, 10 and 11 9. The Government’s newly announced Supply Chain Centre should support companies to conduct effective HRDD by providing a single point of access to verified information, guidance and resources. (Paragraph 100) 10. Government should establish effective regulatory arrangements to ensure compliance with the new rules for mHRDD, including penalties for non-compliance that are proportional to company turn over. (Paragraph 107) 11. This regulatory function could be led either by the Office for Responsible Business Conduct or the Supply Chain Centre. The chosen body must be effectively resourced to deliver these new duties. (Paragraph 108) Government Response Responsibility for government policy on forced labour in supply chains sits with the Office for Responsible Business Conduct (ORBC) rather than the Supply Chain Centre, which will focus on building the resilience of the UK’s critical IS8 supply chains. ORBC works closely with the Supply Chain Centre and other parts of government to ensure a joined-up approach. DBT will continue to use the resources at its disposal across government, as needed, to help support businesses to act responsibly. The RBC review will consider the effectiveness of the UK’s current regime and alternative means of supporting responsible business practices. Any policies developed following the review will consider a range of factors, including how to ensure company compliance and behaviour change. We will wait for the review to conclude before making any decisions on whether a regulatory function is required. 7 Import bans–current position in USA and EU JCHR Recommendation 12 12. The Government should introduce an import ban to prevent goods produced using forced labour from entering the UK market. This should establish: how the risk of forced labour in supply chains will be identified; who is responsible for identifying forced labour risks in supply chains and what is done with this information; who is responsible for preventing the import of goods likely to be exposed to forced labour and if necessary confiscating goods; and what resulting processes will follow once goods are confiscated. (Paragraph 126) Government Response We are actively reviewing the effectiveness of existing UK measures, including as part of the RBC review, and considering the implications of a variety of approaches to tackle forced labour in supply chains. We continue to engage with international partners to support our shared goal of combatting forced labour in supply chains. FCDO is leading the National Baseline Assessment to assess the current level of implementation of the three pillars of the UN Guiding Principles, by the UK government and UK businesses. 8 Import bans–state-imposed forced labour JCHR Recommendation 13 13. The import ban recommended above must clarify that no company which uses or allows state-imposed forced labour in its supply chains can import goods to the UK. (Paragraph 137) Government Response The Government remains firmly opposed to the use of state-imposed forced labour. We are considering how best to reflect this position within our broader frameworks for trade policy and responsible business conduct. It is important to consider the operational and legal complexities involved. We will continue to assess the most effective means of addressing this issue, including through existing due diligence and transparency mechanisms. 9 Implementing import bans JCHR Recommendation 14 14. In taking steps to enable Border Force officers to find illicit consignments, the Government should ensure they are enabled to search out consignments of goods linked to forced labour. (Paragraph 148) Government Response Tackling forced labour require
Addressee Bodies
Ministry of Justice
Timeline
Recommendation age 0.9 yr
Report published 24 Jul 2025