2025 marks the 10th anniversary of the UK’s Modern Slavery Act, which was pivotal in bringing modern slavery to the global and corporate agenda and laid important foundations for tackling the issue. However, the evolving and complex nature of modern slavery, combined with legal and policy reforms introduced in other jurisdictions, mean that the Act is now outdated and in need of reform.
In this blog, Impactt’s Consultant Briar Hulme draws on discussions during the Modern Slavery and Human Rights Policy and Evidence Centre (PEC) conference marking a decade of the Act, and Impactt’s experience working address forced labour and modern slavery, to explore what businesses need to know about the potential evolution of the Act, and the fight against modern slavery, in the years ahead.
Focus areas for strengthening the UK’s response to modern slavery
Supply Chain Transparency: Time for a Stronger Framework
The Transparency in Supply Chains (TISC) provisions in the UK Modern Slavery Act (Section 54) have fallen short of meaningfully addressing exploitation; the Act lacks sufficient enforcement mechanisms, and with no mandatory reporting content requirements, companies can still comply by stating they have taken no action at all. During the last decade, other regions have made progress on enforcement, through HRDD laws, mandatory reporting requirements and forced labour import bans, all of which were discussed during the conference as part of the potential solution for the UK to enable supply chain transparency.
As global scrutiny increases, the need for proactive due diligence and improved reporting is becoming more urgent and at Impactt, we are already supporting businesses to navigate these emerging expectations. Our experience supporting Top Glove to remediate forced labour in their operations, following a WRO from the US CBP, demonstrates how comprehensive programmes in response to such bans can result in profound improvements for workers and business alike.
Ethical Lived Experience: Amplifying Worker Voice
This is at the heart of the Impactt approach, and essential to developing impactful modern slavery policies at a national, as well as individual business level. As speakers at the conference identified, there is a need for a more nuanced approach to addressing the issue – one that values and centres the crucial expertise and experience of survivors and those working to support them. This inclusion must be done respectfully, ethically, and without tokenism. For instance, survivors should always be compensated for their time and should be informed of any actions and outcomes taken as a result of their involvement.
By employing interviewers who are trained in social psychology approaches, and spending 25% more time with workers than our peers, we embed worker voice throughout our diagnostic programmes. This enables us to generate rich, honest data, and surface hidden risks. The solutions proposed then reflect workers’ real experiences and enable us to deliver strategic interventions which communicate our boots-on-the-ground knowledge effectively at management, board, and C-suite levels, driving sustainable change that addresses worker needs in a meaningful way.
Survivors aren’t stories walking on legs. They need to be embedded at every level of work against modern slavery – Jane Lasonder (Lived Experience Expert)
Partnership and Collaboration
The constantly evolving nature of forced labour and modern slavery make effective partnership and collaboration particularly essential. Collaboration must go beyond simply exchanging best practices; it also demands transparent and vulnerable engagement, including a willingness to share what isn’t working and the challenges that persist. Without this openness, we risk missing key insights and failing to address critical blind spots, leaving the most vulnerable exposed to exploitation.
At Impactt, we continuously work at a collaborative, strategic level to bring together key industry players in the fight against modern slavery and forced labour. Recently, we contributed to key Parliamentary debates via the Commonwealth Parliamentary Association, featuring in the ‘Legislating Against Modern Slavery in Supply Chains’ handbook and sharing practical recommendations around uncovering subtle indicators of exploitation.
Looking ahead, we are developing a global recruitment risk map, an innovative multi-stakeholder initiative which will collate and analyse previously inaccessible data, to draw insights into global recruitment risks.
Prevention: Shifting the Focus Upstream
The next decade of the Modern Slavery Act must focus on prevention. Efforts must go beyond addressing exploitation in destination countries, such as through import bans, and also tackle the root causes of exploitation in source countries. Conference panellists called for knowledge hubs which would enable organisations to utilise data and identify risk patterns, deploying targeted action where it matters most.
Impactt’s diagnostic assessments identify and address the root causes of forced labour, highlighting where procurement practices could be altered to connect the bottom line with what is happening in the supply chain. Preventative solutions include integrating human rights considerations into supplier selection (rather than cost alone) whilst also providing capacity building for suppliers to meet these expectations.
Summary: Impactt’s view on the next decade of the Modern Slavery Act
With a changed landscape surrounding human rights in the UK and worldwide, several clear priorities emerged at the conference, which Impactt endorses:
- Closer alignment with international legal and policy developments, including the EU’s Corporate Sustainability Due Diligence Directive (CSDDD), the Corporate Sustainability Reporting Directive (CSRD), and Australia’s Modern Slavery Act.
- A shift toward prevention, recognising the need to move beyond the largely reactive approach embedded in the current UK legislation.
- The need for stronger enforcement mechanisms and potential introduction of corporate criminal liability, addressing the current lack of accountability and “teeth” within the existing framework.
- Ethical and meaningful survivor involvement as a fundamental principle for future policy and practice.
- Enhanced partnership and cross-sector collaboration as vital for driving meaningful change, highlighting the need for coordinated, co-designed approaches across government, business, and civil society.
Impactt: Your Trusted Partner Through Uncertain Times
As the landscape of modern slavery prevention continues to evolve, companies are facing increasing pressure and scrutiny. As these demands grow, Impactt is here to provide support, helping businesses navigate the shifting requirements and expectations.
