Hope for Justice and Slave-Free Alliance have submitted joint responses to two UK consultations on how to respond to modern slavery in supply chains.
Together, we have made several recommendations to the Department of Health as part of their consultation over proposed regulations to tackle modern slavery in NHS procurement.
Separately, we have also responded to an inquiry by the Joint Committee on Human Rights into forced labour in UK supply chains.
Slave-Free Alliance is Hope for Justice’s wholly owned international business membership social enterprise that helps protect supply chains against modern slavery. SFA and Hope for Justice regularly exchange know-how and resources, benefiting the people and organisations we serve. For these submissions, we draw on our joint expertise and collaborate to make recommendations, for instance on mandatory human rights due diligence and the importance of cross-government working on these issues.
Department of Health consultation – tackling modern slavery in NHS procurement
Hope for Justice and Slave-Free Alliance have responded to the Department of Health’s recent consultation on new regulations to tackle modern slavery in NHS procurement.
The proposed new measures would legally require public bodies procuring goods and services for the NHS to identify and mitigate risks of modern slavery. Public bodies would also be required to work with suppliers to identify risks and find solutions.
Euan Fraser, Hope for Justice’s Senior Policy and Research Advisor, said: “Hope for Justice and Slave-Free Alliance welcome the steps taken by the Department for Health. Whilst the Home Office leads the UK Government’s response to modern slavery, it is vital that each Government department play their part in mitigating risks of exploitation. It is also important that these measures taken by the Department of Health are accompanied by robust legislative changes to reduce exploitation in public and private sector supply chains. We recommend introducing mandatory human rights due diligence legislation to keep the UK aligned with requirements in the EU.”
Hope for Justice has previously delivered in-person and virtual training for NHS staff across the UK, including training for NHS Foundation Trusts, Primary Care Networks and safeguarding teams. We have also provided training for Health and Social Care Trusts and medical students in Northern Ireland. NHS workers have also taken our e-learning courses, including our Keeping Kids Safe in the Digital World and our modern slavery awareness course.
In response to the NHS procurement regulations and guidance aimed at addressing modern slavery risks, NHS suppliers are required to adopt comprehensive measures to mitigate or eliminate risks.
Slave-Free Alliance has a track record of supporting organisations of all sizes and from many sectors to build their resilience to modern slavery and labour exploitation. Within our joint response, SFA outlines the services it can offer to support suppliers to meet these expectations, such as creating or improving their modern slavery statements.
Quetzalli Cruz Sosa, Advisor – Human Rights in Supply Chains, for Slave-Free Alliance, said: “As the largest public procurer in the UK, the NHS has a responsibility to prevent and mitigate modern slavery risks in supply chains. Ultimately, we want to see all NHS supply chains and business activities free from exploitation by adopting regulations that align with this purpose and fostering collaboration with organisations such as SFA.”
Two of our recommendations were:
- Clarifying how exceptions to the minimum requirements outlined in the guidance align with regulations to ensure they do not inadvertently weaken compliance.
- Offering ongoing support to suppliers in implementing the regulations and guidance, recognising that businesses will have different levels of understanding and capacity to identify and mitigate modern slavery risks.
Joint Committee on Human Rights – forced labour in UK supply chains
Hope for Justice and Slave-Free Alliance have also responded to the UK Parliament’s Joint Committee on Human Rights’ inquiry into forced labour in UK supply chains.
The inquiry aims to examine the legal and voluntary frameworks underpinning the UK’s response to forced labour in international supply chains. It also explores whether improvements should be made to the UK’s response to this type of exploitation.
Responding to both inquiries
Within our submissions for both the NHS procurement consultation and the Joint Committee’s inquiry, we highlight the importance of strengthening the Modern Slavery Act 2015.
We state that Section 54 of the Modern Slavery Act 2015 was a positive first step and has encouraged some businesses to improve responses. However, section 54 of the MSA “lacks teeth” as there is no requirement on companies to take action to reduce the risks of exploitation in their supply chains. Instead, companies can merely report on action they have taken, even if that means reporting inaction. To our knowledge, the enforcement measures relating to that section of the act have never yet been used.
A recent Report, ‘The Modern Slavery Act 2015: becoming world-leading again’, noted the need to strengthen the section 54 provisions with a series of recommendations. The Modern Slavery Act whilst groundbreaking at the time is now behind other jurisdictions including the EU Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Forced Labour Products Regulation prohibiting products on the Union market made using forced labour. The UK needs to align itself with these global standards: consistent standards are less confusing and make it easier for businesses to comply.
