How the UK is Tackling Forced Labour in Energy Supply Chains
The UK Government is establishing a more defined strategy for addressing forced labour within energy supply chains.
A cross-government review of Responsible Business Conduct (RBC) and updates to public procurement regulations will set these changes in motion.
While no new legislation has been immediately enacted, the direction of policy is apparent with a greater focus on due diligence, more assertive use of procurement mechanisms and enhanced alignment with international trading partners.
Sir Chris Bryant MP, Minister of State for Trade, says: “Forced labour is an egregious and severe violation of human rights.
“The abhorrent practice of forced labour has no place in UK supply chains and the global economy.”
The UK's new Procurement Act
Under the new Procurement Act, a central debarment list has been activated for suppliers found to be connected with modern slavery.
Contracting authorities are now operating under a more stringent exclusion regime and are required to report relevant cases to the Procurement Review Unit.
In the energy sector, Great British Energy (GBE) has been tasked to lead as a pathfinder for developing ethical supply chains.
GBE is mandated to publish its own modern slavery statement and is empowered to terminate contracts where connections to forced labour are discovered.
GBE is set to report on its progress in its first annual report by July 2026 establishing an early standard for governance and transparency in the sector.
Responsible business conduct review
The RBC review is assessing a range of options that include the possibility of mandatory human rights and environmental due diligence.
It is also considering potential import controls and the enforcement frameworks necessary to ensure any new rules are effective.
Ministers are expected to make decisions on penalties and regulatory oversight once the review is complete.
A newly established Office for Responsible Business Conduct (ORBC) is leading the government's efforts on supply chain harms and will be instrumental in defining practical compliance monitoring.
The government is also exploring the possibility of stronger reporting rules that might include extending obligations to public sector bodies and implementing penalties for non-compliance.
The current reporting threshold referenced is about US$46m annual turnover.
Trade policy and sector-specific measures
Trade policy will see the continued inclusion of forced-labour provisions in Free Trade Agreements (FTAs) with mechanisms for recourse through implementation forums and dispute resolution processes where necessary.
The UK has already engaged in labour discussions with 14 FTA partners including specific exchanges on forced labour suggesting a move towards a more stringent international standard.
The clean energy sector has been identified as a priority area for these new measures.
The Department for Energy Security and Net Zero (DESNZ) plans to embed ethical supply chain principles into its growth strategies.
While the government has acknowledged the Solar Stewardship Initiative, it has stated that procurement will not depend solely on this initiative.
Standards will be subject to review and further action will be taken if any gaps are identified.
Additionally, a refreshed critical minerals strategy is anticipated in 2025 which aims to promote responsible and transparent sourcing for these vital materials.
