The UK must strengthen its response to forced labour in supply chains
The UK imports US$26 billion in at-risk goods annually, highlighting the need for stronger forced labour import bans, due diligence laws, and ethical procurement to combat modern slavery in supply chains.
The UK government must prioritise human rights alongside its green energy goals by addressing forced labour risks in its supply chains.
This will ensure that the transition to clean energy is both sustainable and ethical. The green energy transition must not come at the cost of human rights.
To lead by example, the UK must keep its clean energy supply chains free from forced labour.
Strengthening procurement, trade measures, and regulation is essential to preventing exploitation and upholding ethical labour standards.
Forced labour risks in green energy supply chains
Forced labour is deeply embedded in global supply chains, particularly in the production of critical minerals.
This includes cobalt, lithium, and rare earth elements – key components of solar panels, wind turbines, and electric vehicle batteries.
Many of these materials come from high-risk regions such as the Democratic Republic of the Congo (DRC) and China, where forced and child labour are widespread.
- Cobalt mining in the DRC: Over 70 per cent of the world’s cobalt supply comes from the DRC, where artisanal mines are known for hazardous conditions and forced labour practices.
- Solar panel production in China: China dominates the global polysilicon market, producing up to 90 per cent of the world’s supply. Reports of state-imposed forced labour among Uyghur and Turkic Muslim populations in Xinjiang, a region responsible for a significant proportion of China’s polysilicon, raise serious concerns about ethical sourcing.
Despite growing awareness, companies and governments have not done enough to mitigate these risks.
Without stronger enforcement, the UK risks undermining both its climate goals and its commitment to human rights.
Current UK regulations are inadequate
The UK Modern Slavery Act (MSA) requires companies to report on forced labour risks.
However, it lacks enforcement mechanisms, leaving loopholes for non-compliant businesses.
Unlike the United States’ Uyghur Forced Labor Prevention Act (UFLPA) or the European Union’s proposed Corporate Sustainability Due Diligence Directive (CSDDD), the UK has not introduced mandatory due diligence legislation or import bans targeting forced labour.
Walk Free’s research reveals significant gaps in addressing forced labour risks, including:
• Less than 5 per cent of UK and Australian electronics and renewables companies assessed disclosed policies restricting sourcing from regions with state-imposed forced labour.
• Only 7 per cent of UK and Australian renewable energy companies assessed have due diligence policies for sourcing minerals from conflict-affected areas.
• The UK imports US$26 billion worth of goods at risk of forced labour annually, including solar panels valued at US$14.8 billion, according to our latest Global Slavery Index.
Why a forced labour import ban is necessary
The UK must align its trade policies with global best practices by introducing an import ban on goods produced with forced labour.
The UFLPA has already prompted supply chain restructuring in the US, encouraging businesses to source more ethically. A similar approach in the UK would:
• Prevent companies from shifting operations to less-regulated markets, deterring jurisdiction shopping.
• Encourage businesses to strengthen due diligence, increasing corporate accountability.
• Ensure fair competition for companies committed to responsible sourcing, and protecting ethical suppliers.
Key recommendations to strengthen UK policy and combat forced labour in supply chains
To effectively combat forced labour, the UK must take decisive action. Key recommendations include:
- Introduce mandatory human rights due diligence (MHRDD) – Require all businesses to conduct meaningful due diligence on forced labour risks.
- Trade-based solutions – Introduce import bans on forced labour goods, aligning with the US and EU.
- Strengthen public procurement standards – Ensure UK government contracts exclude suppliers linked to forced labour and ensure the Procurement Act has meaningful enforcement.
- Expand corporate liability – Introduce penalties for non-compliance with modern slavery reporting requirements.
- Establish a UK forced labour task force – A cross-government body should oversee trade enforcement and supply chains.
- Implement a smart mix of measures – A combination of regulation, trade enforcement, incentives, and collaboration with businesses and workers is necessary to create lasting change.
- Involve workers and labour rights groups in green energy decisions – Include worker representatives and labour rights organisations in policy consultations and decision-making processes for green energy projects.
Ensuring ethical supply chains in the UK’s green energy sector
A just transition to clean energy must prioritise both environmental sustainability and human rights.
Strengthening legislation, enhancing corporate accountability, and enforcing trade measures will position the UK as a global leader in ethical business practices.
Without urgent reforms, the UK risks becoming a destination for goods produced through forced labour, undermining its commitment to addressing modern slavery and protecting human rights.
