UK government to review its approach to Responsible Business Conduct

International framework

The Trade Strategy states that the government will support the creation of a “level playing field” for UK businesses by “championing international standards and frameworks on human rights, environment, and corruption”. 

It confirms that “[a]ll UK business should respect human rights and the environment” in line with the UN Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines) and the ILO Declaration on Multinational Enterprises. These authoritative frameworks all refer to the concept of undertaking human rights due diligence to identify, prevent, mitigate and account for how a company addresses its adverse impacts. 

The Trade Strategy similarly states that, “[t]o this end” all UK companies should carry out “risk-based human rights and environmental due diligence”. This notably follows the language contained in the EU Corporate Sustainability Due Diligence Directive (CSDDD), which was adopted in 2024 but is currently under review as part of the EU’s Omnibus Simplification Package (see our previous briefing on the Omnibus here). 

UK legislative landscape

The government also reiterates that companies are expected to comply with all relevant UK legislation in this area, and lists specifically the reporting requirements set out in section 54 of the UK Modern Slavery Act 2015 (MSA), as well as the UK Bribery Act 2010. It refers to the newly updated government guidance on Transparency in Supply Chains, aimed at supporting companies with their MSA reporting. 

However, insofar as the UK does not currently have legislation similar to CSDDD, the Trade Strategy recognises that “concerns continue to be raised regarding the effectiveness of the UK’s regime in preventing human rights, labour rights, and environmental harms in supply chains.” It states:

Within a fast-changing international landscape, we acknowledge reforms introduced by many of our trading partners.

This acknowledgement follows a 2024 House of Lords Select Committee report which found that the UK had “fallen behind” on international due diligence developments and recommended the adoption of a “UK due diligence law compatible with the standards of the international landscape to make compliance easier for companies”. (See our briefing on these recommendations here.)

Commitment to launch a review

Based on the above, the government commits to launch a review of its approach to ensuring responsible business conduct, in which it will focus on the global supply chains of businesses operating in the UK.

The review will draw on the insights of stakeholders such as businesses, investors, trade unions, academia, civil society and the UK’s trading partners, and will be aimed at a coordinated approach “that minimises costs”. 

As part of the review, the government has indicated that the UK National Contact Point (NCP) established under the OECD Guidelines will be “refresh[ed]” and renamed the Office for Responsible Business Conduct. It will still be seated within the Department of Business and Trade and will continue to provide a non-judicial grievance mechanism for complaints regarding alleged non-adherence by companies with the OECD Guidelines.

Joint Committee on Human Rights report

Shortly after the publication of the Trade Strategy in June 2025, a July 2025 report by the UK Joint Committee on Human Rights – which comprises of members of both the House of Commons and House of Lords – referred to the above government commitment to launch a review and noted that the UK Home Office had subsequently confirmed that this review will include “considering how to strengthen s.54 of the Modern Slavery Act, including ‘the reporting requirements, the turnover threshold, and penalties for non-compliance’”. 

The Committee stated that it had received a number of submissions which indicated that “there would not be a level playing field for businesses until there is mandatory human rights due diligence in the UK”. The Committee recommended the adoption of legislation “to introduce mandatory human rights due diligence requirements throughout supply chains for businesses trading in the UK”. 

However, noting that the EU’s Omnibus proposal was introduced twelve days after the Committee’s inquiry closed, the Committee highlighted:

In developing its own mandatory human rights due diligence, the UK should be mindful of the outcome of the CSDDD process in the EU, in order to ensure that businesses which operate in both the UK and EU are not placed under conflicting regulatory burdens.

Moreover, SMEs should be subject to lighter mandatory due diligence requirements than larger companies, to avoid excessive burdens, and should be supported through guidance, tools and resources. 

The Committee’s report also recommended that a law which bans products linked to forced labour from being imported or sold in the UK should be introduced “within one year” of the report’s publication (i.e. by July 2026). The EU’s equivalent of such a forced labour import ban was introduced in 2024 and will become effective on 14 December 2027. (See our briefing on EU developments here.) 

Next steps

To the extent the government’s review results in a proposal for legislative reform, the next step is likely to be a public consultation on the types of measure(s) the government should introduce to encourage or require RBC due diligence by companies. This may include mandatory due diligence requirements and / or import bans as proposed by the Joint Committee on Human Rights. We will continue to monitor developments.