The Bishop of Bristol took part in a debate on a report from the Modern Slavery Act 2015 Committee on 28th March 2025, advocating for improvements to corporate accountability in supply chains:
The Lord Bishop of Bristol: My Lords, I, too, speak as a member of the review committee on the Modern Slavery Act in this 10th anniversary week. It was world-leading legislation, as we have heard. I also rise in the week that the Church commemorates Harriet Monsell, founder of the Anglican Community of St John Baptist, Clewer, a community which, from its 19th century inception, had as a core vocation the care of female victims of human trafficking. That community has for several years funded training of community groups across the United Kingdom to notice the trafficked people—women, men and children—hiding in plain sight in their midst and to act on their behalf. Clewer has also produced apps, notably for car washes and nail bars, giving assurance on their labour practices and suppliers. In today’s debate, that is where I would like to focus my remarks.
I draw attention to Section 54 of the Modern Slavery Act, which imposes a duty on companies supplying goods or services that have a turnover of at least £36 million to
“prepare a slavery and human trafficking statement”
every financial year. The statement should set out the steps that the business is taking to address and prevent the rise of modern slavery in its operations and supply chains. I know that some take that commitment very seriously.
I was happy to meet with one such company recently, Primark, which undertakes thorough and regular independent audits of its factories, employing experts who speak the local language and, in turn, talk to the local workforce so that they know what is going on on the ground. Once they find that the situation has materially changed, they pull out of the market. For example, in 2019, Primark found that it could no longer conduct effective human rights due diligence in Xinjiang province in China, so it prohibited all suppliers from using and sourcing products, materials, components or labour originating from the region. Primark has taken equally decisive action when UK suppliers have been found to be non-compliant.
Our report included recommendations on strengthening statutory guidance in Section 54 and the introduction of sanctions for non-compliance, as the noble Baroness, Lady O’Grady, indicated. I look forward to hearing more from the Minister on progress in this area.
The issue of modern slavery and exploitation in supply chains raises questions about corporate accountability. Although consumer businesses are exposed to a greater level of transparency and accountability, their lesser-known competitors can get away with publishing weak statements or not publishing at all, in the knowledge that any penalties are unlikely to be forthcoming. I know that many businesses, including the British Retail Consortium, John Lewis, Tesco and others, are asking for further regulation so that companies that operate supply chains free from forced labour are not left at a financial disadvantage.
A change in the law would chime with the public, as polling shows that four in five people want a new law to prevent exploitative practices. The law must in future hold UK companies accountable by establishing a central registry of statements similar to the gender pay gap register, and enforce the Modern Slavery Act by imposing financial penalties where companies fail to publish a statement and provide swift access to justice for victims.
Public sector organisations are also vulnerable to modern slavery risks in their supply chains and they lack the resources and legal power to address potential labour exploitation threats. Currently, public sector organisations, as we know, are driven by the need to drive down costs and find savings wherever they can, but it is vital that individuals are not endangered through their association with such risks. The Government’s modern slavery assessment tool indicates that 21% of suppliers were identified as high-risk, and that surgical instruments, gloves, gowns, uniforms and masks—PPE—were identified as the five highest-risk products. A possible reform to procurement processes could be the introduction of clauses into public tender legislation, mandating explicit disclosures about modern slavery risks. These clauses would require suppliers to demonstrate due diligence and reaffirm their commitment to preventing modern slavery.
The Modern Slavery Act was truly ground-breaking when it was introduced, but it must keep pace with changes to business practices by recognising the increasing complexities of supply chains. There are exemplary practices, as I have indicated, but these need regulatory support and a corporate environment where best practice is actively encouraged. Incentivising businesses would create a competitive and regulatory environment where companies would race to the top rather than to the bottom. The law as it stands discourages businesses from doing anything but the bare minimum and leaves the UK’s record on human trafficking, once so powerfully pioneering, now profoundly blemished.
Extracts from the speeches that followed:
Lord Bates (Con): My Lords, it is a privilege to follow the right reverend Prelate the Bishop of Bristol. The Church has been an essential voice in the campaign to end modern slavery, and many of us will remember the significant role played by the former Bishop of Derby, Alastair Redfern, during the legislation’s passage through this House. I begin by joining with others in paying tribute to the noble Baroness, Lady O’Grady, all the members of her committee and the clerks and advisers for an excellent and timely report.
As the Minister who had the privilege of steering this legislation through your Lordships’ House, I felt a shared pride with many others when it eventually arrived on the statute book. I say shared, because it was a cross-party measure brought in by a coalition Government—you cannot get more shared than that. That was, and remains, its strength. It could not have happened, however, and as the noble Baroness, Lady O’Grady, has generously said, without the determination and reforming zeal of my noble friend Lady May of Maidenhead as Home Secretary, nor without Frank Field—Lord Field—who first challenged us to “call a spade a spade” and refer to human trafficking as modern slavery. He chaired both the pre and post-legislative scrutiny, ably supported by the noble and learned Baroness, Lady Butler-Sloss, and my noble friend Lord Randall. We should also acknowledge the role played by many civil society organisations, such as the Centre for Social Justice and Justice and Care, and the dedicated civil servants who translated the poetry of our hopes into the careful prose of legislation.
Lord Watson of Invergowrie (Lab): I welcome that the Home Office is currently working with business, academia and civil society to update the Section 54 statutory guidance in this space. That will improve the quality of the statements, but they remain voluntary, and the committee believes that this is not enough. I accept that it is difficult to set up ethical supply chains, but more and more companies now understand the issues and what needs to be done.
Like the right reverend Prelate the Bishop of Bristol, I met Primark—not with the right reverend Prelate—and I found that it was an excellent example of what can be achieved with the right approach. That company has been taking action on supply chains for 20 years and now has 130 people in its ethics and sustainability team. It pays for all its own audits, which ensures that they are independent. Those audits are carried out before appointing a supplier, not after, although of course they update constantly. Primark’s emphasis on using local partners to build its capacity in the country of origin with the aim of leaving a legacy to ensure that standards are maintained is a model that many more companies could and should follow, but I come back to the point that without some form of sanction, there is no reason to believe that those who do not currently do so will change.
Lord McInnes of Kilwinning (Con): The Act can work to protect people only when the threat of repercussions is effective. Criminals will be deterred only if they are made to feel that they are at a genuine risk of being prosecuted and punished for the actions they are perpetrating. It is incumbent upon the Government to make clear their next steps in making these legal threats credible. I therefore ask the Minister—I welcome him to the Front Bench for the first time—what his Government intend to do to support law enforcement bodies in their work to bring perpetrators of modern slavery to justice. What do they intend to do to recognise the confused landscape that my noble friend Lord Kempsell referred to for victims in coming forward and seeing justice done? How will the Government send a clear message that a credible threat exists to those who choose to profit from this practice?
Another point raised by the committee’s report was around Section 54 of the Modern Slavery Act, which imposes a duty on UK-based businesses to make clear the action they have taken to ensure that their own businesses and, often even more importantly, their supply chains are free of modern slavery. This point was adequately raised today by the noble Lord, Lord Watson, and the right reverend Prelate the Bishop of Bristol. Unfortunately, not all companies are Primark and, therefore, vigilance needs to continue as we go through. This cannot be a mere box-ticking exercise.
Lord Moraes (Lab, Government Whip): My noble friend Lord Whitty, the noble Lord, Lord Randall, the noble and learned Baroness, Lady Butler-Sloss, the noble Baroness, Lady Barker, and, importantly, the right reverend Prelate the Bishop of Bristol—almost all noble Lords, I think—raised the issue of the care sector. To be clear, the care sector has become central because it is our current focus in where we see the exploitation. To answer the points made by noble Lords, the Government believe everyone deserves to be treated fairly at work and rewarded for their contribution to the economy.
The Government are deeply concerned about issues being raised in the adult care sector, including potential unethical employment practices by some sponsors of the health and care worker visa. The Home Office has zero tolerance for sponsors who seek to exploit workers and will take action against anyone found to be doing so. Noble Lords may ask what the evidence is of that. The Home Office now revokes sponsors’ licences if they fail to meet their obligations, so the evidence is that that is happening. I know that this was also a question in the report.
Baroness O’Grady of Upper Holloway (Lab): The right reverend Prelate the Bishop of Bristol and the noble Lord, Lord Watson, talked about the importance of strengthening due diligence in supply chains. As a committee, we are keen to see much more ambitious policy on this front.
The Minister should take heart from the appetite for change from our cross-party committee, but I gently forewarn him that we will continue to hold the Government to account on progress. That is the very least that modern slavery victims and survivors deserve.
The Church of England in Parliament 
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