The UK’s Modern Slavery Amendment Act (2024), in force since January, brings a notable shift in how businesses are expected to manage modern slavery risks in their operations and supply chains. While the 2015 Act was largely about disclosure, the amendment pushes firms toward more active due diligence — a move that, depending on one’s vantage point, can feel overdue or daunting. The private sector is now under pressure to move beyond statements and policies, into the realm of concrete action and documentation.
For many organisations, the first significant hurdle is mapping suppliers. Tier 1 suppliers — those with direct contractual relationships — are generally straightforward to identify. But Tier 2 suppliers, sitting further down the chain, often exist in murkier territory. These are the entities providing goods and services to your direct suppliers, and it’s here where risk tends to concentrate. The Amendment essentially tells firms: you need to know who these actors are, or at least make serious efforts to find out. That is easier said than done.
An effective mapping exercise often starts with internal housekeeping — pulling together supplier lists that may be scattered across business units. Beyond that, many firms are turning to collaborative platforms, such as the Open Supply Hub, to triangulate data and fill in the gaps. These tools offer some promise, but of course no system is foolproof. There’s always the question of how far a firm can reasonably be expected to see into its supply chain, especially in industries with complex sourcing webs.
The Amendment also compels firms to go beyond identifying risks — it asks them to outline how they plan to address them. Remediation plans, in particular, have come under scrutiny. Some firms have published generic commitments to “work with suppliers” or “strengthen oversight,” but the more thoughtful actors are being pressed to spell out specifics. What happens if modern slavery indicators are uncovered? Is there a suspension of trade? Is there support for remediation on the ground? It’s difficult to strike the right balance between firm commitments and flexibility for case-by-case judgment. The legislation doesn’t offer a blueprint, leaving much to interpretation.
Open-data platforms are increasingly part of this conversation, though uptake varies across sectors. Some companies, perhaps anticipating future regulatory tightening, have begun disclosing supplier lists and remediation steps via public registries. The theory is that transparency attracts scrutiny, but also perhaps builds trust. It’s still an evolving practice — not everyone is convinced it offers much beyond reputational signaling at this stage.
Verification adds another layer of complexity. The Amendment points to the role of independent auditors in checking supplier declarations, but the mechanics of this remain uneven across industries. Third-party audits can only go so far, and the reliability of supplier self-reporting remains, frankly, a persistent concern. There’s interest — though still a fair bit of skepticism — around emerging traceability technologies, including blockchain pilots. Whether these tools will scale affordably, or at all, is a question hanging over many compliance conversations.
Civil society actors, too, have a role here. NGOs and watchdog groups are increasingly seen as partners in monitoring supply chains, offering external eyes where firms’ visibility fades. Some businesses have started formalising these relationships, though there’s caution about over-reliance or unintended consequences of exposing sensitive commercial data. It’s a space that feels in flux, with norms still taking shape.
What the Amendment will achieve in practice is hard to gauge so early on. Firms are adjusting at different speeds. There’s debate about whether the new requirements will meaningfully shift behaviour, or simply lead to more sophisticated compliance documentation. Enforcement, naturally, looms as a critical factor — but as with many regulatory efforts, the details of how and when enforcement will bite remain, for now, somewhat unclear.