As the U.K. Home Office initiated its second formal review of the Modern Slavery Act in late 2019, many companies across sectors found themselves reflecting, perhaps with some unease, on the adequacy of their current compliance strategies. There has been, for some time, an undercurrent of frustration in certain corners of industry regarding the difficulty of translating good intentions into credible, verifiable action on modern slavery risks. The review process itself, while welcomed in principle, has also rekindled debate about what genuine transparency really looks like, and what it demands in practice. For retail and hospitality chains, in particular, where supplier networks often sprawl across dozens of jurisdictions, the task has begun to feel daunting, if not at times overwhelming.
Among the more promising developments in this space has been the tentative embrace of blockchain-based supplier audit systems. The technology, though still viewed by many as something of a novelty, offers a level of record integrity that traditional spreadsheets and PDFs simply cannot match. When done properly, a blockchain ledger can provide a tamper-proof log of audit findings, declarations, and corrective actions, tied securely to individual suppliers and time-stamped for accountability. Some firms have already begun piloting such systems in high-risk product categories—garments, seafood, certain agricultural goods—where the risk of forced or bonded labour has been particularly acute. Yet even here, challenges abound. Blockchain technology requires both investment and a degree of technical literacy that not every supplier, particularly smaller ones in emerging markets, can easily muster. And of course, the technology is only as good as the data entered into it. There remains the uncomfortable truth that dishonest actors can still game the system if oversight is weak.
In parallel, there has been growing interest in the use of open data sources, such as the supply-chain risk indices produced by Human Rights Watch and other advocacy organisations. These datasets, while not always as granular as compliance officers might wish, can nevertheless provide valuable context for prioritising supplier due diligence. A retail chain with hundreds of suppliers across Asia or Africa might, for example, use these indices to identify regions or sectors where human rights risks are systematically higher. The data can also help firms identify blind spots in existing audit programmes, prompting more targeted field investigations. It is, to be fair, not a perfect science. Risk indices inevitably rely on national-level or sector-level indicators, which can miss sub-regional or company-specific nuances. But as a starting point, they offer a level of objectivity that internal risk ratings sometimes lack.
One best practice that seems to be emerging, albeit unevenly, is the integration of supplier self-assessments with independent investigations carried out by NGOs or trade unions. The logic here is straightforward enough: supplier declarations, however detailed, carry limited weight unless verified by credible third parties. In practice, this means companies need to establish channels for sharing findings, agreeing corrective actions, and—crucially—tracking progress in a way that can be disclosed publicly without compromising commercial confidentiality. Some firms have experimented with joint remediation trackers, published either on their own websites or via industry associations. These trackers typically summarise the nature of identified risks, the steps being taken to address them, and the status of those efforts. It is, admittedly, an evolving practice. The level of detail varies widely between companies, and not all stakeholders agree on how much transparency is enough. There is a tension, sometimes unspoken but palpable, between the desire to demonstrate good faith and the fear of reputational harm if remediation efforts fall short or take longer than expected.
Retailers and hospitality chains looking to strengthen their modern slavery responses could do worse than to pilot these emerging practices in one or two high-risk categories before attempting a wholesale rollout. Starting small allows firms to work through practical challenges, from technology integration to supplier engagement, before scaling up. It also creates space for dialogue—both internally, among compliance, procurement, and operations teams, and externally, with suppliers and civil society partners. Such dialogue, while often time-consuming and at times frustrating, can surface valuable insights that no amount of desk-based analysis would reveal. And it can help build the trust necessary for genuine collaboration on what remains, at its core, an immensely complex and sensitive issue.
The evolving landscape of modern slavery compliance under the U.K. Modern Slavery Act continues to test firms’ resolve and ingenuity. The push for more meaningful transparency, driven both by regulators and by an increasingly vigilant public, shows no signs of abating. Companies that approach the challenge with a willingness to innovate, to collaborate, and, perhaps most importantly, to acknowledge and learn from their shortcomings, may find themselves better positioned as expectations continue to rise. Whether blockchain, open risk data, or joint remediation trackers become standard tools of the trade remains to be seen. What is clear, at least for now, is that the era of tick-box compliance is drawing to a close.