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Rathbones has welcomed the UK Government’s commitment to introduce mandatory human rights due diligence, following years of engagement by the investment industry, businesses and civil society calling for stronger measures to tackle modern slavery and human rights abuses in global supply chains. Rathbones has been among those investors advocating for stronger UK requirements alongside its longstanding engagement with companies through Votes Against Slavery.
The Government has announced that it intends to legislate for a mandatory human rights due diligence regime covering services across the UK and goods in Great Britain. It will apply to UK businesses with global turnover above £350 million and non-UK businesses generating more than £350 million of turnover in the UK.
Companies in scope will be required to identify, assess and address human rights abuses and labour exploitation risks within their operations and supply chains. The detail will need to explain the rationale for the £350 million threshold and ensure that company size is not treated as the only proxy for human rights risk.
The proposals represent an important move beyond an approach principally based on voluntary action. The Government itself said its review found the existing framework for preventing forced labour to be fragmented and overly reliant on voluntary action and reporting, and that the UK had fallen out of step with other major economies.
Matt Crossman, Stewardship Director at Rathbones, said: “This is a hugely important moment for responsible business in the UK. Our experience engaging with companies on modern slavery has reinforced our view that transparency is important, but disclosure alone cannot deliver the change needed.
The economic case for human rights due diligence is clear: investors know that companies that manage human rights risks tend to be more resilient, better governed and well placed to create long-term value.
“This announcement reflects the persistence of a remarkably broad coalition of investors, businesses and civil society groups. Rathbones is proud to have contributed to that collective effort, but the focus must be on maintaining momentum and finding Parliamentary time to deliver a regime that is proportionate, workable and effective in preventing harm and ensuring lasting, sustainable outcomes.”
Under the planned regime, a regulator will also be given powers to investigate businesses suspected of placing goods made with forced labour in the Great British market. Goods will be withdrawn where forced labour is identified and due diligence obligations have not been met.
The interaction between those two tests will therefore be an important detail of the legislation. The Government has said the regime will be risk-based and proportionate and aligned with established international standards, including the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.
Victor Riega, Responsible Business Manager at Rathbones, said: “We are encouraged to see the Government commit to moving from an approach principally based on disclosure towards one that places greater emphasis on identifying, preventing and addressing harm.
However, the detail will matter, including how the regime defines the operations and business relationships in scope and what businesses will be expected to do to prevent, mitigate and remedy harm. A successful framework should focus on better outcomes for people rather than on creating another layer of process. We look forward to working constructively with Government and other stakeholders as the legislation is developed.”
Years of investor engagement
The announcement follows sustained engagement by Rathbones and others to strengthen the UK’s approach to modern slavery and human rights risks.
The UK Modern Slavery Act was considered world-leading when introduced in 2015, but Rathbones' engagement has increasingly highlighted the limitations of an approach based predominantly on reporting and disclosure.
Most recently, Rathbones' six-year review of its Votes Against Slavery initiative found that more than 90% of companies engaged through the initiative met its compliance objective. The review also identified persistent shortcomings in corporate reporting, reinforcing Rathbones’ view that transparency requirements need to be complemented by a stronger framework for identifying and addressing human rights risks
Votes Against Slavery has grown into a coalition of 168 investors representing £1.78 trillion in assets under management. Alongside its engagement with companies, Rathbones has consistently supported policy reform intended to give greater effect to the ambitions behind the Modern Slavery Act.
Rathbones and CCLA first called for stronger requirements in 2019, submitting a response to the Home Office Transparency in Supply Chains Consultation on behalf of investors representing £2.4 trillion in assets under management. In 2023, the two organisations responded to the House of Lords Committee's call for evidence on the Modern Slavery Act on behalf of investors representing £422 billion.
In 2025, Rathbones' Votes Against Slavery was referenced as an example of investor engagement in the Home Office's Transparency in Supply Chains Statutory Guidance.
The focus of that engagement has increasingly shifted towards mandatory human rights due diligence. In 2025, Rathbones and CCLA, on behalf of investors representing £1.4 trillion in assets under management, wrote to Government ministers calling for legislation. This was followed by further engagement in 2026 backed by investors representing £1.6 trillion.
The Government has said it will now work with stakeholders on the design and implementation of the measures and introduce legislation as soon as Parliamentary time allows. The timing of legislation, consultation and implementation therefore remains to be determined.
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