The Ethical Trading Initiative (ETI) has urged the UK government to ensure that workers and their trade unions play a central role in the country’s proposed mandatory human rights due diligence (mHRDD) legislation. The organisation believes that meaningful worker participation and access to remedies must form the foundation of the new regulatory framework.
The recommendation follows the UK government’s announcement of plans to introduce mandatory due diligence requirements for large businesses. The proposed legislation will require companies to identify, evaluate and address human rights violations and labour exploitation risks across their operations and supply chains.
Announced on 4 November, the proposed framework is expected to cover UK-based companies with global annual turnover exceeding £350 million ($470 million). It will also apply to overseas businesses generating more than £350 million in turnover within the UK.
Under the proposed UK human rights due diligence law, companies will be expected to follow the principles established under the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines.
The legislation will also introduce stronger enforcement mechanisms. A designated regulator will receive powers to investigate companies suspected of placing products manufactured using forced labour on the British market. Where inadequate due diligence is established and forced labour is identified, the regulator will be authorised to require the removal of affected goods.
Welcoming the government’s announcement, ETI executive director Giles Bolton said: “Today’s announcement is a huge step forward for workers in global supply chains, and for the many responsible businesses, trade unions and NGOs that have called for it.
“ETI stands ready to work with government on the detail, so the law puts workers at the heart of due diligence, creates a level playing field for responsible businesses and gives people who are harmed a route to remedy. We will also strongly encourage government to ensure that both public sector procurement and environmental due diligence are included in scope, and that a clear timetable is set out so businesses can prepare.”
ETI outlines priorities for effective legislation
While recognising the announcement as an important development, ETI has stressed that the effectiveness of the legislation will depend on how its provisions are designed and implemented. The organisation particularly emphasised the need for workers and trade unions to participate meaningfully in due diligence activities, alongside access to effective remedies for those affected by labour and human rights violations.
Its recommendations include several measures to strengthen the proposed framework:
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Comprehensive supply chain coverage: Requirements should extend across entire value chains, both in the UK and internationally, including companies’ own purchasing practices.
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Environmental accountability: Environmental harm should be incorporated into the regulatory framework as it evolves.
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Public procurement inclusion: Government purchasing activities should fall within the scope of the rules, using public sector buying power to encourage responsible practices across industries.
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Proportionate business responsibilities: Larger companies should use their influence to support suppliers in meeting standards rather than simply transferring compliance obligations down the supply chain.
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Clear implementation timeline: The government should establish a defined schedule and introduce the legislation during the current parliamentary session.
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Stronger regulatory oversight: The regulator’s responsibilities should extend beyond identifying forced-labour goods, with appropriate sanctions to encourage improvements and mechanisms to secure remedies for affected individuals.
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Stakeholder-led guidance: Implementation guidance should be developed through consultation with businesses, trade unions, NGOs and people with direct experience of supply chain abuses.
The government’s announcement follows several years of campaigning by ETI’s members, representing businesses, trade unions and non-governmental organisations, alongside other industry and civil society groups, including the British Retail Consortium and the Corporate Justice Coalition.
Momentum for stronger regulation also increased last month when 33 organisations joined ETI in writing to the Prime Minister, calling for more effective and clearly regulated supply chain practices.
The government has indicated that it intends to “work closely” with relevant stakeholders while developing and implementing the new requirements. The legislation is expected to be introduced as soon as parliamentary time permits.
ETI board chair Philip Jennings highlighted the growing international movement towards legally binding human rights due diligence requirements. He added: “Around the world, more and more countries are making due diligence a legal duty, and today the UK has taken its place among them. Global supply chains connect workers, businesses and consumers across borders, and a common international standard, built on the UN Guiding Principles and OECD Guidelines, is what makes respect for workers’ rights possible at scale. The UK’s commitment sends a strong signal to its trading partners, and to workers everywhere who make the goods we rely on.”
The proposed UK human rights due diligence law could represent a significant shift in how large businesses manage human rights risks across international supply chains. Its eventual impact will depend on the scope of the requirements, enforcement powers and the extent to which workers are involved in monitoring conditions and securing accountability.
