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Comment: Modern slavery is a growing governance risk hiding in plain sight

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Read time: 5-6 minutes 

Summary: Joshua Domb is the founder of Gen-R Law, a climate and ESG-focused law firm. He advises on governance and compliance, including the management of supply chain risk. In this comment blog, he explores why modern slavery and human rights abuses are critical risks that businesses must actively manage to ensure accountability, resilience, and long-term trust. 

In February 2026, Dyson reached a settlement with 24 Nepalese and Bangladeshi migrant workers, who were suing Dyson in the English courts over human rights abuses that they claimed to have suffered whilst working at Malaysian factories within Dyson’s supply chain. Claims included trafficking, forced labour, abusive working and living conditions, and, in some cases physical mistreatment. The settlement, for an undisclosed sum, was reached without any admission of liability from Dyson. Nonetheless, the case offers a powerful reminder that in addition to facilitating real and serious human suffering, human rights failings in global supply chains can present significant legal, financial and reputational risks at home.

Whilst we might like to think of modern slavery (defined as exploitation that individuals cannot refuse or leave due to coercion, abuse of power, or deception) as a problem reserved for ‘developing’ economies, the truth is that modern slavery is embedded within everyday economic activity, including in the UK.  

According to the CCLA Modern Slavery Benchmark 2025, 35 of 111 companies (including the FTSE 100) reported identifying cases of modern slavery in their most recent Modern Slavery Act compliance statements.  And in 2025 alone, more than 23,000 potential victims of modern slavery were referred into the UK’s National Referral Mechanism, the highest figure recorded since its introduction.  

Despite these realities, many organisations are still avoiding critical evaluations of human rights compliance; according to the World Benchmarking Alliance, fewer than 10% of companies assess human rights risks in their supply chain.  

New legislation on the horizon? 

The Modern Slavery Act 2015 marked a significant step forward by requiring large businesses operating in the UK to publish an annual statement outlining the steps they have taken during the financial year to ensure that slavery and human trafficking is not taking place within its supply chains or own business. However, more than a decade on, it is clear that transparency alone has not been enough to bend the curve on this serious and growing problem. Increasingly, stakeholders, from regulators to investors, are demanding that businesses take a far more proactive approach. 

The risks associated with failing to address human rights effectively are much bigger than reputational damage alone. Businesses are now facing a far broader range of consequences, including litigation from affected individuals and advocacy groups, regulatory scrutiny, operational disruption, and barriers to investment and market access.  This is being reinforced by investor expectations, with major institutions making clear that companies must integrate human rights into strategy, risk management, and reporting frameworks, not as an optional extra, but as a fundamental component of responsible business. 

While the Modern Slavery Act was once considered pioneering, there is now a growing consensus that new laws are required to strengthen the legal and regulatory position. Recent government guidance has already begun to reflect lessons learned over the past decade, and further reforms are under active consideration. Proposals such as mandatory human rights due diligence, import restrictions on goods linked to forced labour, and new “failure to prevent” obligations indicate a significant shift. Should these measures be implemented, they will move the focus firmly beyond transparency towards enforceable corporate responsibility, fundamentally changing the expectations placed on businesses operating in the UK and internationally. 

Why governance is critical for change 

The proper management of human rights risks requires cross-functional engagement, underpinned by the right organisational culture and supported by oversight at the highest levels. Boards have a responsibility to ensure that human rights considerations are embedded within decision-making processes, risk frameworks, and internal controls. This includes maintaining up-to-date risk assessments, ensuring clear accountability at a senior level, and establishing effective mechanisms for identifying and responding to concerns across the organisation and its supply chain. 

Crucially, governance must move beyond policies and statements to active engagement such as regular board-level discussion, ongoing training, and creating cultures that encourage transparency and challenge. Effective grievance mechanisms, clear escalation processes, and readiness to respond swiftly to potential violations are all components of a competent approach. Without these, organisations risk creating a gap between what they say and what they can evidence, an issue that becomes particularly exposed under legal or public scrutiny. 

For companies today, getting human rights right is not just a moral imperative; it is a legal consideration and governance necessity, as well as a defining factor in long-term resilience and trust. 

The human in human rights

When reviewing the outcome of high-profile cases like the Dyson litigation, it can be all too easy to forget about the individuals who sit at the heart of any such claim, and the harrowing circumstances that they are alleged to have endured. In the case of the Dyson litigation, the lead claimant, Mr Dhan Kumar Limbu, alleged that he: 

  • paid a recruitment fee; 

  • was required to work excessive hours for unlawfully low wages without regular rest days and without suitable personal protective equipment; 

  • was forced to live in overcrowded, insanitary and defective accommodation at his own expense; 

  • had his passport and visa retained by his employer; 

  • was taken to a local police station where he was interrogated and beaten in the presence of management and then forced into making a false statement about working and living conditions, when he tried to raise his concerns. 

Getting human rights compliance right is not just a matter of managing legal, financial or reputational risk. More importantly, it is about protecting vulnerable individuals, who all too often find themselves entrapped in situations of modern slavery and forced labour, in which they inevitably suffer from a compounding downward spiral of human rights abuse. 

According to Jess Philips MP, former Minister for Safeguarding and Violence against Women and Girls "Modern slavery is so prevalent that if businesses are not identifying risks and cases, they are probably not looking hard enough." All businesses have a role to play in promoting an environment in which human rights are respected and protected, strengthening their own businesses and brands whilst also doing their part to stamp out the evils of modern slavery and human rights abuse

Interested in finding out more? Join expert speaker Joshua Domb for his free upcoming event Getting Human Rights Right, where he will discuss learnings from the last decade, and reflect on business risks from around the world where human rights considerations have fallen short.