RBC review

The government’s Responsible Business Conduct (RBC) review is currently exploring several options to strengthen corporate accountability. These include the potential for mandatory human rights and environmental due diligence obligations for businesses.

The review is also assessing the viability of import controls and the enforcement model required to give these new rules authority. The details regarding penalties and regulatory oversight will be decided by ministers upon the review’s conclusion.

This work is being led by the newly-formed Office for Responsible Business Conduct (ORBC), which is responsible for coordinating government efforts on supply chain harms. Additionally the government is considering enhanced reporting rules potentially extending obligations to public sector bodies and introducing penalties for non-compliance.

According to government information, the current reporting threshold referenced is an annual turnover of about US$46m, meaning the focus remains on larger firms while expectations of cascading due diligence through supply tiers will grow.

Trade policy and sector-specific scrutiny

Trade policy will continue to be a key tool, with the government embedding forced-labour provisions into its Free Trade Agreements (FTAs). These agreements allow for recourse to implementation forums and dispute processes if obligations are not met.

The UK has already held labour discussions focused on forced labour with 14 FTA partners which could indicate a move towards a stricter international baseline for supply chain conduct.

Clean energy has been identified as a priority area for these new measures. The Department for Energy Security and Net Zero (DESNZ) plans to embed ethical supply chain requirements into its growth strategies. While the government has welcomed industry-led initiatives like the Solar Stewardship Initiative it has stated that public procurement will not depend on this alone.

Standards will be continuously reviewed and action will be taken if compliance gaps are found.

A refreshed critical minerals strategy due in 2025 also aims to enhance responsible and transparent sourcing across these vital inputs. Procurement leaders in sectors with known exposure such as solar, electronics, garments and critical minerals should anticipate that buyers will expect clear evidence of progress on due diligence.