New report warns modern slavery policies must lead to action

Businesses should judge their response to modern slavery by what changes for workers, rather than the number of policies, audits or training sessions they report, according to a new white paper from King’s Business School.

The report looked at how organisations are using the British Standard BS 25700 to turn commitments into practical systems for preventing, identifying and addressing exploitation, and how the forthcoming ISO 37200 will further strengthen their efforts. Its case studies feature National Grid, with complex international supply chains supporting major infrastructure projects, and small UK security provider Cava Security.

Following earlier King’s Business School research exposing modern slavery risks in UK housebuilding, the report shifts the focus from identifying the problem to showing what effective action looks like.

National Grid used BS 25700 to identify where workers were most at risk and shape a three-year Human Rights Action Plan. This included improving training, strengthening routes for reporting concerns and making responsibilities clearer across the business.

The report highlights how third-party audits at a First Solar facility in Malaysia identified passports being retained, recruitment fees charged to migrant workers and wages unlawfully withheld. The supplier subsequently returned the passports, reimbursed the fees and paid the withheld wages.

It also strengthened its policies and trained service providers, with a follow-up audit achieving the Responsible Business Alliance’s highest recognition level. National Grid shared the findings through the Utilities Against Slavery working group to help improve practice across the sector.

The case demonstrates why human rights oversight matters as investment in clean energy infrastructure grows. Without it, projects intended to support a more sustainable future can still expose workers deep within global supply chains to exploitation.

Cava Security showed that meaningful action is also possible without a multinational’s compliance resources. The SME appointed a modern slavery lead and created a cross-functional team to respond to suspected cases.

It has introduced procedures for victim support, investigation and remediation, mandatory staff training, supplier audits and welfare checks. The report says these changes have reduced risk, increased client confidence and helped the company compete for responsible procurement contracts.

Dr Gabriela Gutierrez-Huerter O, Senior Lecturer in International Management at King’s Business School and co-author of the report, said:

“The real test of a modern slavery strategy is not how many audits have been completed or policies published. It is whether an organisation can uncover exploitation, act when it finds harm and improve outcomes for workers.”

Daphning Pierre, Sustainability Manager at National Grid, said:

“Addressing human rights risks goes beyond policies and commitments. It is driven by practical action, collaboration and a commitment to continuous improvement. Our work with King’s Business School and BSI has provided valuable opportunities to share learning, strengthen our approach, and contribute to a broader conversation on how organisations can better identify, prevent and address labour exploitation risks across complex supply chains.”

Dan Palmer, Director of Standards Innovation at The British Standards Institution (BSI), said:

“BSI is pleased to have supported this partnership with King’s Business School. This joint white paper shows the need to bridge the gap between policy and practice. BS 25700 and the forthcoming ISO 37200 can help organisations move beyond compliance and statements of intent towards outcomes-focused, governance-led and worker-centred risk management, building trust across complex supply chains and turning ambition into demonstrable action.”

The white paper draws on a King’s Business School and British Standards Institution partnership, including learning labs involving 82 organisations and a flagship conference attended by representatives from 77 organisations. Participants warned that measures such as audit and training totals reveal little about whether workers are protected from labour exploitation.

Its central takeaway is that companies cannot audit their way out of modern slavery risk. They must combine supplier information with worker testimony and on-the-ground checks, focus resources on the highest-risk parts of their supply chains and remedy harm when it is found.

The work of the partnership was supported by a Fellowship awarded to Dr Gutierrez-Huerter O by the Economic and Social Research Council (ESRC) Impact Acceleration Account.