Review of risk of modern slavery and human trafficking in the NHS supply chain

An estimated 50 million people live in modern slavery across the world. Modern slavery exists in every country, including the UK, with instances of forced and child labour documented within the supply chain of the health and social care sector.

The Health and Care Act 2022 requires the Secretary of State for Health and Social Care, with the support of NHS England, to conduct a review of modern slavery risk in healthcare supply chains and propose legislation to eradicate the use of goods or services tainted by slavery or human trafficking. This report contains the outcomes of that review. 

The review represents a snapshot in time, covering around 60% of the NHS spend on medical consumables procured through NHS Supply Chain at the supplier level. Risk ratings drawn from the government’s Modern Slavery Assessment Tool (MSAT), and international risk data reflects previous indications of risk, with 21% of suppliers identified as high risk, and surgical instruments, gloves, gowns, uniforms, and face masks identified as the 5 highest risk products. More significantly the review identified the limitations of the available risk data, the reliance on supplier submissions, the complexity of risk identification and the need to increase supply chain transparency.

Establishing regulation that sets out how to address the risk of modern slavery through the procurement process is needed to embed modern slavery due diligence in the procurement process. Implementation of the regulations should be supported by the development of NHS guidance. This will enable the NHS to use its extensive buying power more effectively to eradicate modern slavery. It is not presently possible to avoid high risk suppliers completely.

Improving modern slavery risk identification and management will require a standardised and consistent approach to minimise the burden on suppliers and NHS staff. Building risk assessment data into the health family’s e-commerce system will enhance due diligence practices throughout the procurement lifecycle. Supported by capacity building of both the supply chain and staff.

It is also important to recognise the wider benefits to the NHS of enhanced supply chain understanding, with the potential to improve the quality of products supplied and resilience of supply.

While the scope of the new regulations will be limited to healthcare supply chains, modern slavery exists in all government supply chains and the adoption of a cross government approach would optimise resources further.​