Joint statement on the Department for Business and Trade’s proposed review of responsible business conduct: Six criteria to ensure the review is meaningful.
We welcome the news that the Department for Business and Trade will be reviewing its “approach to ensuring responsible business conduct, focusing on the global supply chains of businesses operating in the UK” as part of the UK’s Trade Strategy (launched 26 June 2025).
We wholeheartedly agree that “business must play its part in addressing the adverse impacts on people and planet caused by its activities” and we are pleased that the government has recognised that “concerns continue to be raised regarding the
effectiveness of the UK’s regime in preventing human rights, labour rights, and environmental harms in supply chains.” Businesses have caused, contributed and been linked to serious human rights and environmental abuses in the UK and abroad on a significant scale and without effective access to remedy for those impacted. New legislation is needed to address these ongoing abuses.
We commend the fact that the section on Responsible Business Conduct with the Trade Strategy recognises both the moral and financial benefits of responsible business conduct. We urge the Government to ensure that all government policy is
assessed in terms of the risks that could be caused to people and the planet, and the social and the economic costs that human rights abuses and environmental devastation present to society.
Currently, published references to the review do not provide full details of how it will be conducted and what will be included within the review including whether we can expect it to consider the policy recommendation that many parliamentarians, civil
society organisations, trade unions, businesses, rights holders and the public are calling for: robust new legislation that requires businesses to take meaningful action to prevent human rights, labour rights and environmental harms in their operations and supply chains.
It is essential that the Department for Business and Trade conducts a thorough, open and meaningful review, in consultation with a wide array of rightsholders, including those impacted by business activities in the Global South, that gives full consideration to our proposal for a Business Human Rights and Environment Act and results in strong legislative recommendations to protect people and the planet.
Requirements for a meaningful review:
- Fully consider the need to introduce new legislation to support responsible UK businesses and ensure alignment with international standards.
We welcome the Government’s confirmation that it will champion international standards to protect responsible British businesses from being put at a disadvantage to businesses that are abusing human rights, labour rights and environmental standards. To deliver on this promise, the Government must introduce effective, mandatory, enforceable regulation that aligns with international human rights law. Continued reliance on voluntary measures will not ensure a thriving economy, nor will it level the playing field for businesses already doing the right thing.
The Trade Strategy refers to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights, which are the authoritative standards on Responsible Business Conduct. We urge those conducting the review to ensure proper consideration of these standards as the minimum requirements for not only identifying, preventing, mitigating and accounting for abuse in business and public sector value chains, but also for the creation of effective access to remedy. Crucially, legislation must require businesses to carry out informed, meaningful and safe engagement with rightsholders throughout the due diligence process and the right to Free, Prior and Informed Consent must be respected.
In particular, it is important to note that the OECD has recently recognised the limitations of voluntary standards and stressed the importance of enforcement when it comes to corporate governance and human rights. The UN Office of the High Commissioner for Human Rights also recognised the scarcity of effective accountability and remedy mechanisms when it published “Access to Remedy in Cases of BusinessRelated Human Rights Abuse: A Practical Guide for State-Based Judicial Mechanisms”. Considerable attention needs to be given to how new legislative approaches will be enforced with adequate resources and using an approach which is effective in deterring poor practice and changes business behaviours which both cause and perpetuate violations. It is also essential that new legislation works for SMEs and protects rightsholders across the value chain.
2. Take a holistic approach to responsible business conduct.
The OECD considers responsible business conduct to address both human rights abuses and environmental harms. This review must take an aligned approach. A Business, Human Rights & Environment Act takes a holistic approach, addressing the business responsibility to respect human rights, labour rights and the environment. Bringing all harm prevention under one law would help minimise regulatory burden, as per the Prime Minister’s commitment, as this would be a comprehensive piece of legislation that covers human rights and environmental protections across all industries and sectors (including public authorities).
The current proposal is for the review to focus only on global supply chains; however, we stress that it is essential that this review covers the full value chain, in alignment with the UN Guiding Principles on Business and Human Rights, including both upstream and downstream aspects of responsible business conduct. Furthermore, domestic supply chains must not be overlooked. In consideration of the known harm that has been caused in the UK (i.e. Grenfell, Boohoo operations in Leicester and alleged exploitation of migrants on Haygrove farms) we strongly advise against a two tier system.
3. Address access to remedy
In far too many cases, existing systems are failing to ensure that there is access to remedy for survivors of corporate abuse. The review must address how to ensure effective remedy for those harmed by business practices, including but not limited to Indigenous peoples, rural communities, human rights defenders and women and girls, who face unique and disproportionate barriers in accessing remedy and justice. While the strategy mentions the UK National Contact Point, rebranding the mechanisms will not be enough to make it effective in the way envisioned by the UNGPs. Neither is it sufficient as a non-judicial mechanism to provide effective access to remedy. Responsible Business Conduct regulation must include access to justice for those harmed.
4. Ensure cross-departmental engagement.
We understand that there will be cross-departmental engagement on this review and wish to further stress the importance of this. The current approach to issue- and sectorspecific regulation creates a patchwork of obligations for businesses, which also increases their compliance burden and costs. We recommend that relevant departments (including at least DBT, FCDO, DEFRA, DESNZ, the Home Office and the Cabinet Office) engage regularly with each other and with other key external stakeholders, including civil society, for this review.
5. Conduct a wide-ranging, fully accessible, public consultation
It has been confirmed that Stakeholders will be consulted during the review, including businesses, investors, trade unions, academia, civil society and the UK’s trading partners. However, the engagement must go further and include a full public consultation that enables meaningful gender-informed input from all affected rightsholders, including but not limited to Indigenous peoples, peasants (campesinos), women’s rights organisations, human rights defenders and workers from the Global North and South. This should include ensuring that submissions can be received in languages other than English.
6. Publish the timeline for the review and ensure full transparency on the process.
The review is already underway; however, we are unaware of the full timeline and how long it is expected to take. We stress that this review should be conducted as an urgent priority for the government, and a clear timeline should be published promptly, providing clarity on the points at which external stakeholder input and consultation will occur.
In conclusion:
We are pleased to see the UK government’s commitment to improving the conduct of UK businesses. In order to have the intended impact, this review must look in detail at what actions can actually deliver the best impact for people and the planet and what effectively prevents harm and enables remedy, including full consideration of a Business Human Rights and Environment Act.