From our London office at Holborn Gate, 330 High Holborn, London, WC1V 7QH, TRW & Co advises UK and international organisations on the intersection of business activity and human rights law in England and Wales. Responsible business conduct increasingly sits at the centre of regulatory compliance, investor expectations and supply‑chain risk management.

Overview: legal and commercial drivers

While the UN Guiding Principles on Business and Human Rights (UNGPs) provide the global baseline for corporate human rights due diligence, the UK legal framework contains several specific obligations and reporting expectations that business leaders should address. Key drivers include statutory requirements such as the Modern Slavery Act 2015 (transparency in supply chains), corporate disclosure duties, sectoral regulation and sector-specific licences and procurement standards.

Key corporate obligations and enforcement considerations

Companies should consider their obligations across several dimensions: statutory reporting, contractual obligations in supply chains, anti‑discrimination and employment law, and sectoral regulatory requirements. Boards and senior management need documented policies and systems that show identification, prevention, mitigation and remediation of adverse human rights impacts.

Enforcement and stakeholder challenge can arise via regulatory action, shareholder proposals, civil litigation and reputational campaigns. A proportionate and documented due diligence framework reduces legal risk and supports defensible decision‑making in high‑risk jurisdictions or complex supply chains.

Practical due diligence checklist

The following checklist outlines practical steps that companies typically adopt when building or strengthening a business and human rights programme:

• Map operations and supply chains to identify high‑risk jurisdictions, sectors and suppliers.
• Adopt a written human rights policy aligned with the UNGPs and integrate it into procurement and contracting.
• Conduct targeted human rights impact assessments and update them periodically.
• Establish grievance and remediation mechanisms accessible to affected stakeholders.
• Embed monitoring, KPIs and regular reporting to the board and external stakeholders.
• Train procurement, legal and compliance teams on red flags and contractual remedies.
• Ensure disclosure and reporting meet statutory requirements and investor expectations.

Risk management and dispute preparedness

Effective risk management combines preventative measures and dispute preparedness. Preventative measures include enhanced contract clauses, supplier audits, and conditional procurement clauses. Dispute preparedness requires incident response plans, evidence retention protocols, and consideration of alternative dispute resolution or remediation pathways that preserve commercial relationships while addressing rights‑holders’ concerns.

Jurisdiction and sources

• UN Guiding Principles on Business and Human Rights (OHCHR)
• UK National Action Plan on Business and Human Rights (gov.uk)
• Modern Slavery: guidance and resources (gov.uk)
• Modern Slavery Act 2015 (legislation.gov.uk) and Companies Act 2006 (legislation.gov.uk)
• Equality and Human Rights Commission (EHRC)

Staying aligned with these sources and maintaining documented processes helps organisations demonstrate compliance and respond proportionately to legal, investor and civil society scrutiny.

General information only; not legal advice and not a substitute for advice on a particular matter.