Procurement, Slavery and Human Trafficking Regulations: NHS

The regulations we bring forward today will require all public bodies to assess modern slavery risks in their supply chains when procuring goods and services for the health service in England. They give effect to a duty established by the Health and Care Act 2022, which requires the Secretary of State to eradicate modern slavery wherever it is found in NHS procurement processes. We are asking public bodies to take reasonable steps to address and eliminate modern slavery risks, especially when designing procurement procedures, awarding and managing contracts and setting up frameworks or dynamic markets.

Reasonable steps may include enforcing robust conditions of participation in our supply chains, with assessment criteria built into every stage of that process. They may include monitoring suppliers’ compliance and reassessing risk throughout the lifetime of a contract. They can also include writing terms that require immediate mitigation where instances of modern slavery are discovered. The regulations will also require public bodies to have regard to any relevant guidance issued by the Department of Health and Social Care or NHS England for consistency and accountability across the system. The updated version of the guidance has now been published by NHS England and is publicly available.

Colleagues might be worried about legislative overlap. They might ask themselves why we need new regulations when modern slavery is already illegal, but these regulations have been carefully drafted to fit with existing statute, and I can assure the House that contradictory duties have been avoided. We are building on existing measures, such as the Modern Slavery Act 2015 and the Procurement Act 2023, not replacing them. We are bringing all NHS England’s procurement into scope and creating a stronger legislative footing for enforcement. The point is to introduce a single, enforceable risk management approach to modern slavery across the NHS, and we will continue to review our arrangements to ensure that they remain effective for years to come.

I do not pretend that this will be easy. If there was a button somewhere in Whitehall or inside the national health service that could eliminate modern slavery at a stroke, I do not doubt that all of us would push it, but our supply chains are vast, making it difficult to fully assess the scale. Although the 2023 review was just a snapshot in time, it is likely that more than a fifth of our supply chains are still at high risk of modern slavery. Items include cotton-based products, surgical instruments and PPE gloves—all products that are vital for the day-to-day functioning of hospitals and clinics up and down the country. That is why we will back NHS organisations with clear guidance and support to root out the scourge of modern slavery wherever we find it.

There is an argument that we could procure these items on the cheap if we could just turn a blind eye, but that way of thinking is abhorrent and fundamentally un-British. We cannot simply weigh such things on the scale of a tradesman behind a counter, and we must remember our historical responsibility in eliminating slavery wherever we find it. But even if we could do that, ethical supply chains have been proven to be cost effective in the long term. There is a strong case that they help to avoid litigation and, more important, supplier collapse. Even if that were not the case, I know the will of the British people, and I have not a shred of doubt that decent people across our country will not think modern slavery a price tag worth paying. This place, the mother of Parliaments, is here to answer a call today and to send a message to all enslaved people across the world: what is happening to you is unjust, but we have not forgotten, and we will do our utmost to ensure that our money does not go to those that exploit you and keep you in chains.

Secondly, I turn to implementation and support. Regulations are not enough on their own; they must be embedded in practice. What steps will NHS England take to support procurement teams in applying these rules consistently and effectively and in maintaining the same standards across all the public sector bodies that are covered by these regulations? The regulations require NHS England to issue guidance, which is welcome, but how comprehensive will that guidance be? With NHS England being abolished, who will produce it? Will there be accompanying training and practical support for procurement teams to ensure consistency across the system? What will happen to a supplier if they are found to be non-compliant? Will the consequences be decided by NHS England centrally, or by individual trusts or ICBs? Will there be independent oversight to assess progress? With all the churn in NHS England and ICBs and the cuts to their budgets, how will they have the time and space to do that?

Next, I turn to the impact on business. The NHS relies on a wide range of suppliers, many of which are small and medium-sized businesses that bring innovation, flexibility and local expertise. Can the Minister confirm that the new requirements will not place undue burdens on suppliers or deter small businesses from bidding for NHS contracts? We must uphold the highest ethical standards, but we must also avoid creating unnecessary bureaucracy that excludes capable businesses from contributing to patient care.

Finally, I turn to the issue of co-ordination across Government. Many NHS goods are sourced internationally from complex and often opaque global supply chains. It is crucial, therefore, that our framework aligns with the broader cross-Government effort to tackle modern slavery, including at the Home Office and the Foreign Office. I would be grateful if the Minister outlined how those links are maintained in practice.

The question of co-ordination is not new. During the passage of the Great British Energy Act 2025, an amendment was introduced in the Lords to stop GB Energy from sourcing panels linked to forced labour. The Government’s initial position was that existing laws already addressed that risk, but later down the road, the Government heeded those calls by introducing their own amendment to block GB Energy from using slavery-linked solar. That episode shows how important it is to have clear and joined-up action across Government when addressing the risks of modern slavery.

The NHS should be a beacon of integrity as well as excellence. Patients and the public rightly expect that the care provided in our hospitals is not, however indirectly, tainted by the exploitation of others. The regulations are a step forward in ensuring that our health service lives up to that ideal. We welcome the intent and the ambition behind the regulations, but we will continue to push to ensure that they work in practice and without unintended consequences.