Modern Slavery Risks in the UK Facilities Management Sector
Recent legal decisions have raised important questions about how robust modern slavery risk management truly is within the UK Facilities Management sector. These developments also cast renewed scrutiny on the strength of the UK’s regulatory framework and the effectiveness of emerging reporting standards intended to address labour exploitation.
Key modern slavery risks in the FM sector
The FM sector is structurally exposed to modern slavery risks due to its workforce profile and complex supply chains. The industry relies heavily on migrant, temporary and agency labour, groups widely recognised as being more vulnerable to exploitation. Many FM roles mirror conditions found in the construction sector: physically demanding work, irregular hours, and dispersed or isolated sites. These working environments make oversight difficult and can conceal abusive practices.
FM providers also operate multi‑tiered supply chains across high‑risk service categories including cleaning services, maintenance, waste management, and construction subcontracting. Limited visibility into second‑ and third‑tier suppliers means the highest‑risk activities often sit furthest from direct oversight. Ongoing labour shortages amplify this vulnerability, increasing reliance on external recruitment agencies and subcontractors—arrangements that can introduce risks such as deceptive recruitment, wage withholding and debt bondage.
Risks are further heightened by the procurement of goods produced overseas. Many products commonly used in FM operations originate from regions or industries where forced labour is well‑documented. Global benchmarks continue to flag concerns across textiles, electronics, solar panels, PPE, cleaning chemicals and other imported categories, meaning FM companies may inadvertently source goods linked to exploitative labour conditions deeper in global supply chains.
Regulatory environment: UK vs international requirements
The UK Modern Slavery Act (MSA) 2015 brought transparency to the issue by requiring large organisations to publish annual modern slavery statements. While pioneering at the time, the regime has faced longstanding criticism for lacking enforcement, penalties and mandated reporting standards. The result has been highly variable statement quality and a focus on policy descriptions rather than outcomes.
A 2024 House of Lords review recommended introducing mandatory human rights due diligence, stronger regulatory intervention, and clearer enforcement mechanisms—though meaningful legislative change is still pending.
Internationally, the UK is now lagging. Jurisdictions such as Germany and France require companies to actively identify, prevent and mitigate human rights abuses across their supply chains, backed by fines and legal liability. The EU’s forthcoming due diligence requirements move even further in this direction. Meanwhile, the United States maintains import bans in cases of suspected forced labour, highlighting the growing global expectation for companies to evidence real due diligence.
Current disclosures by UK FM companies
The UK’s Modern Slavery Statement Registry offers insights into reporting trends across the FM sector. While many FM companies outline policies, staff training and supplier vetting processes, the overall quality and depth of disclosures remain inconsistent. As in other high‑risk sectors, very few companies report identifying actual cases of exploitation—despite ongoing NGO and government warnings that the absence of findings typically reflects insufficient scrutiny rather than the absence of risk.
External benchmarks show gradual but modest improvement. Persistent gaps remain in risk identification, corrective action, victim remediation and outcome‑based reporting. Many FM companies still struggle to trace supply chains beyond first‑tier suppliers, limiting their ability to detect and address deeper systemic risks.
Expanding corporate accountability: recent case law
Recent UK legal developments have significantly expanded the potential liability of UK‑based companies for labour abuses in global supply chains. A landmark case involving Dyson found that UK companies may owe a duty of care to workers in overseas supplier factories where they exert substantial control over working conditions. This aligns with earlier rulings involving Vedanta and Shell, which extended UK jurisdiction over environmental and social harms linked to foreign subsidiaries.
For sectors like FM, where global procurement and outsourced operations are common, the precedent underscores a rising expectation: companies can be held accountable for harm occurring deep within their supply chains if they influence how those suppliers operate.
The role of the TISFD in strengthening reporting
The Taskforce on Inequality and Social‑related Financial Disclosures (TISFD), launched in 2024, aims to standardise and elevate corporate reporting on social risks—including labour exploitation—by treating inequality and human rights abuses as financially material, system level risks.
The TISFD promotes consistent metrics, double materiality analysis, stronger governance expectations, and outcome focused disclosures. It integrates social considerations into mainstream financial reporting frameworks, mirroring the impact the TCFD had on climate risk governance. By embedding labour conditions, human dignity, and worker wellbeing into financial risk analysis, the TISFD offers a powerful mechanism to enhance transparency, strengthen risk identification, and drive more meaningful corporate action on modern slavery.
The SFMI (Sustainable Facilities Management Index) empowers businesses to drive positive impact. Through our exclusive partnership programme, collaborative forums, trusted assessment framework, and our first-of-its-kind self-assessment tool, we help FM organisations achieve measurable results across a broad range of ESG criteria. If you’d like to know how the SFMI could support your organisation, please get in touch.
