In March 2025, a sitting UN decide, Lydia Mugambe, was convicted at Oxford Crown Courtroom of recent slavery offences, together with compelled or obligatory labour beneath the Trendy Slavery Act 2015. She had trafficked a home employee from Uganda, confiscated her passport, and prevented her from leaving. The offences have been sustained over a number of years. Even after arrest, Mugambe tried to intimidate the sufferer into silence. She was sentenced to over six years in jail in Could 2025.
The case is as surprising as it’s symbolic: a distinguished determine in worldwide justice abusing her place to take advantage of one other human being—and being held totally accountable beneath UK legislation.
However this isn’t only a story about particular person criminality. It’s a sign to companies.
With the Crime and Policing Invoice 2025 now within the Home of Lords and prone to move into legislation quickly, the prosecution of recent slavery offences is about to alter dramatically—particularly with regards to company publicity.
A much bigger web for company legal responsibility
The Financial Crime and Company Transparency Act 2023 (ECCTA) launched the idea of company felony legal responsibility the place a Senior Supervisor commits sure financial crimes (like fraud or bribery) in the middle of their position.
The Crime and Policing Invoice 2025 goes additional: if a Senior Supervisor commits any felony offence—not simply an financial one—whereas performing inside their precise or obvious authority, the corporate itself could also be held criminally liable.
That is the lacking hyperlink in prosecuting trendy slavery in provide chains.
Till now, felony circumstances beneath the Trendy Slavery Act 2015 have largely targeted on people. Company publicity has been restricted to reputational danger and necessary disclosure beneath Part 54. But when the Crime and Policing Invoice passes as anticipated, firms may face prosecution if a Senior Supervisor knowingly permits—and even not directly helps—the usage of compelled labour within the provide chain.
Prosecutors are paying consideration
The Mugambe case isn’t remoted. It displays a broader pattern: UK prosecutors have gotten extra keen to go after trendy slavery offences, particularly when there’s public stress to behave.
This pattern was additionally evident in R (on the Utility of World Uyghur Congress) v Nationwide Crime Company (NCA), the place the Courtroom of Attraction inspired the NCA to revisit its refusal to research compelled labour in Xinjiang-linked imports. Whereas no order was made, the court docket rejected the NCA’s argument that the brink for launching a cash laundering investigation was too excessive. In brief: do extra.
The message is obvious—regulators are beneath stress to take compelled labour critically, and so they’re beginning to take action.
Now’s the time to behave
For compliance groups, the danger is not theoretical. Trendy slavery compliance can not be a back-burner problem or a tick-box assertion buried in your web site. With ECCTA in power and the Crime and Policing Invoice nearing enactment, it’s time to maneuver from coverage to motion. Right here’s a sensible guidelines for compliance groups to evaluate and strengthen their defences:
- Map your Senior Supervisor dangers
Know who holds decision-making authority over sourcing, procurement, HR, logistics, and provider choice. Below the brand new legislation, their conduct may turn out to be your company legal responsibility.
- Transcend boilerplate slavery statements
Annual trendy slavery disclosures aren’t sufficient. Replace them to replicate present enforcement developments, and again them up with measurable motion plans.
- Audit your provide chain—correctly
Deal with high-risk areas, industries, and labour practices. Don’t depend on provider self-certifications. Fee impartial audits the place applicable.
- Ship focused coaching
Guarantee Senior Managers perceive their private and company legal responsibility. Embrace real-world eventualities, particularly round crimson flags in outsourcing or recruitment.
- Strengthen your whistleblowing and escalation frameworks
Victims or witnesses will need to have secure, nameless, and efficient methods to boost issues—even when a Senior Supervisor is the issue.
The path is obvious
The mix of increasing company felony legal responsibility and rising prosecutorial momentum round trendy slavery means companies should act now. The Mugambe case could have centred on a home employee, however its ripple impact reaches far into the company world.
When misconduct by a Senior Supervisor turns into the corporate’s felony legal responsibility, no agency can afford to show a blind eye.
Shield your organisation from trendy slavery danger with VinciWorks. Our greatest follow Trendy Slavery Reporting Resolution permits companies to remain forward of compliance with one centralised answer, and our trendy slavery coaching suite is designed to satisfy the wants of a complete staff, from common workers to procurement groups.
In March 2025, a sitting UN decide, Lydia Mugambe, was convicted at Oxford Crown Courtroom of recent slavery offences, together with compelled or obligatory labour beneath the Trendy Slavery Act 2015. She had trafficked a home employee from Uganda, confiscated her passport, and prevented her from leaving. The offences have been sustained over a number of years. Even after arrest, Mugambe tried to intimidate the sufferer into silence. She was sentenced to over six years in jail in Could 2025.
The case is as surprising as it’s symbolic: a distinguished determine in worldwide justice abusing her place to take advantage of one other human being—and being held totally accountable beneath UK legislation.
However this isn’t only a story about particular person criminality. It’s a sign to companies.
With the Crime and Policing Invoice 2025 now within the Home of Lords and prone to move into legislation quickly, the prosecution of recent slavery offences is about to alter dramatically—particularly with regards to company publicity.
A much bigger web for company legal responsibility
The Financial Crime and Company Transparency Act 2023 (ECCTA) launched the idea of company felony legal responsibility the place a Senior Supervisor commits sure financial crimes (like fraud or bribery) in the middle of their position.
The Crime and Policing Invoice 2025 goes additional: if a Senior Supervisor commits any felony offence—not simply an financial one—whereas performing inside their precise or obvious authority, the corporate itself could also be held criminally liable.
That is the lacking hyperlink in prosecuting trendy slavery in provide chains.
Till now, felony circumstances beneath the Trendy Slavery Act 2015 have largely targeted on people. Company publicity has been restricted to reputational danger and necessary disclosure beneath Part 54. But when the Crime and Policing Invoice passes as anticipated, firms may face prosecution if a Senior Supervisor knowingly permits—and even not directly helps—the usage of compelled labour within the provide chain.
Prosecutors are paying consideration
The Mugambe case isn’t remoted. It displays a broader pattern: UK prosecutors have gotten extra keen to go after trendy slavery offences, particularly when there’s public stress to behave.
This pattern was additionally evident in R (on the Utility of World Uyghur Congress) v Nationwide Crime Company (NCA), the place the Courtroom of Attraction inspired the NCA to revisit its refusal to research compelled labour in Xinjiang-linked imports. Whereas no order was made, the court docket rejected the NCA’s argument that the brink for launching a cash laundering investigation was too excessive. In brief: do extra.
The message is obvious—regulators are beneath stress to take compelled labour critically, and so they’re beginning to take action.
Now’s the time to behave
For compliance groups, the danger is not theoretical. Trendy slavery compliance can not be a back-burner problem or a tick-box assertion buried in your web site. With ECCTA in power and the Crime and Policing Invoice nearing enactment, it’s time to maneuver from coverage to motion. Right here’s a sensible guidelines for compliance groups to evaluate and strengthen their defences:
- Map your Senior Supervisor dangers
Know who holds decision-making authority over sourcing, procurement, HR, logistics, and provider choice. Below the brand new legislation, their conduct may turn out to be your company legal responsibility.
- Transcend boilerplate slavery statements
Annual trendy slavery disclosures aren’t sufficient. Replace them to replicate present enforcement developments, and again them up with measurable motion plans.
- Audit your provide chain—correctly
Deal with high-risk areas, industries, and labour practices. Don’t depend on provider self-certifications. Fee impartial audits the place applicable.
- Ship focused coaching
Guarantee Senior Managers perceive their private and company legal responsibility. Embrace real-world eventualities, particularly round crimson flags in outsourcing or recruitment.
- Strengthen your whistleblowing and escalation frameworks
Victims or witnesses will need to have secure, nameless, and efficient methods to boost issues—even when a Senior Supervisor is the issue.
The path is obvious
The mix of increasing company felony legal responsibility and rising prosecutorial momentum round trendy slavery means companies should act now. The Mugambe case could have centred on a home employee, however its ripple impact reaches far into the company world.
When misconduct by a Senior Supervisor turns into the corporate’s felony legal responsibility, no agency can afford to show a blind eye.
