In today’s fast-evolving risk landscape, modern slavery and immigration compliance are no longer just concerns for HR and legal teams. Increasingly, procurement leaders find themselves on the front line of ethical sourcing, supply chain accountability, and reputational risk. And yet, one critical intersection remains overlooked: the link between immigration enforcement and the hidden exploitation risks within labour supply chains.
As UK immigration policy grows more enforcement-led, and modern slavery legislation tightens, the implications for procurement strategies are profound. Understanding this connection is vital not only to legal compliance but to upholding ethical standards in sourcing and recruitment.
The changing face of immigration enforcement
Immigration enforcement has traditionally been viewed as an employment or HR issue, with emphasis on right-to-work checks and avoiding civil penalties of up to £60,000 per illegal worker. That view is changing. Government strategy increasingly targets labour abuse through a broader lens, holding organisations accountable for indirect violations occurring further down their supply chains.
The 2023 Labour Market Enforcement Strategy specifically highlighted the risks of outsourcing and complex labour supply chains, calling for stronger joint working between the Gangmasters and Labour Abuse Authority (GLAA), HMRC, and the Home Office. Where workers are recruited through third parties, the risk of non-compliance with immigration law and modern slavery obligations multiplies.
Ignorance is no defence. Procurement professionals must understand not only who supplies labour, but how that labour is sourced, treated, and documented.
Why indirect labour sourcing is a legal blind spot
Modern slavery and immigration risks thrive in the grey areas of labour provision. Agencies, sub-agencies, and umbrella companies often mask exploitative practices: underpayment, coercion, debt bondage, or unlawful deductions. These conditions can be especially difficult to detect where migrant workers are concerned.
Non-compliant recruitment practices don’t always leave a paper trail. Migrant workers may not report abuse due to fear of deportation or lack of awareness of their rights. Meanwhile, the companies benefiting from this labour may be unaware they are breaching laws or exposing themselves to liability.
Procurement’s expanding duty of care
Under the UK Modern Slavery Act 2015, companies with a turnover above £36 million are required to publish an annual slavery and human trafficking statement (UK Government, 2015). But beyond this statutory obligation lies a growing expectation from investors, customers, and regulators: that businesses take proactive steps to prevent exploitation.
This means procurement teams must expand their due diligence to include:
- Robust vetting of labour suppliers and intermediaries
- Contractual safeguards and audit rights
- Evidence of right-to-work compliance further down the chain
- Monitoring of working conditions, wages, and recruitment fees
- Swift reporting and remediation processes
Proactive procurement isn’t just about compliance. It’s about risk mitigation, brand protection, and being on the right side of the ethical debate.
Case in point: Construction, hospitality and care sectors
Sectors that rely heavily on outsourced or temporary labour are especially vulnerable. In construction, for example, layers of subcontracting can create ambiguity around who is employing whom, and on what terms. In hospitality and social care, low wages, staff shortages, and high turnover can incentivise corner-cutting and exploitation. To quote from current official guidance:
[Y]ou are strongly encouraged to check that your contractors and labour providers carry out right to work checks in accordance with this guidance on people they employ, engage or supply (or carry out these checks yourself). This includes anyone in your supply chain using a substitute to perform work on their behalf.
The Home Office has increased inspections and enforcement activity in these sectors, often uncovering illegal working, poor accommodation standards, and worker mistreatment. According to Home Office figures, more than 1,400 civil penalties were issued in 2023 under the Right-to-Work rules, exceeding £26 million in total, marking a 45% increase on the previous year. Procurement leaders cannot afford to assume that because a contract is with a reputable agency, everything further down the chain is compliant.
How procurement leaders must respond
- Map your labour supply chain: Know exactly where your workforce comes from, who supplies it, and who is responsible for immigration checks at every stage.
- Integrate compliance into supplier onboarding: Build immigration and modern slavery due diligence into procurement processes, contracts, and onboarding.
- Engage legal and HR early: Immigration law is complex and fast-changing. Home Office right to work checking guidance, in particular, is updated regularly, and it is vital you stay on top of it to avoid financial penalties. Engage specialist legal advisors to review contracts, policies, and supplier relationships.
- Train your teams: Ensure your procurement and supplier management teams understand the red flags of exploitation and their legal responsibilities.
- Establish audit and remediation mechanisms: Don’t just rely on paperwork. Audit suppliers, talk to workers, and create clear pathways for raising concerns.
Beyond compliance – a leadership imperative
Procurement leaders have an opportunity to drive real change. By embedding immigration and modern slavery compliance into sourcing strategies, they can strengthen resilience, protect vulnerable workers, and lead with integrity.
At Latitude Law, we support organisations in navigating this evolving landscape. From immigration compliance training to supplier audits and legal risk reviews, we work across sectors to ensure our clients stay ahead of the curve.
Choosing not to act on modern slavery and immigration risk doesn’t protect you, it exposes you.
- Risk & Resilience