Procurement, Slavery and Human Trafficking Regulations: NHS

Caroline Nokes Excerpts

Wednesday 22nd October 2025 Commons Chamber

[The Parliamentary Under-Secretary of State for Health and Social Care (Dr Zubir Ahmed)]

I beg to move,

That the draft National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025, which were laid before this House on 9 September, be approved.

I am here on behalf of the Minister for Secondary Care, my hon. Friend the Member for Bristol South (Karin Smyth). It is an honour to represent the Government as we bring forward this important secondary legislation, and it is right that it should be given the full scrutiny of the House today.

Slavery is one of the greatest evils in human history. This Government cannot and will not accept that we could be supporting forced labour or human trafficking through our supply chains, however inadvertently. Before I continue, I acknowledge the cross-party support on this issue, both in this House and in the other place. I pay tribute to all hon. and right hon. Members and peers of the realm, such as Lord Alton, who have worked tirelessly to put modern slavery at the forefront of our national conversation.

I begin by setting out why we need the regulations. Many people are taken aback when they are told that there are more enslaved people now, in absolute terms, than at any point in human history. It is estimated that around 50 million people worldwide are living in some form of modern slavery. Globalisation has provided near-limitless opportunities for trade in goods and services, but also, unfortunately, in human beings. Though we on these isles would like to think that we are insulated from the highways of human trafficking, we are not.

In late 2023, the previous Government published a review into NHS supply chains that covered 60% of medical consumables. It accounted for £7 billion of spend across 1,300 suppliers, representing 600,000 products, and a fifth of those suppliers were deemed to be high risk. Imagine my horror when I read that some of the tools of my trade—surgical instruments, facemasks—could be contaminated by modern slavery. As someone who still practises as a surgeon, I know that I share that revulsion with my colleagues across the national health service. I ask my colleagues in this place to keep all our NHS staff in mind over the course of our proceedings.

The review also recognised the wider benefits to the NHS of a better understanding of how our supply chains work, noting how we could improve the quality of products supplied and the resilience of supply. It gave us clear recommendations for us to act on and today I am proud to come to the House with landmark modern slavery legislation to put those policies into practice. This is a first on these isles and I sincerely hope that our colleagues across the devolved Governments can follow suit soon.

I now turn to what the regulations will do. The NHS is one of the largest public sector procurers in the world, with an annual spend of £35 billion, doing business with over 80,000 suppliers. We have a duty to ensure that no products we procure could be tainted by forced labour, and an opportunity to use our immense purchasing power for global good.

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.

[Madam Deputy Speaker (Caroline Nokes)]

I call the shadow Minister.