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Executive Summary
Ethixbase360 hosted a pharma-focused roundtable in partnership with Norton Rose Fulbright at their London office, bringing together senior risk and compliance professionals from across the life sciences industry. Held under Chatham House Rule, the discussion focused on Human Rights Due Diligence in Pharma, examining how companies are responding to increasing regulatory expectations around supply chain transparency, modern slavery, and human rights.
The session explored the practical implications of the NHS Procurement, Slavery and Human Trafficking Regulations 2025 and the updated Modern Slavery Act guidance. Its clear message: structured, transparent supply chain due diligence is rapidly becoming a baseline expectation.
Key Facts
Key Insights from the Roundtable
New Regulatory Requirements for NHS Suppliers
The NHS Procurement, Slavery and Human Trafficking Regulations 2025, effective May 2026, require public bodies to assess modern slavery risks before tendering and take reasonable steps to address and, where practicable, eliminate identified risks.
Suppliers will need to strengthen contractual obligations and supporting controls, including supply chain due diligence, record-keeping, corrective action processes, monitoring, training, mandatory reporting, and flow-down clauses to subcontractors.
Modern Slavery Act Guidance Updates
Updated guidance places stronger emphasis on alignment with international frameworks such as the UN Guiding Principles (UNGPs) and OECD Guidelines, reinforcing the expectation that companies adopt risk-based and transparent due diligence approaches.
Organisations are expected to identify and prioritise risks based on severity and likelihood, implement meaningful prevention and remediation measures, and provide transparency around their findings.
Practical Implications for Pharma Suppliers
Participants highlighted several practical steps organisations are already taking or considering:
- Conducting enhanced pre-engagement due diligence and full value-chain risk assessments
- Strengthening contractual assurances and implementing ongoing monitoring supported by clear KPIs
- Establishing governance processes to manage escalation and remediation
- Preparing for increasing litigation and enforcement risks linked to supply-chain human rights issues
Opportunities for Engagement
Awareness of the detailed regulatory expectations remains limited among many NHS suppliers, creating opportunities for greater engagement and guidance across the sector.
Several participants also highlighted the importance of building scalable human rights and modern slavery programmes that can adapt as requirements evolve across jurisdictions. Others noted that if the outcomes of NHS risk assessments were shared more broadly, this could strengthen the case for more systematic sector-wide screening and proactive risk management.
The Direction of Travel for Pharma Supply Chains
The discussion reinforced a clear message: structured, transparent supply chain due diligence is rapidly becoming a baseline expectation.
For NHS suppliers in the pharmaceutical and life sciences sector, preparing early will be critical — not only to meet regulatory requirements, but also to manage operational disruption, reputational exposure, and potential legal risk as scrutiny around supply chains continues to intensify.
Key Concepts
- NHS Procurement, Slavery and Human Trafficking Regulations 2025
- Regulations, effective May 2026, requiring public bodies to assess modern slavery risks before tendering and to take reasonable steps to address and, where practicable, eliminate identified risks.
- Updated Modern Slavery Act guidance
- Guidance placing stronger emphasis on alignment with the UN Guiding Principles and OECD Guidelines, and on risk-based, transparent due diligence.
- UNGPs and OECD Guidelines
- The international frameworks the updated guidance aligns with, reinforcing the expectation of risk-based and transparent due diligence approaches.
- Severity and likelihood
- The basis on which organisations are expected to identify and prioritise human rights and modern slavery risks.
- Flow-down clauses
- Contractual obligations passed down to subcontractors, listed among the controls NHS suppliers will need to strengthen.
Frequently Asked Questions
Key Takeaways & Actions
- ✓Conduct enhanced pre-engagement due diligence and full value-chain risk assessments.
- ✓Strengthen contractual assurances and implement ongoing monitoring supported by clear KPIs.
- ✓Establish governance processes to manage escalation and remediation.
- ✓Prepare for increasing litigation and enforcement risks linked to supply-chain human rights issues.
- ✓Build scalable human rights and modern slavery programmes that can adapt as requirements evolve across jurisdictions.
- ✓Prepare early — to meet regulatory requirements and to manage operational disruption, reputational exposure, and legal risk.