Procurement, Slavery and Human Trafficking Regulations: NHS

Caroline Johnson Excerpts

Wednesday 22nd October 2025 Commons Chamber

[Dr Caroline Johnson (Sleaford and North Hykeham) (Con)]

It is a pleasure to speak in this debate on the draft National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025. I thank the Under-Secretary of State for Health and Social Care, the hon. Member for Glasgow South West (Dr Ahmed), for bringing forward the regulations and welcome him to his place at the Dispatch Box.

This important issue goes to the very heart of the values that underpin our national health service. It is a vast organisation—one of the largest in the world—with supply chains that reach across many sectors and many countries. With that scale comes a responsibility to ensure that the products and services we rely on to care for patients are sourced ethically, and that the health service does not, even inadvertently, contribute to exploitation or modern slavery.

As an NHS consultant, I know that the idea that any item used in the care of patients, from surgical gloves to hospital linen, could have been produced through exploitation or forced labour is abhorrent to all of us. These regulations seek to strengthen the NHS’s ability to identify, prevent and address such risks—an ambition that I am sure commands support right across the House. Indeed, this work began under the last Conservative Government. The Health and Care Act 2022 passed new regulations to address the risk of modern slavery in NHS supply chains, and in December 2023 we delivered a review into those risks, supported by NHS England, which examined where the greatest risks lay and how they could be mitigated. Although we welcome the direction of travel, there are, however, some important questions about how the regulations will work in practice and how we will ensure that the regulations deliver what is intended in a fair way.

First, what demands do we expect that the regulations will place on the NHS? They apply to all public bodies procuring goods and services for the NHS in England, including NHS England, hospital trusts and integrated care boards. Will each organisation have to make its own separate risk assessment? Has an estimation been made of the time that that is expected to take? How many people are expected to be required for organisations to fulfil the requirement, and what will be the associated cost? Will any mechanisms be put in place to prevent duplication, for example, where suppliers are already reporting under the Modern Slavery Act 2015?

Secondly, I turn to implementation and support. Regulations are not enough on their own; they must be embedded in practice. What steps will NHS England take to support procurement teams in applying these rules consistently and effectively and in maintaining the same standards across all the public sector bodies that are covered by these regulations? The regulations require NHS England to issue guidance, which is welcome, but how comprehensive will that guidance be? With NHS England being abolished, who will produce it? Will there be accompanying training and practical support for procurement teams to ensure consistency across the system? What will happen to a supplier if they are found to be non-compliant? Will the consequences be decided by NHS England centrally, or by individual trusts or ICBs? Will there be independent oversight to assess progress? With all the churn in NHS England and ICBs and the cuts to their budgets, how will they have the time and space to do that?

Next, I turn to the impact on business. The NHS relies on a wide range of suppliers, many of which are small and medium-sized businesses that bring innovation, flexibility and local expertise. Can the Minister confirm that the new requirements will not place undue burdens on suppliers or deter small businesses from bidding for NHS contracts? We must uphold the highest ethical standards, but we must also avoid creating unnecessary bureaucracy that excludes capable businesses from contributing to patient care.

Finally, I turn to the issue of co-ordination across Government. Many NHS goods are sourced internationally from complex and often opaque global supply chains. It is crucial, therefore, that our framework aligns with the broader cross-Government effort to tackle modern slavery, including at the Home Office and the Foreign Office. I would be grateful if the Minister outlined how those links are maintained in practice.

The question of co-ordination is not new. During the passage of the Great British Energy Act 2025, an amendment was introduced in the Lords to stop GB Energy from sourcing panels linked to forced labour. The Government’s initial position was that existing laws already addressed that risk, but later down the road, the Government heeded those calls by introducing their own amendment to block GB Energy from using slavery-linked solar. That episode shows how important it is to have clear and joined-up action across Government when addressing the risks of modern slavery.

The NHS should be a beacon of integrity as well as excellence. Patients and the public rightly expect that the care provided in our hospitals is not, however indirectly, tainted by the exploitation of others. The regulations are a step forward in ensuring that our health service lives up to that ideal. We welcome the intent and the ambition behind the regulations, but we will continue to push to ensure that they work in practice and without unintended consequences.

[Dr Ahmed]

I am grateful for the comments of the Opposition health spokesperson. Proportionality is the theme of the day when it comes to anything that we implement in the NHS at a global scale. The appropriate training will be provided. As the hon. Lady well knows from her time in government, conversations across Departments, particularly on these issues, are always ongoing. We are always willing and able to flex as we learn and as we feel our way through these regulations. The hon. Lady will recognise their importance and primacy when engaging in supplier contract negotiations, and therefore businesses both small and large can feel confident that, if they follow ethical procurement practices, their business is most welcome in the national health service.

I want to end by reminding colleagues that these regulations are not just about what we can do on these isles but what we can do to eliminate modern slavery across the globe. NHS England is one of the biggest buying organisations in the UK. We have a golden opportunity at the moment to leverage its purchasing power to influence supply chains not only in the UK and Europe but right across the world. Today, Parliament can send a clear signal to the world that we will not tolerate human rights abuses and that, if a company wants to do business with the NHS, they must get their house in order. Under this Government, there will be no compromise with the evil of slavery. I ask colleagues from all sides to help us to keep that promise, to back our NHS and its staff and to help us to keep this country’s conscience clean. I commend the regulations to the House.

Question put and agreed to.

Resolved,

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