In March 2025, a sitting UN judge, Lydia Mugambe, was convicted at Oxford Crown Court of modern slavery offences, including forced or compulsory labour under the Modern Slavery Act 2015. She had trafficked a domestic worker from Uganda, confiscated her passport, and prevented her from leaving. The offences were sustained over several years. Even after arrest, Mugambe attempted to intimidate the victim into silence. She was sentenced to over six years in prison in May 2025.
The case is as shocking as it is symbolic: a prominent figure in international justice abusing her position to exploit another human being—and being held fully accountable under UK law.
But this isn’t just a story about individual criminality. It’s a signal to businesses.
With the Crime and Policing Bill 2025 now in the House of Lords and likely to pass into law soon, the prosecution of modern slavery offences is about to change dramatically—especially when it comes to corporate exposure.
A bigger net for corporate liability
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduced the concept of corporate criminal liability where a Senior Manager commits certain economic crimes (like fraud or bribery) in the course of their role.
The Crime and Policing Bill 2025 goes further: if a Senior Manager commits any criminal offence—not just an economic one—while acting within their actual or apparent authority, the company itself may be held criminally liable.
This is the missing link in prosecuting modern slavery in supply chains.
Until now, criminal cases under the Modern Slavery Act 2015 have largely focused on individuals. Corporate exposure has been limited to reputational risk and mandatory disclosure under Section 54. But if the Crime and Policing Bill passes as expected, companies could face prosecution if a Senior Manager knowingly allows—or even indirectly supports—the use of forced labour in the supply chain.
Prosecutors are paying attention
The Mugambe case isn’t isolated. It reflects a broader trend: UK prosecutors are becoming more willing to go after modern slavery offences, especially when there’s public pressure to act.
This trend was also evident in R (on the Application of World Uyghur Congress) v National Crime Agency (NCA), where the Court of Appeal encouraged the NCA to revisit its refusal to investigate forced labour in Xinjiang-linked imports. While no order was made, the court rejected the NCA’s argument that the threshold for launching a money laundering investigation was too high. In short: do more.
The message is clear—regulators are under pressure to take forced labour seriously, and they’re starting to do so.
Now’s the time to act
For compliance teams, the risk is no longer theoretical. Modern slavery compliance can no longer be a back-burner issue or a tick-box statement buried on your website. With ECCTA in force and the Crime and Policing Bill nearing enactment, it’s time to move from policy to action. Here’s a practical checklist for compliance teams to assess and strengthen their defences:
- Map your Senior Manager risks
Know who holds decision-making authority over sourcing, procurement, HR, logistics, and supplier selection. Under the new law, their conduct could become your corporate liability.
- Go beyond boilerplate slavery statements
Annual modern slavery disclosures are not enough. Update them to reflect current enforcement trends, and back them up with measurable action plans.
- Audit your supply chain—properly
Focus on high-risk regions, industries, and labour practices. Don’t rely on supplier self-certifications. Commission independent audits where appropriate.
- Deliver targeted training
Ensure Senior Managers understand their personal and corporate liability. Include real-world scenarios, especially around red flags in outsourcing or recruitment.
- Strengthen your whistleblowing and escalation frameworks
Victims or witnesses must have safe, anonymous, and effective ways to raise concerns—even when a Senior Manager is the problem.
The direction is clear
The combination of expanding corporate criminal liability and growing prosecutorial momentum around modern slavery means businesses must act now. The Mugambe case may have centred on a domestic worker, but its ripple effect reaches far into the corporate world.
When misconduct by a Senior Manager becomes the company’s criminal liability, no firm can afford to turn a blind eye.
