Business and Regulatory Impact Assessment for Scotland's Trafficking and Exploitation Strategy 2025

Section 3: Costs, impacts and benefits

Quantified costs to businesses

The Strategy does not introduce new legal duties, regulatory requirements or statutory compliance obligations for businesses. Consequently, no direct regulatory costs have been identified.

During development of this final BRIA, business stakeholders were specifically invited to identify any burdens arising from the Strategy. No evidence was identified to suggest that businesses have incurred direct costs as a consequence of implementation during the first year following publication.

Some organisations may choose to undertake activities such as staff awareness training, reviewing recruitment practices or strengthening supply chain due diligence. Broader statutory requirements for businesses continue to be implemented under the UK Government’s Modern Slavery Act 2015.

Other impacts

Previous Guidance produced in 2018 is still applicable (Slavery and Human Trafficking: Guidance for Businesses in Scotland) and has not been revised for this iteration of the Strategy. The legal duty on businesses comes from UK legislation, and this guidance is designed to complement UK Government guidance^[5], and other relevant resources. The guidance outlines that the legal duty only applies directly to larger businesses, but all businesses have an ethical duty to comply.

Businesses may benefit from improved staff retention, reduced legal risk, and stronger reputational standing. Given that regulation about transparency in supply chains (TISC) is already in place via section 54 of the Modern Slavery Act 2015. The Strategy is founded upon partnership working and collaboration and is underpinned by guidance, public resources, and sectoral support. No statutory compliance burden is imposed under the strategy.

During business engagement, no concerns were identified that implementation of the Strategy had affected competitiveness, business operations or investment decisions.

Scottish firms’ international competitiveness

As the Strategy promotes voluntary action rather than regulation, it does not create a competitive disadvantage for Scottish firms. Any ethical practices may enhance Scotland’s international reputation as a responsible place to do business.

Benefits to business

Businesses aligned with ethical and transparent practices are more likely to win public sector contracts, meet investor expectations, and attract socially conscious customers. These practices can also help mitigate workforce risks and improve relationships with regulators, partners, and the wider community.

Small business impacts

The Scottish Government recognises that smaller organisations may have fewer internal resources to devote to awareness raising or supply chain assurance. Existing guidance, including Slavery and Human Trafficking: Guidance for Businesses in Scotland, remains available to support businesses wishing to strengthen their approach on a voluntary basis.

Small and micro businesses are not subject to any additional legal requirements as a result of the Strategy. During business engagement no evidence was identified that implementation had resulted in disproportionate impacts on smaller businesses.

Investment

No direct impacts on investment have been identified.

Workforce and Fair Work

The Strategy reinforces the Scottish Government commitment to Fair Work, and we continue to use fair work to drive success, wellbeing and prosperity for individuals, businesses, organisations and society. Ministers are clear that the best way to protect Scotland’s workers is by devolving employment law. In the meantime, we will continue to use our Fair Work policy to drive up labour market standards for workers across Scotland to tackle poverty, and supporting an economy that is fair, green and growing, while creating more secure, sustainable and satisfying jobs.

Climate change/ Circular Economy

Not applicable

Competition Assessment

Not applicable

Consumer Duty

The Consumer and Regulatory Duty has been considered during the development of this Strategy and the accompanying BRIA. While the Strategy itself does not introduce new regulatory obligations, it operates within an existing statutory framework. This includes the Human Trafficking and Exploitation (Scotland) Act 2015 and relevant provisions of the UK Modern Slavery Act 2015, such as section 54 on transparency in supply chains. The Strategy promotes voluntary improvements in practice across a range of industry sectors, particularly those identified as higher risk, in a way that is proportionate and accessible. The accompanying Delivery Plan sets out implementation activities in a way that provides clarity for stakeholders while avoiding statuary requirement on businesses.

Consumers, defined in the Consumer Scotland Act 2020 as individuals or small businesses who buy, use or receive goods or services in Scotland, or could potentially do so, supplied by a public authority or other public body are not affected by the revised Strategy in any new or different ways.