Trafficking and Exploitation Strategy 2025: partial business and regulatory impact assessment

Section 3: Costs, impacts and benefits

Quantified costs to businesses

The Strategy does not impose new regulatory costs on businesses. However, employers operating in sectors with a higher risk of exploitation—such as agriculture, construction, hospitality, and care—may choose to invest in processes to strengthen ethical recruitment, staff training, or compliance initiatives which may result in an indirect cost. These actions are voluntary and vary by sector and organisation. Some businesses already undertake these steps as part of their corporate social responsibility efforts.

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, we do not expect businesses to experience any negative or unintended consequences. 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.

Scottish firms’ international competitiveness

As the Strategy promotes voluntary action rather than regulation, it does not create a competitive disadvantage for Scottish firms. Instead, 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

Small business who do not have human resource teams may find it more time and resource consuming to raise awareness and ensure transparency in supply chains. Guidance such as the Slavery and Human Trafficking: Guidance for Businesses in Scotland is available to assist.

Investment

No direct impact on investment has currently been identified although this will currently be kept under review as actions under the implementation plan progress.

Workforce and Fair Work

The Strategy reinforces the Scottish Government commitment to Fair Work. Our vision has been for Scotland to be a leading Fair Work Nation by 2025, 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 ensuing delivery plan for the Strategy will be designed to ensure expectations are clear and achievable, enabling meaningful engagement without placing undue burden on organisations.

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.