UK employment law round-up: April 2025

Modern slavery reporting changes 

For nearly a decade there has been widespread efforts to change guidance around the Modern Slavery Act 2015 (MSA).  

Now, following significant recommendations from the MSA Committee in October 2024, the UK Government’s Transparency in Supply Chains Guidance has been republished.  

The amends within this guidance provide clarity to businesses on how the government expects them to continually, and proactively, interrogate their supply chains to comply ‘with the spirit’ of modern slavery reporting (as mandated by section 54 of the MSA).  

In particular, the new guidance suggests that there are two key international frameworks that businesses should use to examine the risk of modern slavery in their business – these are frameworks from the OECD and the UN. 

Further, the changes signpost six recommended areas where significant detail should be provided on in businesses’ modern slavery statements. These areas are; organisational structure, organisational policies, the assessment and management of risk, due diligence, training, and, monitoring and evaluation. Read the full update on these areas in the employment law timetable.   

Equality law - call for evidence  

As part of a series of consultations that are running alongside the development of the Plan to Make Work Pay, the UK Government have published a call for evidence on equality rights.  

A call for evidence acts as a means for government to gather information that can guide decision making and potentially contribute to amendments to legislation. In this instance, the call for evidence is seeking views on: 

• How frequently organisations and individuals are seeing differences in pay in relation to race and disability.
• The proposed extension of the right to equal pay for ethnic minority and disabled people.
• What measures may ensure that organisations do not outsource services to avoid paying equal pay.
• How equal pay enforcement could improve via an Equal Pay Regulatory and Enforcement Unit.
• Recommendations and insights to improve pay transparency.
• How protection against combined discrimination may be actioned (combined discrimination meaning discrimination of multiple protected characteristics. Currently someone can only bring a claim based on discrimination of one characteristic. This can create issues where there has been less favourable treatment because of a combination of two characteristics. Therefore, if a claimant was allowed to present multiple characteristics together in a claim, the combined power of this evidence may make the claim more likely to succeed).
• How all parties that perform public functions can meet the Public Sector Equality Duty.
• How workplaces and working conditions can be free from sexual harassment – this is in relation to the preventative duty on employers, includes third parties, to take steps to ensure that the risk of sexual harassment is reduced (a duty in place since October 2024). The government is looking for examples (supported by clear evidence) of proportionate actions, or steps, to prevent workplace sexual harassment.
• How the socio-economic duty in England can start. 

If you wish to submit responses to this call for evidence, they must be logged here, before 11.59pm BST on 30 June 2025.

Please note that a seperate call for evidence on mandatory ethnicity and disability pay reporting for larger employers is running until 10 June 2025. 

Tribunal outcomes to consider 

Practitioners may want to consider the outcomes of the following tribunals:  

In Sullivan v Isle of Wight Council [2025] the appellant, Phyllis Sullivan, questioned whether lack of protection from whistleblowing for job applicants (other than those applying for jobs in the NHS) impinges on peoples’ freedom of speech. As a result of the case, the Court of Appeal confirmed that it does not impinge on freedom of expression for job applicants to not have this right as “the position of someone seeking work is materially different from someone in work”. Read the case report on People Management.  

People practitioners may wish to review their organisation’s dismissal policy and training in light of the Court of Appeal’s ruling in Hewston v Ofsted [2025] in mid March . Here, the court held that an employment tribunal had been wrong to find that a school inspector's dismissal for a single incident of physical contact with a pupil during a school visit was fair, as there was no clear written policy or any training on the matter.   

An earlier tribunal ruling may also be worth noting. In Ms A Pereira v Wellington Antiques Ltd and J M Wellington [2025], as part of a series of claims, the tribunal found that “inherently sexist” remarks about the claimant were linked to the “outdated idea that men are the main breadwinners in a house”. Practitioners may want to read through the tribunal’s findings and, in particular the section ‘Harassment related to race and/or sex’. People professionals and managers can review examples of behaviours that are recognised to be forms of sexual harassment if they wish to check organisational policies.