PPN 05/21: Human Rights in Public Procurement — What It Means for UK Suppliers

Why human rights due diligence is no longer optional and how suppliers can prepare

Public procurement in the UK is undergoing a significant shift. While environmental impact and social value have moved firmly into the mainstream of tender evaluation, ethical supply chain management and human rights compliance are rapidly becoming areas of heightened scrutiny.

PPN 05/21 – “Taking Account of Social Value in the Award of Central Government Contracts” reinforces the government’s commitment to ensuring suppliers demonstrate responsible business practices, including control of human rights risks across their operations and supply chains.

Although originally positioned within the Social Value Model, PPN 05/21 now interacts closely with the Procurement Act 2023, Modern Slavery Act 2015, and PPN 02/23 (Tackling Modern Slavery) — creating increasing expectations for organisations bidding for public sector contracts.

This article outlines what suppliers need to know and how to respond.

1. What PPN 05/21 Actually Requires

PPN 05/21 places human rights considerations under the “Fighting Economic Crime” and “Wellbeing” themes of the Social Value Model. Authorities are encouraged to evaluate how suppliers:

• Prevent labour exploitation

• Protect workers’ rights

• Promote fair pay and working conditions

• Address modern slavery risks

• Ensure responsible practices throughout their supply chain

While not all contracting authorities use the full Social Value Model, the principles of PPN 05/21 have become standard practice.

Suppliers must therefore demonstrate credible, proportionate, and evidence-based human rights due diligence, even for contracts where social value weighting is relatively low.

2. Why Human Rights Now Matters More Than Ever

Several legal and policy developments have created a sharper focus on human rights:

• The Procurement Act 2023 emphasises risk, governance, and accountability

Authorities are now required to consider supplier suitability, ethical practices, and contract delivery risk.

• Increasing pressure on contracting authorities to ensure ethical supply chains

Local authorities, NHS bodies, and central government departments all face reputational and compliance risks.

• Public expectations have changed

There is greater awareness of labour exploitation, global supply chain risks, and the ethical responsibilities of public bodies.

• Buyers are tightening requirements in light of geopolitical pressures

Issues such as forced labour allegations, supply shortages, and international trade risks have increased scrutiny.

The message is clear:
Ethical business practices are no longer optional — they are a foundation of procurement compliance.

3. What This Means for Suppliers (Practical Implications)

3.1 You must demonstrate clear human rights governance

Authorities expect to see:

• A documented ethical sourcing or human rights policy

• Supply chain risk assessments

• Defined roles and responsibilities

• Whistleblowing procedures

• Modern Slavery statements (where legally required)

• Evidence of due diligence processes

Without this, suppliers risk losing points or being deemed too high-risk.

3.2 You will be asked to evidence your supply chain controls

Typical questions include:

• How do you assess high-risk suppliers?

• What checks do you perform before onboarding suppliers?

• How do you monitor ongoing compliance?

• How do you ensure fair working conditions?

• How do you respond to ethical breaches?

“Policy only” answers will no longer be enough — buyers want evidence of action.

3.3 Suppliers must train their workforce

Evidence that staff understand human rights risks is increasingly expected.
Training may include:

• Modern slavery awareness

• Ethical procurement and sourcing

• Whistleblowing and reporting mechanisms

Training records are becoming standard supporting evidence.

3.4 SMEs are not exempt — but expectations are proportionate

Authorities understand SMEs have smaller supply chains.
However, they still expect:

• Awareness of human rights risks

• At least basic due diligence

• A commitment to continuous improvement

• Clear processes for reporting concerns

Human rights compliance is now part of being “public-contract ready”.

3.5 “High-risk industries” face deeper scrutiny

These sectors are receiving heightened attention from contracting authorities:

• Construction and FM

• Logistics and warehousing

• Cleaning and security

• Manufacturing

• Social care

• ICT hardware supply

Suppliers in these industries should prepare enhanced documentation.

4. What Good Practice Looks Like

Authorities increasingly expect suppliers to show credible maturity in human rights due diligence. Good practice includes:

1. A human rights policy aligned to the UN Guiding Principles

Clear commitments, adapted to your organisational size and sector.

2. Supply chain mapping and risk categorisation

Identifying where labour violations are most likely to occur.

3. Documented due diligence procedures

How suppliers are screened, onboarded, and monitored.

4. Clear escalation and incident response procedures

Including corrective action plans.

5. Transparent reporting

Buyers prefer suppliers who can demonstrate previous audits, improvements, or interventions.

6. Integration into your social value offer

Human rights activities now contribute to your social value score.

5. The Competitive Advantage for Proactive Suppliers

Suppliers who invest early in human rights controls gain:

• Higher social value scores

• Better evaluation outcomes under the Procurement Act 2023

• Stronger relationships with primes and tier-1 contractors

• Reduced reputational and operational risk

• A more sustainable workforce and supply chain

Human rights is not just a compliance obligation — it is a commercial opportunity.

6. How Suppliers Can Prepare Now

1. Develop or refresh your ethical sourcing and human rights policy

Keep it simple, practical, and proportionate to your business size.

2. Train your staff

Especially procurement, HR, operations, and supervisors.

3. Map your supply chain

Identify high-risk suppliers, categories, or geographies.

4. Document your due diligence steps

Even basic documentation is better than none.

5. Strengthen whistleblowing and reporting

Ensure staff know how to raise concerns confidentially.

6. Prepare evidence ahead of bidding

Authorities increasingly expect you to submit evidence with your tender.

Final Thought

PPN 05/21 signals a clear direction of travel:
Human rights due diligence is becoming a standard expectation for all suppliers, not just large corporations.

In the new UK procurement landscape, suppliers who can demonstrate ethical practices, credible governance, and transparent supply chain controls will stand out — and will be significantly better positioned to succeed in public sector competitions.

Human rights is no longer just a policy chapter.
It is a core part of what it means to be a responsible, contract-ready supplier.