Only 14 percent of firms can show due diligence works

What the survey found

Source: Kumi Consulting, 17 September 2026.

The Kumi Responsible Sourcing Barometer 2026 is an independent industry survey of 110 medium-to-large enterprises across 13 industries, published by Kumi Consulting on 17 September 2026. The Barometer is a confidential cross-industry benchmarking survey drawing on confidential insights rather than public reporting. Only 14 percent of companies can point to clear improvements resulting from their responsible sourcing activities. Less than one in five, 19 percent, measure outcomes for workers or the environment. A quarter, 25 percent, do not measure programme impact at all. Less than one in ten companies, 9 percent, seek feedback from stakeholders such as workers when assessing the effectiveness of their responsible supply chain programmes.

On governance, nearly half, 46 percent, have board-level oversight of responsible sourcing and 77 percent assign accountability to a senior executive. The structures exist without the evidence. A company can have a named executive owner and a board committee while still being unable to show what changed for a worker or for the environment as a result of its programme. The survey suggests that the machinery of accountability is more widespread than the measurement of outcomes. For a UK finance director, that distinction matters because the published statement and the internal governance can both look complete while the underlying evidence base remains thin.

The gap that matters

Around half of those surveyed state labour and human rights issues as their biggest risk. Yet nearly a quarter, 24 percent, have mapped only direct suppliers or have not mapped their supply chains at all. Among companies identifying forced or child labour among their most serious risks, more than a third, 36 percent, conduct no due diligence beyond their direct suppliers. Kumi's point is that resources are not going where the risk is. The companies that name the most serious labour risks are, in a significant proportion of cases, not looking past Tier 1. That is the layer where the risk is often least visible and where the commercial exposure to a customer's own due diligence is greatest.

Supplier capability is identified as the biggest barrier to progress, but only 15 percent of companies prioritise building supplier capability. 32 percent typically require suppliers to implement corrective actions without providing additional support. The report warns that this turns corrective action into transferring responsibility. A supplier asked to fix a problem without support may respond by documenting a fix rather than changing a practice. For a UK business, the practical consequence is that a corrective action request can create a paper trail that looks like progress without changing the underlying condition. The survey does not settle whether that pattern reflects a lack of resources, a lack of leverage, or a lack of measurement.

KT: what UK law already requires

Section 54 of the Modern Slavery Act 2015 requires commercial organisations supplying goods or services with a total turnover of 36 million pounds or more to prepare a slavery and human trafficking statement for each financial year. A modern slavery statement must be approved by the board and signed by a director, and published with a prominent link on the organisation's homepage. The UK government operates a modern slavery statement registry. The Act does not prescribe the content of the statement, only that it is published. That is why activity can run ahead of evidence without breaching the requirement. A company can publish a statement that describes a programme, a policy, and a governance structure without stating what changed as a result.

Companies also face section 172 of the Companies Act 2006, which requires directors to have regard to the impact of the company's operations on the community and the environment. For larger firms, the Streamlined Energy and Carbon Reporting requirements apply. UK suppliers to European customers are increasingly asked for evidence under the EU's corporate sustainability due diligence regime, which is enforced on their customers rather than on them. The enforcement route for a UK supplier is therefore commercial rather than regulatory: a European customer subject to the regime may pass the evidence requirement down the chain as a condition of doing business.

Why a finance director should care now

The commercial exposure is procurement rather than prosecution: losing a contract because a customer's own due diligence requires evidence you cannot produce. Andrew Britton, CEO of Kumi Consulting and one of the principal authors, said: 'The question is no longer whether companies are doing due diligence. The question is whether it is delivering results.' He adds that there are serious regulatory compliance and commercial risks related to responsible sourcing. For a UK business, the practical test is whether the company can show, on request from a customer or an investor, what changed as a result of its programme rather than what it spent.

That test is harder to pass than a statement requirement because it depends on evidence that sits outside the finance function: supplier records, worker feedback, and outcome measures. The survey's finding that 9 percent seek feedback from stakeholders such as workers is relevant here, because worker feedback is one of the few direct sources of evidence about whether a programme changed anything. A finance director preparing for a customer request may find that the company can produce a policy, a board minute, and a published statement, but not a record of what changed. The gap between those two positions is the gap the Barometer describes.

What the report does not settle

The survey is confidential and self-reported, from companies willing to take part in a benchmarking exercise, which tends to over-represent the more engaged. It gives no breakdown by industry or company size in the summary. It is published by a consultancy that sells responsible sourcing advice, which is worth stating plainly when quoting the figures. Kumi Consulting is an independent management consultancy specialising in responsible business conduct in global supply chains, working in mining and metals, energy, infrastructure, agriculture, manufacturing, consumer goods and fashion. It has also established the Kumi Foundation, a UK-registered charity.

The figures should therefore be read as a picture of a self-selected group rather than of UK business as a whole. The direction of travel is still useful for a finance director: the companies most likely to be asked for evidence by customers are the ones most likely to appear in a survey of this kind. The report does not settle whether the 14 percent figure reflects a lack of measurement, a lack of results, or a lack of willingness to report results that exist. Media enquiries can be directed to sasha.ragan@kumiconsulting.co.uk or +44 (0)20 3637 4440.

Source: Modern Slavery Act 2015, section 54.

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Frequently asked questions

What does the Kumi Responsible Sourcing Barometer 2026 measure?

It is an independent industry survey of 110 medium-to-large enterprises across 13 industries, published on 17 September 2026. It is a confidential cross-industry benchmarking survey drawing on confidential insights rather than public reporting. It measures responsible sourcing activity, governance, measurement, supply chain mapping, and supplier capability.

How many companies can show clear improvements from responsible sourcing?

Only 14 percent of companies can point to clear improvements resulting from their responsible sourcing activities.

What does UK law already require on modern slavery statements?

Section 54 of the Modern Slavery Act 2015 requires commercial organisations supplying goods or services with a total turnover of 36 million pounds or more to prepare a slavery and human trafficking statement for each financial year. It must be approved by the board and signed by a director, and published with a prominent link on the organisation's homepage. The UK government operates a modern slavery statement registry. The Act does not prescribe the content of the statement, only that it is published.

Who published the Barometer and do they sell responsible sourcing advice?

Kumi Consulting published the Barometer. Kumi Consulting is an independent management consultancy specialising in responsible business conduct in global supply chains. It sells responsible sourcing advice, which is worth stating plainly when quoting the figures.

What did Andrew Britton of Kumi Consulting say?

Andrew Britton, CEO of Kumi Consulting and one of the principal authors, said: 'The question is no longer whether companies are doing due diligence. The question is whether it is delivering results.' He adds that there are serious regulatory compliance and commercial risks related to responsible sourcing.