Modern-day Slavery and Forced Labour

Business Case

Brand reputation

A strong forced labour prevention programme protects a company’s brand value by mitigating the risk of NGO campaigns and media scrutiny, while supporting employee retention and maintaining attractiveness to prospective talent who value ethical operations.

Financial resilience

Investing in forced labour prevention can allow companies to avoid the significant financial consequences of consumer boycotts and investor divestment, including loss of sales and remediation costs, while also benefiting from the growing trend of investors applying ESG criteria that reward businesses with clean and transparent supply chains through a lower cost of capital.

Legal and regulatory compliance

With modern slavery legislation expanding, companies that have already established comprehensive due diligence and reporting programmes are positioned ahead of these mandatory requirements, thereby avoiding the significant penalties and supply disruptions associated with non-compliance.

Operational continuity

By establishing due diligence systems, companies can avoid the severe operational disruptions that occur when responding to forced labour findings after the fact, which often requires terminating supplier contracts, relocating sourcing at short notice and dedicating significant internal resources to investigation and remediation.

Strategy & Planning

Assessment

Initial Action

Identify priority product types, products, product components, focus regions or supplier sites and/or operations located in high-risk regions and map upstream supply chain actors involved, collecting data on:

  • trends on prevalent migrant, temporary or agency-supplied labour
  • trends on subcontracting and informal labour arrangements
  • presence of vulnerable worker populations (migrants, refugees, minorities)
  • local regulatory environments
  • recruitment corridors and labour intermediaries
Intermediate Progress

For selected product(s), conduct a risk assessment annually or as appropriate to categorize and prioritize suppliers by forced labour risk level, based on factors such as:

  • sector (prevalence or higher risk of forced labour)
  • rule of law (strength of local regulatory enforcement, rule of law and regulatory shifts)
  • supply chain visibility and long value chains
  • geography (presence of conflict-affected, poverty, high-risk areas, migration trends)
  • labour market structure (single / small number of industries, seasonal or short term contracts, low skilled workers, work permits for migrant workers)
  • new audit findings and worker‑voice data
Advanced Practice

Identify gaps in forced labour monitoring across high-risk supplier portfolio, develop action plans to address unmonitored categories, regions or supplier groups and initiate process of TierX screening of forced labour risk, along the value chain.

Policy

Initial Action

Establish a zero-tolerance policy on forced labour, modern slavery, human trafficking and debt bondage and embed this in the supplier code of conduct, covering the ILO 11 indicators of forced labour, such as:

  • prohibition of all forms of forced, bonded and compulsory labour
  • freedom of workers to terminate employment with reasonable notice
  • prohibition of retention of identity documents or personal belongings
  • prohibition of charging recruitment fees to workers (Employer Pays Principle)
Intermediate Progress

Integrate forced labour risk criteria into sourcing decisions and into supplier audit protocols for high-risk categories, requiring enhanced due diligence on forced labour as a condition of supplier approval or contract renewal with mandated due‑diligence quality criteria, such as independent verification of recruitment practices.

For existing suppliers, while focusing on remediation before termination decisions are made, establish a forced labour escalation protocol with defined consequences and triggers such as:

  • verified forced‑labour indicators
  • retention of documents
  • recruitment‑fee charging
  • blocked worker mobility
Advanced Practice

Require strategic suppliers to implement their own forced labour zero tolerance policies and due diligence processes, cascading forced labour prevention requirements to their suppliers with clear consequences for violations of policies.

Targets

Initial Action

Set targets on percentage of procurement spend covered by forced labour risk screening.

Intermediate Progress

Set targets for percentage of suppliers in high-risk categories assessed on forced labour risk.

Advanced Practice

Set multi‑year outcome‑oriented targets for percentage of high-risk suppliers with verified responsible recruitment practices in place.

Supplier Selection

Screening

Initial Action

Screen potential suppliers for forced labour risk factors by adding forced labour-related questions to supplier pre-qualification and RFPs:

  • zero-tolerance policy on forced labour, bonded labour and human trafficking
  • use of labour agencies or subcontracted labour
  • whether recruitment fees are charged to workers and whether there is a process to identify, repay and prevent such fees
  • retention of identity documents
  • provision of written employment contracts and whether these contracts are written in a language the workers understand
Intermediate Progress

Request evidence of forced labour prevention practices in supplier pre-qualification and RFPs:

  • due diligence records on labour agencies and recruiters used
  • third party audit results
  • sample employment contracts
  • evidence of grievance mechanism accessible to all workers
  • records of any incidents and corrective actions taken
Advanced Practice

Require suppliers to submit the following as a prerequisite to apply for RFP:

  • forced labour due diligence policy covering their own supply chain
  • evidence of monitoring and audit processes beyond their own operations
  • remediation protocols and records of corrective actions at their supplier level
  • documentation of how forced labour prevention requirements are cascaded to their own suppliers
  • disclosure of any forced labour incidents identified across their supply chain in the past 3 years
  • independent verification of labour‑agency due diligence, contract transparency and document‑retention compliance

Selection

Initial Action

Only select suppliers that confirm a zero-tolerance forced labour policy, commitment to the Employer Pays Principle and prohibition of document retention.

Intermediate Progress

Only select suppliers that have evidence of forced labour prevention measures, including responsible recruitment practices, as a condition of supplier approval or renewal.

Advanced Practice

Select suppliers that can demonstrate forced labour prevention measures not only in their own operations but across their own supplier base, with evidence of cascaded due diligence.

Contracts

Initial Action

Include specific clauses against forced labour in supplier contracts, covering prohibition of forced, bonded, and compulsory labour, the Employer Pays Principle, document retention, freedom to terminate employment, due diligence, mitigation and reporting of any identified cases; and require suppliers to notify buyer immediately of any identified or suspected cases.

Intermediate Progress

Include enforceable remediation protocols and right-to-audit clauses with defined consequences for non-compliance, including remediation obligations such as repayment of recruitment fees, restoration of documents, provision of back wages and safe return and reintegration.

Advanced Practice

Require suppliers to cascade contractual forced labour prevention clauses to their own suppliers, with suppliers taking responsibility for compliance across their own supply chains.

Supplier Engagement

Goal Setting

Initial Action

Set targets with suppliers to complete forced labour risk assessments of their operations within a defined timeframe.

Intermediate Progress

Set public goals with suppliers on specific strategies to strengthen forced labour prevention, such as implementing the Employer Pays Principle, conducting labour agency due diligence, formalizing employment contracts, or establishing effective worker grievance mechanisms.

Advanced Practice

Set public goals with Tier 1 suppliers on working with their suppliers (Tier 2 and 3) to ensure forced labour prevention measures are in place across the supply chain.

Capacity Building

Initial Action

Provide suppliers with guidance or training on forced labour prevention, including:

  • recognizing the ILO indicators of forced labour (debt bondage, document retention, restriction of movement, deception, intimidation, withholding of wages, abuse of vulnerability, excessive overtime, abusive working/living conditions)
  • understanding the Employer Pays Principle
  • international standards, responsible procurement practices, company policies
  • grievance mechanisms and remediation processes
  • case studies on effective forced labour prevention and remediation
Intermediate Progress

Provide in-depth training to suppliers, such as on the following topics:

  • conducting their own forced labour risk assessments and recruitment due diligence
  • vetting and monitoring labour agencies and recruiters
  • building internal monitoring and reporting systems for forced labour indicators
  • working with suppliers on forced labour prevention
Advanced Practice

Provide training on strategies to most effectively address root causes of forced labour, such as linking forced labour prevention to responsible recruitment programmes, worker empowerment initiatives, and supply chain transparency efforts like worker voice surveys to be implemented as triangulation mechanism.

Data

Initial Action

Request data from suppliers on:

  • number of migrant and agency-supplied workers in the workforce
  • number and nature of forced labour grievances received
  • remediation actions taken on any identified cases
Intermediate Progress

Work with suppliers to obtain the following data:

  • percentage of workers paid on time and in full, with no unauthorized deductions
  • grievance records related to working conditions, freedom of movement, or recruitment practices
  • progress on corrective action plans
Advanced Practice

Work with suppliers to develop integrated reporting systems that capture forced labour due diligence data across their own supply chains, including recruitment audit findings, incident data, tracking results of worker voice surveys, remediation outcomes, etc.

Advisory

Initial Action

Provide guidance to suppliers on how to implement forced labour prevention measures, such as responsible recruitment procedures, employment contract practices, whistle-blowing processes, and worker grievance mechanisms.

Intermediate Progress

Consult and work with suppliers on how to assess forced labour risks in their own supply chains, including screening their own suppliers and labour agencies.

Advanced Practice

Consult and work with suppliers in embedding forced labour due diligence and supplier engagement into their own procurement practices, including developing their own supplier codes, screening processes, worker voice surveys for their suppliers and engagement programmes on forced labour.

Financial Support

Initial Action

Fund supplier access to forced labour risk assessment tools, responsible recruitment resources and training materials.

Intermediate Progress

Provide commercial incentives to suppliers for improvements in forced labour prevention performance, such as price, volume, duration, and preferred supplier status.

Advanced Practice

Link commercial incentives (contract extensions, volume increases, pricing adjustments) to verified progress on eliminating forced labour risks across the supplier's own supply chain.

Audits

Initial Action

Require suppliers to complete self-assessment questionnaires on forced labour prevention policies and practices, covering recruitment practices, employment contracts, document retention, worker freedom of movement, grievance mechanisms and remediation.

Intermediate Progress

Conduct on-site assessments of suppliers in high-risk categories or sponsor verified third-party auditing, including triangulation, worker interviews (including off-site/in safe locations, discussions without management, and in workers' languages), unannounced or short-notice site visits, independent worker surveys, and verification that grievance mechanisms are functioning and accessible to all workers, with corrective action plans in place for any violations and actions identified for any risks.

Advanced Practice

Work with strategic suppliers to conduct their own supplier audits on child labour and share audit findings, including:

  • forced labour grievances recorded (number and nature)
  • audit findings on ILO forced labour indicators
  • progress on corrective action plans
  • worker interview findings, including off-site and in workers' languages
  • official inspection outcomes

Project Partnerships & Innovation

Initial Action

Launch pilot projects with suppliers in high-risk categories to establish confidential, independent worker voice channels such as anonymous hotlines or third-party worker interviews conducted off-site, to surface forced labour risks that may not be visible through standard audits or supplier self-reporting.

Intermediate Progress

Collaborate with suppliers on targeted interventions developed from pilot project findings, such as ethical recruitment corridor programmes, worker education initiatives on their rights, developing safe reporting mechanisms, etc.

Advanced Practice

Scale successful pilot interventions to additional suppliers or categories, partnering with NGOs, industry peers, or responsible recruitment initiatives to address systemic root causes of forced labour in shared supply chains.

Continuous Improvement

Metrics

Initial Action

Track the following:

  • percentage of procurement spend covered by forced labour risk screening
  • percentage of suppliers that have forced labour policy
  • number of suppliers that have completed self-assessment questionnaires
  • number of forced labour incidents reported by suppliers
  • number of suppliers receiving forced labour prevention training
Intermediate Progress

Track progress indicators such as:

  • percentage of suppliers with verified responsible recruitment practices
  • number and outcomes of on-site assessments conducted
  • corrective action plan completion rates
  • remediation outcomes for identified cases
Advanced Practice

Track indicators such as:

  • verified elimination of forced labour across direct and key upstream supply chain actors, including performance tracking for Tier 2 and Tier 3 suppliers
  • percentage of strategic suppliers conducting their own forced labour due diligence

Scorecards

Initial Action

Include forced labour compliance as a component in supplier scorecards, covering policy existence and execution, self-assessment completion and incident reporting.

Intermediate Progress

Weigh forced labour performance in supplier scorecards, incorporating audit findings, corrective action progress, training completion and prevention‑system maturity.

Advanced Practice

Weigh forced labour prevention performance in supplier scorecards, with top performers receiving preferential weighting in tenders and bottom performers required to submit improvement plans.

Impact Verification

Initial Action

Gather feedback from suppliers on effectiveness of engagement programmes.

Intermediate Progress

Assess whether supplier engagement initiatives are improving forced labour prevention outcomes, including using off‑site worker‑voice channels and independent worker interviews.

Advanced Practice

Measure improvement in forced labour prevention outcomes attributable to engagement programmes. For example, consider:

  • comparing incident rates and audit findings before and after interventions
  • tracking remediation outcomes and recurrence rates over time
  • improvements on results of independent verification for high‑risk suppliers through third‑party audits and off‑site worker interviews

Sources consulted

Child Labour Freedom of Association & Worker Voice