
Require 100% traceability for high‑risk manufacturing inputs within 12 months, confiscate goods immediately when forced labor is found, and terminate (fire) supplier contracts that fail independent verification.
Implement targeted measures at scale: commission independent third‑party audits for the top 1,000 suppliers across the five largest sourcing countries within six months; mandate randomized payroll sampling covering 100% of factory shifts; install multilingual worker grievance channels with guaranteed follow‑up within 72 hours. Publish full audit reports and remediation outcomes publicly to give procurement teams clear direction and allow civil society to find unresolved cases.
Require suppliers to disclose primary источник (source) and all sub‑tier flows for key commodities, and blacklist vendors that use exploitative recruitment practices. Set measurable KPIs: cut verified exploitative incidents by 50% within 18 months, close corrective actions within 30 days, and allocate 2% of annual procurement value to worker remediation and improvement programs. Strengthen regulations by aligning contracting terms with these KPIs and by enabling confiscation and criminal referral when audits find systemic abuse.
Adopt practical practices that move procurement ahead of risk: prioritize orders from factories with documented worker contracts and electronic payrolls; score suppliers on remediation progress and remove repeat offenders from bids. Require quarterly public reports, support capacity building at the factory level, and tie executive compensation to verifiable improvements in worker conditions to sustain change.
Start tracking implementation now–publish timelines, assign accountable leads, and deploy resources so that sourcing decisions reflect both compliance and human dignity across the manufacturing chain.
Transparency-Based Supply Chain Strategy to Detect and Remove Forced Labor
Mandating supplier-level transparency with clear enforcement: require monthly anonymized worker registers, payroll chains, and contract copies from all Tier 1 suppliers, and publish redacted audit outcomes within 30 days to spot and remove forced labor quickly.
- Mapping and data requirements
- Map 100% of Tier 1 sites and 60% of Tier 2 sites within 12 months; update map quarterly.
- Incorporate unique site IDs, geolocation, worker headcount, and recruiter records into a centralized database that evaluates risk by region and commodity.
- Use a Forced Labor Transparency Index that scores sites 0–100; scores below 60 trigger targeted auditing and below 40 trigger order suspension and remediation planning.
- Auditing cadence and methods
- Require regular third-party audits for 100% of Tier 1 sites every 3 months and for 30% of Tier 2 sites annually; add unannounced spot audits covering at least 10% of sites each quarter.
- Combine document review, worker interviews (minimum 8% sample or 30 workers, whichever larger), and payroll forensic analysis; auditors must be rotated to avoid familiarity bias.
- Publish audit methodology and auditor accreditation criteria so buyers and civil society can compare results globally.
- Worker-centred remediation and grievance
- Investing in independent, free grievance channels in local languages, with targets: 90% acknowledgement within 48 hours and resolution plan within 30 days.
- Provide immediate relief funds for displaced people and cover verified back wages within 60 days of a substantiated finding.
- Train middle managers and worker representatives in complaint handling; measure reductions in unresolved complaints quarter over quarter.
- Supplier incentives and penalties
- Tie 20% of procurement score to transparency index performance; share higher-margin contracts with suppliers scoring above 80 to reward compliance.
- Apply graduated penalties: corrective action plan for score 40–59, probation for 20–39, suspension for <20; enforce via contract clauses and withholding 5–15% of payment until remediation verified.
- Mandating supplier-funded capacity building for high-risk regions where poverty and pandemic-related debt spikes have increased vulnerability to forced labor.
- Data governance and public reporting
- Publish an annual transparency report with a supplier share breakdown by score band, remediation outcomes, and a risk heat map; update the interactive index monthly.
- Use open data standards and provide an API so downstream buyers, NGOs, and researchers can cross-check (источник: supplier self-assessments and audit firms).
- Ensure data privacy: aggregate public disclosures so worker identities stay protected while enabling civil society verification.
- Governance, KPIs and budgets
- Set board-level KPIs: reduce sites scoring <60 by 50% within 18 months and achieve 95% audit coverage for Tier 1 within 12 months; report progress quarterly to investors and the public.
- Allocate 0.5–1.5% of procurement spend to monitoring and remediation; companies that invest this range report reduced supply disruption and greater access to regulated markets.
- Appoint a senior manager who reports to the CEO and integrates transparency metrics into supplier management tools so the company is well-positioned to act on findings.
- Collaboration and scaling
- Share anonymized risk data with multi-stakeholder platforms to reduce duplicate audits and scale remediation funding; aim to reduce audit duplication by 40% within 12 months.
- Example: a consortium launched in March that pooled auditing results and reduced costs per audit by 25% while increasing detection rates by 30% across participating members.
- Coordinate with local governments and NGOs to target communities where poverty is highest; align transparency work with local social protection programs to deliver greater impact.
Metrics you must track monthly: number of sites audited, index median score, share of substantiated complaints, average remediation time, and percentage of suppliers meeting transparency thresholds. Transparency alone will not end forced labor; pair it with binding contracts, worker empowerment, and financial remediation to achieve measurable reductions.
Map upstream suppliers and high-risk commodities: step-by-step risk screening

Implement a four-step, 90-day risk screening: capture supplier and spend data, apply a weighted risk score, verify high-risk sites, and require targeted remediation. Set targets: 90% spend coverage at tier‑1 within 60 days, 50–70% at tier‑2 within 180 days, and immediate mapping of commodities above $100,000 annual spend that are known to carry high forced-labour risk (cotton, palm oil, seafood, mica, certain minerals, electronics components).
Collect standardised fields for every supplier and site: legal name, GPS coordinates, production activity, workforce size, share of migrant workers, third-party recruiters used, payroll samples for the last 12 months, subcontractor lists, shipment origin points and recent audits. Use open and commercial tools (Open Supply Hub, Sedex, Verisk Maplecroft, supplier portals) and require signed attestations; do not just rely on questionnaires. Combine these inputs into a single dataset to enable batch assessments and visual mapping.
Score each supplier and commodity with a transparent algorithm: commodity risk 40%, country/regulatory risk 25%, supplier governance 20% (policies, contracts, payroll), and human‑risk indicators 15% (recruitment fees, withheld documents, evidence of restricted movement). Flag scores >70 as high, 40–70 as medium, <40 as low. use several specific indicators: recruitment fees> 1 month’s wage, >20% migrant workforce, absence of written contracts, recent worker movement restrictions or mass hiring events. Treat any single indicator of violence, coercion or withheld identity documents as an immediate high‑risk trigger.
For high scores require direct, rapid verifications: on‑site visits within 30–90 days, unannounced inspections where safe, worker-centred interviews conducted by third‑party human-rights experts, payroll reconciliation and cross‑checks with social insurance data. Complement physical checks with remote assessments and supply‑chain forensics (shipping manifests, customs data). Watch for false documentation and patterns that allow manipulation; integrate anonymous worker reporting channels that allow safe disclosures.
Mandate remediation pathways tied to contracts: set three tiers of corrective action with timelines and measurable deliverables (immediate corrective action within 7 days for abuse, remediation plan within 30 days for systemic findings, and suspension or termination clauses for non-compliance after 90 days). Require meaningful remediation such as repayment of recruitment fees, rehiring or safe repatriation, strengthened grievance mechanisms and prevention training for supervisors. Document all measures and publish redacted summaries to protect workers while preserving reputations and buyer accountability.
Embed these processes in procurement governance: assign a cross-functional owner (procurement + human rights + legal), include KPIs in supplier scorecards, and run quarterly assessments that feed to the executive risk committee. Use automated alerts from monitoring tools to detect sudden movement of labour or shipment route changes throughout the network. Meanwhile, provide suppliers with technical support and templates for governance improvements so their remediation is realistic and verifiable.
Require supplier-level workforce records and direct worker contact channels
Mandate that every supplier maintain complete, person-level workforce records and provide at least two independent direct contact channels for workers, and require suppliers to meet time-bound targets: 100% of first-tier suppliers and 80% of upstream suppliers must comply within 12 months, and 100% of workers must have access to direct contact channels within 6 months.
Specify the exact elements of workforce records: worker name (or unique ID), date of birth, nationality, passport/ID type (hashed where privacy laws require), hire and termination dates, contract terms, wages and deductions by pay period, overtime hours, recruitment fees paid and by whom, recruiting agency name and license, worker-provided emergency contact, and grievance history. Retain records for at least five years and require suppliers to link those records to purchase orders and shipments so forced-labor indicators trigger before dispatch.
Prioritize measurable KPIs and regular reporting: measuring should include percent of suppliers with complete records, percent of workers with confirmed direct-contact access, average grievance response time (target <72 hours), percent of cases resolved within 30 days (target ≥90%), and reduction in worker-paid recruitment fees (target 0% within 24 months). Require quarterly submissions from suppliers and publish aggregated metrics for consumers, particularly for high-risk trade lanes.
Require multiple, confidential contact channels under supplier responsibility: a toll-free multilingual hotline, SMS/WhatsApp with end-to-end encryption, physical suggestion boxes accessible off-site, and an independent third-party reporting app. Do not rely on audits alone–conduct independent worker interviews covering at least 10% of site populations each quarter and corroborate findings with payroll and time records.
Regulate recruitment agencies and remedial measures: register all agencies used by suppliers, audit agency contracts for excessive fees or debt-bondage indicators, and ban retention of identity documents under any pretext. Enforce corrective action plans with financial penalties and suspension from orders for suppliers or agencies implicated in the worst practices. Align record templates with slcp tools and international convention standards to enable comparability across suppliers and support growing regulator and buyer expectations for transparency.
Protect privacy and ensure freedom from retaliation: encrypt stored data, limit access to authorized compliance staff and vetted auditors, require worker consent for data use, and implement anti-retaliation protocols with anonymous case escalation. Track remediation outcomes to show workers are free to leave abusive employment and to demonstrate concrete progress to stakeholders.
Deploy traceability tools (blockchain, unique IDs, batch tagging) to verify origin
Implement a blockchain-backed unique-ID and batch-tagging protocol immediately: assign UUID-prefixed IDs at source, anchor batch hashes on a public chain, and require RFID/QR scans at every handover to guarantee verifiable origin data.
Define what components involve: immutable ledger nodes, unique ID schema (site prefix + UUIDv4), batch tag hardware (QR, NFC, RFID), IoT readers, middleware for data normalization, off-chain storage with hash anchoring, and audit dashboards that connect devices to APIs and to the ledger.
At each facility, perform embedding of unique IDs into raw-material containers and finished-goods labels during collection. Capture supplier legal name, GPS coordinates, ISO lot number, production timestamp and photos; store large media off-chain and record SHA-256 hashes on-chain to protect tamper resistance and for identifying provenance during investigations.
Track transportation with GPS-enabled seals, time-stamped scan checkpoints, and automated exception rules so shipments stay traceable. Configure alerts for missed scans, require automated holds for anomalous routes, and log workplace safety checks to keep handlers accountable–ensuring chain-of-custody records comply with audit windows.
Require third-party verification and public disclosure to break opaque supplier networks and protect companys reputations. Require each corporation and large supplier above revenue thresholds to publish verifiable trace logs; reference australia’s Modern Slavery Act reporting expectations as a disclosure model. Use accredited auditors to assist in identifying noncompliance and to fight forced labor claims.
Set operational targets and KPIs: 100% origin tagging for high-risk SKUs within 12 months; 48-hour maximum data-upload latency; monthly physical inspections of 5% of batches; cryptographic retention of hashes for seven years. Track metrics (tag coverage, scan rate, mean time to reconcile) and report outcomes quarterly–the result is faster investigations, clearer remediation paths, and stronger supplier accountability.
Set procurement and contract clauses that eliminate incentives for forced labor
Require suppliers to prohibit recruitment and retention fees, and mandate documented repayment to affected people within 30 days; publish proof on a shared platform and verify via third-party audits.
Sample prohibition clause: “Supplier will not charge, directly or indirectly, recruitment, placement, document retention or border-related fees to any worker. If any worker reports fees, Supplier will repay 150% of the fees plus interest within 30 days and provide audited evidence to Buyer and applicable public databases.”
Embed measurable KPIs: annual risk assessments, unannounced audits for at least 10% of high-risk suppliers, remediation plans confirmed within 60 days, and contract termination if failing to remedy within 90 days. Hold back a last 10% of payment until compliance verification for new or high-risk contracts; increase holdback to 20% for sectors with documented problems (e.g., agriculture, fishing, construction).
Require supplier governance and improvement plans with a named, accountable officer, quarterly progress reports, and board-level sign-off for corrective action. Demand disclosure of worker source locations, recruitment agencies, and contract templates; keep recruitment and payroll retention records for five years and make summary data accessible to the buyer’s platform and public registries where legislation allows.
Use practical solutions: escrow or direct-to-worker wage channels so people get wages without intermediary diversion; mandatory return of identity documents at the workplace; immediate suspension of goods shipments if hazards to workers or environmental hazards are reported; and funding of independent remediation by the supplier when harm is confirmed.
Integrate a multilingual grievance platform with telephone, text and secure web channels, ensure non-retaliation protections, and connect complaints to audit trails and remediation databases. Cross-check supplier lists with government watchlists and open-source databases to identify source-level risks and what remediation has already occurred.
Specify contractual remedies: financial restitution formula, on-site corrective action budgets, third-party monitoring funded by the supplier, and debarment for repeat violations. Where local legislation allows, publish the entire list of audited suppliers and termination actions to increase accountability and to generate systemwide improvement.
Define remediation protocols: immediate protection, compensation, and supplier corrective plans
Require immediate protective measures for any worker identified as subjected to forced labor: secure shelter, medical care, independent legal counsel, and full wage restitution deposited to an escrow account within 14 days.
Create a standardized intake and evidence collection form that logs worker statement, photographic ID, medical records, pay stubs, bank transactions, and a designated contact field (sample placeholder name: steve). Maintain chain-of-custody for all documents and store encrypted backups to prevent tampering while enabling transparent review by authorized reviewers.
Calculate compensation using a clear formula: unpaid wages = documented hours × local statutory wage + overtime at 150% for hours over legal limits + documented benefits (health, social contributions) + a fixed relocation allowance where needed. Disburse 80% of verified back pay within 90 days and release remaining 20% after a 6-month post-remediation verification to confirm no retaliation or recurring coercion.
For immediate protection and reintegration, provide short-term cash assistance covering 60 days of basic living costs, paid medical bills, and job placement services. Require suppliers or buyers to fund temporary employment stipends and skills training to preserve the worker’s future employment prospects and benefits continuity.
Mandate supplier corrective action plans (SCAPs) that include: a) full supply chain mapping within 30 days to identify where goods or labor are sourced; b) risk-ranked remediation measures for each facility and subcontractor; c) capital and timeline commitments signed by senior governance at the supplier; d) independent monitoring and verification milestones at 30, 90, and 180 days. Require SCAPs from any supplier flagged in a major audit or credible NGO report.
Use third-party monitors and a neutral mediator acting between the affected worker and the supplier to resolve disputes, protect witness confidentiality, and evaluate impact on worker welfare. Engage local civil society and labor inspectors when mapping complex subcontracting chains across countries to reduce opportunities for suppliers to hide workers in informal facilities.
Require contract clauses that prohibit retention of identity documents, recruitment fee charging, and forced overtime; include sanctions up to suspension of orders and contract termination for verified breach. Ask investors to require these clauses as part of procurement governance and to condition financing on demonstrable remediation capacity.
| Action | Responsible actor | Timeline | Success metric |
|---|---|---|---|
| Immediate protection & intake | Buyer + local NGO | 0–14 days | Protection provided to 100% of identified cases; collection of required evidence |
| Compensation disbursement | Supplier escrow + independent verifier | 0–90 days (80%); remainder after 6 months | Verified back pay paid; benefits restored; no financial barriers to worker recovery |
| Supply chain mapping | Supplier + third-party auditor | 30 days | All facilities and subcontractors identified and risk-ranked |
| SCAP submission | Supplier governance | 30 days after mapping | Robust, budgeted SCAP with timelines and responsible leads |
| Independent verification audits | Third-party monitor | 30, 90, 180 days, then biannual | Reduction in forced labor indicators; evaluate impact on employment and benefits |
Require public reporting of remediation outcomes: number of cases, average payout, time to payment, and percentage of suppliers adopting SCAPs. Use those KPIs to measure reducing incidence across the organization and to allow investors to evaluate remediation performance. Track recurrence rates and worker re-employment outcomes to assess long-term impact.
Build contractual escalation: if a supplier fails to submit a verifiable SCAP within 30 days, buyers must suspend new orders to the facility and fund emergency relief for affected workers. Strengthen procurement governance by tying future contracts to verifiable remediation milestones to uphold buyer ability to enforce standards across countries and the wider industry.