Supply Chain · Track A · Assessment

Forced labour due diligence

Risk assessment, traceability review and evidence files for EU Forced Labour Regulation and US UFLPA exposure across your supply base.

Who this is for

  • EU importers and brands ahead of December 2027
  • US importers exposed to UFLPA detentions
  • Suppliers asked by buyers to prove their raw material origin
  • Companies with migrant workers in their supply chain

How this fits our independence policy

This is assessment work. If we assess you against a standard, we will not also implement it for you. That keeps the result credible with buyers, assurers and certifiers.

Our independence policy

What we do

  1. Map riskProducts, materials, countries and suppliers ranked by forced labour risk.
  2. Trace the supply chainFollow high-risk products back to raw material with documents.
  3. Screen suppliersQuestionnaires and documentary checks on recruitment and employment practices.
  4. Verify on siteWorker interviews and record checks against the ILO indicators of forced labour.
  5. Build the evidence fileA file your customs broker, buyer or authority can review.

What you receive

  • A forced labour risk map
  • Traceability documentation for high-risk products
  • Supplier screening results
  • On-site verification reports
  • An evidence file per product line
  • A due diligence procedure for ongoing use

Standards and frameworks referenced

  • EU Forced Labour Regulation
  • US UFLPA and Section 307
  • ILO indicators of forced labour

Decisions on detentions and market bans are made by the authorities. We build the evidence you present to them.

Last verified: 2 October 2026

Typical sequence

Every engagement is planned around your deadline. You receive a dated plan with the written scope.

  1. Risk map
  2. Trace
  3. Screen
  4. Verify
  5. Evidence

Related services

Second-party supplier social assessment

Assessment of your suppliers against your own code of conduct, with consistent methodology and reporting across all your sourcing markets.

Service details

Recruitment fee remediation

Migrant worker recruitment fee assessment, repayment programme design and Employer Pays Principle implementation across Southeast Asia.

Service details

Worker grievance mechanism — build and operate

Design, launch and ongoing operation of an independent grievance channel — independence is easier to demonstrate when the channel is outsourced.

Service details

Where we deliver

  • India
  • China
  • Indonesia
  • Malaysia
  • European Union
  • United States

Frequently asked questions

When does the EU Forced Labour Regulation apply?

From 14 December 2027. It has no company size threshold and covers the whole lifecycle from raw material.

Does it apply to non-EU suppliers?

Yes. It applies to products placed on or exported from the EU market, wherever they were made.

What does UFLPA require?

Goods with a Xinjiang nexus face a rebuttable presumption of forced labour. Importers need traceability evidence to clear a detention.

What are the ILO indicators of forced labour?

Eleven indicators, including deception, restriction of movement, withholding of wages, retention of identity documents and debt bondage.

Request a scoping call

Tell us your sites, markets and deadline. We reply with a written scope.