A six stage methodology for detecting modern slavery indicators in deep tier supply chains. It is aligned to the International Labour Organization (ILO) Indicators of Forced Labour, the UN Guiding Principles on Business and Human Rights (UNGPs), OECD Due Diligence Guidance and the Palermo Protocol. Procurement, environmental, social and governance (ESG) and compliance teams use it to supplement statutory due diligence.
Download methodology PDFTier 1 visibility is mandated. Tier 3 and below, where forced labour predominantly occurs, is rarely reached by traditional audit. Our methodology closes that gap.
We start with the buyer's declared supplier list, sectoral risk profile (cotton, electronics, seafood, mica, palm, construction, garments), and geographies of concern. We benchmark against ILO global slavery prevalence data and Walk Free Global Slavery Index country risk weightings.
Output: Risk weighted shortlist · roughly 10 to 25 priority supplier lines.
For each priority line, we trace beyond declared tier 1 manufacturers using shipping records, customs filings, corporate registries and open source intelligence. We map suspected tier 2 (component / processing) and tier 3 (raw material / labour pool) nodes.
Output: Multi-tier supplier map · with confidence scoring per node.
We deploy multilingual, anonymous worker voice channels (mobile first, available in priority labour source languages). These are run independently of supplier management and aligned to UNGP Principle 31 effectiveness criteria. Survivor and worker advisors review communications design.
Output: Worker reported indicators · against the eleven ILO Indicators of Forced Labour.
We correlate documented worker testimony with open source signals: regulatory enforcement actions, NGO reporting, satellite imagery (e.g. dormitory clustering, transport patterns), and where available, anonymised connectivity and platform usage signals consistent with restricted movement.
Output: Cross-referenced indicator set · per supplier node.
Findings are validated against the ILO Indicator framework and OECD severity criteria, then triaged into remediation tracks (engagement, escalation, disengagement) per UNGP guidance. We do not act as auditor of record; we equip the buyer's compliance and procurement function to act, escalate, or disclose.
Output: Validated findings register · remediation pathway per finding.
We support the buyer's Modern Slavery Act statement (Australia / UK) and disclosure aligned to the EU Corporate Sustainability Due Diligence Directive (CSDDD), with evidence grade documentation. Ongoing monitoring is contracted as a separate engagement, with quarterly re-screens of the priority supplier set.
Output: Statement ready evidence pack · quarterly monitoring cadence.
Our methodology is not novel for novelty's sake. It implements established international frameworks rigorously, in deep tiers where they typically aren't reached.
The operational definition we test against: abuse of vulnerability, deception, restriction of movement, isolation, physical & sexual violence, intimidation & threats, retention of identity documents, withholding of wages, debt bondage, abusive working & living conditions, excessive overtime.
The framework for the corporate responsibility to respect human rights, which defines due diligence, remediation and access to remedy. We pay particular attention to Principle 17 (human rights due diligence, or HRDD) and Principle 31 (effectiveness criteria for grievance mechanisms).
Sector specific OECD guidance (garments, minerals, agriculture) provides the severity and scope test we use to triage findings into engage / escalate / disengage tracks.
The international legal definition of trafficking in persons, used to distinguish forced labour, debt bondage and trafficking in persons indicators where they overlap.
Statement ready outputs that meet the disclosure obligations of the Australian Modern Slavery Act 2018 and the UK Modern Slavery Act 2015, with evidence grade documentation.
Outputs designed to support the EU Corporate Sustainability Due Diligence Directive, including the requirement for HRDD across the chain of activities, not just direct suppliers.
The 16 page methodology document covers each stage in detail, with worked examples, sample worker voice protocols and the full indicator mapping schema. It is available on request to qualifying compliance, ESG, procurement and academic readers.