Modern slavery · Methodology

How we surface forced labour past tier 1.

A six-stage methodology for detecting modern slavery indicators in deep-tier supply chains. Aligned to ILO Indicators of Forced Labour, the UN Guiding Principles on Business and Human Rights, OECD Due Diligence Guidance, and the Palermo Protocol. Used by procurement, ESG and compliance teams in supplement to statutory due diligence.

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The six stages

From declared supplier list to tier-3+ visibility.

Tier 1 visibility is mandated. Tier 3 and below — where forced labour predominantly occurs — is rarely reached by traditional audit. Our methodology closes that gap.

i.

Scoping & risk profiling.

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 · ~10–25 priority supplier lines.

ii.

Tier mapping beyond declared.

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.

iii.

Worker-voice & testimony channels.

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.

iv.

Open-source & technical signals.

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.

v.

Findings, validation & remediation pathway.

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.

vi.

Disclosure & ongoing monitoring.

We support the buyer's Modern Slavery Act statement (Australia / UK) and EU CSDDD-aligned disclosure 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.

Frameworks we align to

The standards we work to.

Our methodology is not novel for novelty's sake. It implements established international frameworks rigorously, in deep tiers where they typically aren't reached.

ILO

11 Indicators of Forced Labour

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.

UN

UN Guiding Principles (UNGPs)

The corporate-responsibility-to-respect framework that defines due diligence, remediation, and access to remedy. Particular attention to Principle 17 (HRDD) and Principle 31 (effectiveness criteria for grievance mechanisms).

OECD

Due Diligence Guidance

Sector-specific OECD guidance (garments, minerals, agriculture) provides the severity-and-scope test we use to triage findings into engage / escalate / disengage tracks.

UN

Palermo Protocol

The international legal definition of trafficking in persons — used to distinguish forced labour, debt bondage, and trafficking-in-persons indicators where they overlap.

AU / UK

Modern Slavery Acts

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.

EU

CSDDD-aligned

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.

Operating principles

What this work is, and isn't.

  • We supplement, not replace, statutory due diligence. Our work informs and strengthens your obligation; it does not discharge it.
  • We are not the auditor of record. We do not certify suppliers compliant. We surface findings; your compliance and procurement function acts.
  • We do not take fees from suppliers we investigate. Independence is contractual and disclosed in every engagement.
  • Worker-voice channels are independent of supplier management. Survivors and worker advisors review their design before deployment.
  • We do not "name-and-shame" without disclosure pathways. Findings are delivered to the buyer with a remediation pathway. Public disclosure is the buyer's call, supported by our documentation.
  • Severity over volume. We surface fewer findings, validated rigorously, with clear remediation tracks — not long lists of low-confidence flags.
Methodology PDF

Read the full methodology document.

The 16-page methodology document covers each stage in detail, includes worked examples, sample worker-voice protocols, and the full indicator-mapping schema. Available on request to qualifying compliance, ESG, procurement, and academic readers.