3. Supply chains and business duty
What good due diligence looks like
Due diligence means actively checking, rather than passively assuming, that the people who make, move, and deliver what you buy are working freely and fairly. Done well, it is proportionate to risk: you look hardest where the risk is highest.
Know your supply chain
You cannot manage what you have not mapped. Good practice starts with knowing who your direct suppliers are, and then asking who sits behind them. Risk usually increases with distance: the further down the chain, the less visibility you have, and the more likely labour is casual, subcontracted, or informal.
Ask suppliers real questions
A supplier questionnaire is only useful if the questions have teeth. Good questions include:
- Do you use labour agencies, and if so, which ones, and how do you vet them?
- How do you verify that your workers hold their own documents and bank accounts?
- Do workers pay any recruitment fees, and who checks?
- What is your process if a worker raises a concern about their treatment?
- Do you subcontract any of this work, and do the same standards apply?
Vague or defensive answers, or a refusal to answer at all, are findings in themselves.
Build it into contracts and reviews
Anti-slavery expectations belong in contracts, with the right to audit and the right to exit if serious problems are found and not fixed. Supplier reviews should revisit the questions periodically, not treat them as a one-off box ticked at onboarding.
Respond, don't just detect
If due diligence uncovers a problem, the goal is to protect the workers, not simply to drop the supplier and walk away, which can leave victims worse off. Good practice is to require remediation, work with the supplier where they engage honestly, and involve the appropriate authorities where a crime is suspected. Terminating the relationship is the right answer when a supplier will not change.
› Course contents
What modern slavery is
Spotting the signs
Supply chains and business duty
Responding safely