Your code of conduct, forbidding forced labour, is signed. An assessment came back with no risk concerns. And still, something feels incomplete — because you know this doesn’t tell you what’s actually happening on the factory floor or at their (unauthorized) subcontractors.

That’s not a failing on your part. It’s the (unfortunate) reality of international supply chains. Forced labour hides in places that standard compliance systems (usually) don’t find. And with the EU Forced Labour Regulation (FLR) applying from 14 December 2027, the expectation is no longer that you’ve documented your efforts — it’s that you’ve genuinely understood the risk and acted on it. In other words, you have done your human rights due diligence. This article will help you do just that: take first steps at building a forced labour due diligence system that goes beyond paperwork. Every company starts somewhere different. The steps below are suggestions, not a checklist you need to complete in order — use what’s most relevant to where you are.

Why this matters

Under the Forced Labour Regulation, authorities will assess companies’ due diligence systems before deciding whether to open a full investigation (Art. 17 FLR). If authorities find substantiated evidence that a product was made with forced labour, your products can be detained or even destroyed (Art. 20(4) and 25 FLR). That’s a concrete business argument for getting this right — not just an ethical one.

Step 1 — Start with a policy that means something

Some companies have a forced labour policy. Few have one that tells anyone what to actually do. A useful policy explicitly names the 11 ILO indicators, as they provide a concrete reference point and are anchored in EU law (Art 2(1) FLR). Examples include debt bondage, retention of identity documents, deceptive recruitment, and coerced overtime. It also needs to assign responsibility beyond the CSR team, and include a code of conduct that commits the buyer as much as the supplier (also known as a two-way code of conduct). Ideally, all of this is supplemented by responsible contracting to solidify it legally.

→ Your next step: If your company doesn’t have a forced labour policy yet, a useful starting point is to open your existing supplier code of conduct and check whether it names any of the 11 ILO indicators. If it doesn’t name a single one, that’s your first gap — and something concrete you can bring to a meeting this week.

Step 2 — Map the risk, beyond Tier 1

You can’t address what you can’t see. If you don’t have full traceability yet, it is important to start mapping your full supply chain, including deeper tiers, as the Forced Labour Regulation is product-based and applies to your whole supply chain (Art. 2(6) and 3 FLR). Pay particular attention to choke points: traders or processors who may sit between you and deeper tiers and control what information reaches you. Desk research based on country and product category helps prioritise, but it must be followed by on-the-ground verification. For example, confidential worker interviews conducted in collaboration with local trade unions or civil society organisations consistently surface issues that documentation alone will not reveal.

→ Your next step: Pick one product. List every supplier involved in producing it that you know of. Mark where your visibility ends. That’s where to focus next.

Step 3 — Act on root causes, not symptoms

Step 3, to cease, prevent, or mitigate forced labour, is often the most challenging part. Let’s take an example of excessive overtime, one of the 11 ILO indicators for forced labour. A corrective action plan (CAP) is sent. Overtime decreases. Six months later, it’s back. Because the overtime was driven by piece rates that made legal working hours financially impossible for workers. The symptom was addressed; the cause wasn’t. Been there.

My suggestion? Before designing any corrective action, do a root cause analysis involving factory management and workers to identify what is actually going on. One simple method is asking “why” five times. This step also means examining your own purchasing practices. Unrealistic delivery timelines and prices that don’t allow for decent wages are part of the system that creates the conditions for exploitation.

→ Your next step: For one forced labour indicator risk in your supply chain, ask “why” five times before proposing a solution. Does the root cause involve anything your company does?

Step 4 — Build a monitoring system, not a paper trail

Companies are required to track whether the measures they have taken are adequate and effective, and whether new risks have arisen (Art. 15 CSDDD, as amended, 2026). A solid internal system and effective CAPs are of importance here. Even more important are worker-led monitoring systems, especially in hidden cases such as forced labour. These systems allow workers to report on working conditions directly and anonymously, giving you regular updates on the situation on the ground and the ability to track how circumstances are changing.

→ Your next step: Find out what worker-led monitoring tools exist in the countries you source from. Pick one that seems like a good fit for you and send them an email.

Step 5 — Communicate honestly, even when it’s uncomfortable

Transparency builds trust and gives external stakeholders the insights needed to help you improve your due diligence system (in addition to being a formal requirement (art. 16 CSDDD)). Publish your forced labour policy, your risk identification approach, your grievance mechanisms and other related documents that you have. When a case is under investigation, communicate promptly with worker representatives and keep public communication focused on actions taken rather than on details that could identify individuals.

→ Your next step: Is your forced labour policy publicly available? If not, that’s a place to start. Make sure it is also accessible and understandable for the workers in your supply chain.

Step 6 — Set up effective grievance channels

What if a worker signals that identification documents are being held by management or that new colleagues are hired via deceptive recruitment, and wants to flag these forced labour indicators? They would need to know where to go. What channels exist, and trust that it’s safe. There should be a functional grievance mechanism at the factory level, one that your company sets up or as part of a multistakeholder initiative. And of course, for this to be effective, the worker must be able to recognize these indicators as signs of forced labour. Investing in workers’ knowledge is therefore essential.

→ Your next step: Could a worker at your key supplier’s factory tell you today how to raise a concern? If you’re not sure, that’s the question to ask on your next supplier visit.

Next Steps: Start Today

Building this kind of system takes time, and knowing where to start isn’t always obvious. Hopefully, one of the suggested actions above has sparked your inspiration. Don’t want to do it alone? I’d be glad to think it through with you. Feel free to reach out.

Sources and further reading

• EU Forced Labour Regulation (Regulation 2024/3015): eur-lex.europa.eu
• ILO Indicators on Forced Labour – Revised Edition (2025): ilo.org
• Corporate Sustainability Due Diligence Directive (CSDDD, Directive 2024/1760): eur-lex.europa.eu
• CSDDD as amended by Omnibus I (Directive 2026/470): eur-lex.europa.eu
• ILO Convention No. 29 on Forced Labour (1930): ilo.org
• ILO Convention No. 105 on the Abolition of Forced Labour (1957): ilo.org
• UN Guiding Principles on Business and Human Rights (2011): ohchr.org
• OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (2023): oecd.org