Coverage: Global
According to the ILO, forced labor, modern slavery and human trafficking “refers to situations in which persons are coerced to work through the use of violence or intimidation, or by more subtle means such as manipulated debt, retention of identity papers or threats of denunciation to immigration authorities.”
It typically encompasses four main offences:
- Slavery: when a person is under the control of another person who applies violence and force to maintain and exploit that control.
- Servitude: when a person is subjected, voluntarily or involuntarily, to another person as a servant.
- Forced/compulsory labor: extracting work or service from another under threat of penalty and against their will.
- Human trafficking: where a person arranges or facilitates the travel of another person with a view to that person being exploited.
Many products available on the market are made by, or include, ingredients grown, harvested or mined by people in slavery.
Our coverage of Human Trafficking and Slavery (HT&S) is limited to legislation that creates concrete obligations that manufacturers need to comply with, such as:
- Report their efforts to eradicate slavery from their supply chains. This reporting obligation may only arise where entities meet a certain profit and/or employee threshold;
- Undertake due diligence on suppliers, agents or contractors to determine compliance with company standards for human trafficking and for those entities to provide certification of compliance;
- Provide training on mitigating human trafficking for employees and management responsible for supply chains;
- Certify that materials incorporated into a product comply with human trafficking laws;
- Draft modern slavery statements/reports and register them with a Modern Slavery Statements Register.
Our coverage does not include legislation that contains general requirements on other entities, such as governments, to tackle this issue. We also do not cover criminal law unless a specific law sets out penalties for violating a particular human trafficking law that impacted companies; generic criminal laws are not covered.
HT&S is usually not product-specific unless the regulation applies explicitly to certain products.
New legislation is gaining momentum globally, with a marked trend toward mandatory corporate disclosure regimes. Some legislation in force also has an extra-territorial effect and may, therefore, apply to companies outside of the jurisdiction in question. HT&S is, hence, a hot topic in supply chain management.
Compliance & Risks’ coverage of HTS is historically comprehensive and includes:
- Australia: Modern Slavery Act, No. 153, 2018
- Australia: Statutory Review of the Modern Slavery Act 2018, Report, May 2023
- Canada: Fighting Against Forced Labour and Child Labour in Supply Chains Act, c. 9, 2023
- California (USA): Transparency in Supply Chains Act, 2010
- Chile: Establishing Due Diligence Reports in Respect of Human Rights, the Environment, and Climate Change, Draft Law, April 2025
- EU: Prohibiting Products Made with Forced Labour on the Union Market, Regulation, November 2024
- France: Duty and Vigilance of Parent and Subcontracting Companies, Law No. 2017-399
- Germany: Standards, Audits and Certifications as Due Diligence Tools, Guidance Document, December 2024
- Netherlands: Child Labour Due Diligence Law, 2019
- Netherlands: Responsible and Sustainable International Business Conduct, Revised Draft Law, November 2022
- New South Wales (Australia): Modern Slavery Act, 2018
- New Zealand: Modern Slavery and Worker Exploitation Supply Chain Legislation, Policy Document, September 2023
- Norway: Business Transparency and Work on Fundamental Human Rights and Decent Working Conditions, Act No. 99, 2021
- Norway: Penalties for Non-Compliance with the Transparency Act, Regulation No. 193, 2023
- Switzerland: Due Diligence Obligations and Transparency Regarding Minerals and Metals from Conflict Areas and Child Labour, Ordinance, December 2021
- SRA: Slavery & Trafficking Risk Template (STRT), Version 3.2, 2023
- Thailand: Measures for Preventing and Suppressing Human Trafficking, Announcement, October 2024
- UK: Modern Slavery Act, 2015
- UK: Slavery and Human Trafficking in Supply Chains, Guidance Document, March 2025
- USA: Prevention of Forced Labor in Xinjiang Uyghur, House Bill 6256 Enacted, 2021
- USA: Submission of Force Labor Supporting Documents, Guidance Document, May 2023
- USA: Reporting of Sourcing and Due Diligence Activities within Supply Chains, Senate Bill 1358, 2025
We cover key ESG standards related to the content areas in your subscription as a part of our ESG Solution.
Connection with other topics:
ESG Reporting
Whilst the topic of ESG Reporting also covers obligations for certain companies to report on their overall environmental, social and governance performance (which may include human trafficking and slavery), ESG Reporting is a separate topic to our Human Trafficking and Slavery topic, and no overlap should exist.
Sources that only focus on human trafficking and slavery do not directly fall under our ESG Reporting topic as they are focused on one aspect only, e.g. human slavery.
In addition, ESG reporting obligations typically apply to ‘large’ companies above a certain threshold regarding turnover and number of employees. HT&S, on the other hand, is much broader in scope and covers other obligations in addition to reporting that impact a much broader number of companies under a much wider number of regulatory sources.
Supply Chain Due Diligence
Whilst HT&S legislation may require companies to undertake due diligence on their suppliers, agents and contractors in order to eradicate HT&S from their supply chains, the HT&S topic also covers additional requirements including (i) reporting on efforts to eradicate slavery from the supply chain; (ii) certifying that materials incorporated into products comply with human trafficking laws (iii) provision of training on mitigating human trafficking for employees and management responsible for supply chains; and (iv) drafting modern slavery statements and registering them with a Modern Slavery Statements Register.
On the other hand, the topic of Supply Chain Due Diligence focuses solely on due diligence requirements.
Regulations that require companies to undertake due diligence on their suppliers, agents and contractors to eradicate HT&S from their supply chain may, therefore, fall under both HT&S and Supply Chain Due Diligence. However, regulations that require companies to report on their efforts to eradicate slavery from the supply chain, or certify that materials incorporated into products comply with human trafficking laws or train employees on human trafficking regulations - and that do not contain any due diligence obligations - fall under HT&S only.
Labor / Employment
Whilst our HT&S topic covers situations where persons are coerced to work through the use of violence, intimidation, retention of identity papers or threats of denunciation to immigration authorities, such as forced or child labor, our Labor and Employment topic is broader in nature and covers additional regulations regarding working conditions, equality of treatment and worker related rights. Regulations that cover forced and child labor may fall under both topics. In contrast, regulations that cover additional issues covering other types of working conditions, equality of treatment and worker-related rights will fall under Labor and Employment only.
Further information:
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