Forced labour and migrant workers in supply chains

Migrant workers — people who move within or across national borders to find work — are among the most vulnerable populations in global supply chains. 

They account for a disproportionate share of forced labour victims relative to their share of the overall workforce, and the structural features of their situation — the costs and distances involved in migration, dependence on employers for legal status, language barriers, and isolation from community support — make them particularly susceptible to exploitation. 

Understanding why migrant workers face elevated forced labour risk, where that risk concentrates, and what businesses can do about it is essential for any supply chain due diligence programme that takes forced labour seriously. 

This page sets out the specific vulnerabilities of migrant workers in supply chains, the role of labour recruitment in creating and enabling exploitation, key contexts where risk is highest, and what effective business responses look like. 

For sector- and geography-specific risk context, see: High-risk sectors and sourcing regions for forced labour.

For guidance on identification, see: How to identify forced labour in your supply chain 

Why migrant workers face elevated forced labour risk 

Migrant workers are not inherently more likely to be exploited than local workers. What makes them vulnerable is the structural position they occupy — and the ways in which that position can be exploited by recruiters, employers, and the systems that govern their presence in the destination country. 

The cost of migration creates financial dependency. Workers who have borrowed money or spent significant savings to fund their migration arrive in a situation of financial precarity that employers and recruiters can exploit. Where workers have also paid fees to recruitment agencies — fees that in many corridors run to thousands of dollars — the debt may take months or years to repay, during which time the worker feels unable to leave even when conditions are poor. 

Legal status is often tied to the employer. In many countries and migration systems — most explicitly in the Gulf states’ Kafala (sponsorship) system — a migrant worker’s legal right to remain in the country is contingent on remaining with a specific employer. Workers who leave an abusive employer face not just loss of income but loss of legal status. This is one of the most powerful structural drivers of forced labour in global supply chains. 

Language barriers and knowledge gaps limit access to remedy. Migrant workers often do not speak the language of the host country, may not know what rights they are entitled to, and may be unfamiliar with how to access support. This limits their ability to raise complaints, seek help from labour inspectors or civil society organisations, or understand what options are available to them. 

Distance from family and community creates isolation. Workers who have migrated, often leaving families behind and with limited social networks in the destination country, have fewer informal support structures to turn to. This isolation is often compounded by employer practices — including housing workers in employer-controlled accommodation, restricting movement, or confiscating mobile phones — that deepen dependency. 

Irregular immigration status creates particular vulnerability. Workers without legal status in the destination country face the additional threat of deportation if they raise concerns or seek help. This threat — whether real or perceived, explicit or implied — is a powerful tool of control for exploitative employers.  

The recruitment process: where exploitation often begins 

For migrant workers in supply chains, exploitation frequently starts not at the worksite but during the recruitment process — before the worker has set foot in the destination country. 

Recruitment fees and debt bondage 

The charging of fees to workers to secure employment is one of the most pervasive and well-documented drivers of forced labour in global supply chains. Workers pay fees — to recruitment agencies in their home country, to brokers in the destination country, or to both — in exchange for a job offer. These fees can range from a few hundred dollars for domestic migration to several thousand dollars for international placements. Migrant workers, a primary labour source in many supply chains, pay recruitment fees ranging from $3,000 to $5,000, trapping them in debt bondage. In some corridors the amounts are higher: thousands of workers have paid recruitment fees five times higher than the official rate to access jobs in Malaysia from Bangladesh. 

Once indebted, workers find themselves in a position where leaving the job — even in abusive conditions — means defaulting on a loan and losing everything they invested. The debt becomes the mechanism of control. Even where wages are paid, the need to service debt makes the worker functionally unable to exercise free choice about their employment. 

The Employer Pays Principle — established by the ILO and endorsed by ETI’s Base Code — is unambiguous: workers should never pay fees to access employment. The cost of recruitment should fall on the employer, not the worker. This principle is now reflected in due diligence frameworks including the UK Home Office’s updated modern slavery statutory guidance (March 2025) and the CSDDD. 

In practice, implementing the Employer Pays Principle requires companies to understand how their suppliers source labour — including through which agencies and intermediaries — and to verify that workers have not been charged fees. Where fee-charging is discovered, remediation includes reimbursement of fees to affected workers. 

Deceptive recruitment 

Many migrant workers take up employment on the basis of representations — about the type of work, the pay, the location, or the conditions — that do not reflect the reality of what they find on arrival. A worker recruited for a processing job who finds themselves in a fishing vessel at sea, or promised a wage that does not materialise in their pay packet, has been deceived in a way that can constitute the basis for a trafficking or forced labour finding. 

Deception in recruitment is particularly difficult to identify through supply chain audits, which typically occur at the worksite rather than at the point of recruitment. Identifying it requires engagement with workers who can speak honestly about what they were told before they arrived — which in turn requires the conditions of trust and confidentiality described in the identification spoke. 

Document retention 

The retention of identity documents — passports, national identity cards, work permits — by employers or recruitment agencies is a clear forced labour indicator and is prohibited by ETI Base Code Clause 1. It is particularly common in migrant worker contexts, where documents are retained ostensibly for “safekeeping” but in practice remove the worker’s ability to leave independently, change employer, or access consular or legal support. 

No legitimate employment relationship requires workers to surrender their documents. Where document retention is found in a supply chain, it should be treated as a serious forced labour indicator warranting immediate investigation rather than a minor compliance finding. 

Key contexts and corridors 

The Gulf states and the Kafala system 

The Kafala (sponsorship) system, operating across GCC countries and Lebanon and Jordan, has historically been one of the most significant structural drivers of forced labour risk for migrant workers globally. Under the system, a worker’s legal residency is tied to a specific employer-sponsor, creating a profound power imbalance: workers who leave without employer consent lose their legal status, making exit from even abusive employment deeply costly. 

Under the Kafala system, employers frequently withhold compensation and food allowances, confiscate workers’ passports, require them to work overtime without compensation, and prevent them from leaving their residences outside of work hours. 

The system is undergoing significant reform. Qatar introduced changes ahead of the 2022 World Cup allowing workers to change jobs and leave the country without employer permission, though implementation has been inconsistent. Saudi Arabia announced the abolition of the Kafala system in June 2025, replacing it with a contractual employment model under which workers can change employers without prior approval, leave the country freely, and access legal protections previously unavailable — though human rights organisations have noted the need for careful monitoring of implementation. Other GCC states have introduced partial reforms, though the picture varies considerably by country. Several countries have in the past claimed to “abolish” the Kafala system by replacing the term with another without changing the underlying structure — the gap between announced reform and lived experience for workers has historically been significant. 

For companies sourcing from or manufacturing in Gulf states — including through construction, agriculture, hospitality, and domestic supply chains — the Kafala context means that forced labour risk is structural, not exceptional. Due diligence must go beyond worksite visits to examine how workers were recruited, what fees they paid, whether their documents are held, and whether they have genuine freedom to leave. 

South and Southeast Asian labour corridors 

Major migration corridors from Bangladesh, India, Nepal, Pakistan, the Philippines, Myanmar, Cambodia, and Vietnam — to Gulf states, Malaysia, Taiwan, Singapore, and elsewhere — are among the highest-risk contexts for migrant worker exploitation in global supply chains. 

Recruitment fee-charging is a significant issue across these corridors, with workers charged fees leading to debt and devastating financial pressures. Workers from Bangladesh in Malaysia, Nepalese workers in Gulf construction, Indonesian workers on Taiwanese fishing vessels — these are among the most extensively documented cases of forced labour risk in the world, and they connect directly to supply chains serving European and North American consumer markets. 

The Business & Human Rights Resource Centre’s 2025 global analysis of migrant worker abuse found that forced labour indicators — including wage theft, excessive working hours, and abusive living conditions — are present across data from these corridors, with construction and manufacturing among the most affected sectors. 

Agricultural seasonal labour in Europe 

Forced labour risk among migrant workers is not confined to distant supply chains. Seasonal agricultural labour in Southern Europe — fresh produce in Spain and Italy in particular — carries well-documented risk, with migrant workers from sub-Saharan Africa and Eastern Europe among the most affected. ETI’s own investigations have documented exploitation in salad and tomato production linked to UK supermarket supply chains in both countries. 

The UK’s own agricultural and food processing sectors carry significant risk through seasonal migrant labour, with workers recruited through gangmasters and labour agencies. The Gangmasters and Labour Abuse Authority (GLAA) has documented ongoing exploitation in these sectors. 

Domestic workers 

Domestic workers — employed in private homes — represent a specific and acutely vulnerable migrant worker population. They work outside the formal labour inspection system, in a one-to-one relationship with their employer, often in a country far from their own, with few people aware of their conditions. Domestic servitude — confinement, document retention, non-payment of wages, and physical abuse — is documented across the Middle East, Southeast Asia, Europe, and North America. 

For companies, domestic worker risk enters the picture primarily through cleaning, catering, and care sector procurement chains. It also exists in the private households of employees in high-risk sourcing countries, where domestic workers employed by local managers or expatriate staff may be invisible to any corporate due diligence system. 

What businesses should do 

1. Map your labour supply chains, not just your product supply chains 

Most supply chain mapping focuses on the legal entities that produce goods — factories, farms, processors. Forced labour risk among migrant workers requires mapping the labour supply chain as well: which recruitment agencies supply workers to your suppliers, from which countries, through which intermediaries, and at what cost to workers. 

This is not a straightforward exercise, and suppliers may resist it. But without understanding how workers are recruited, it is not possible to identify the debt bondage and deceptive recruitment that drive the majority of migrant worker exploitation in supply chains. 

2. Implement and verify the Employer Pays Principle 

ETI’s Base Code Clause 1 prohibits workers from being required to lodge deposits or pay recruitment fees as a condition of employment. The Employer Pays Principle — that all costs of recruitment should fall on the employer, not the worker — is the operational standard against which this should be measured. 

Implementing this principle requires: communicating clearly to suppliers and their recruitment agencies that fee-charging is not acceptable; building verification into supplier engagement and due diligence processes; and — where fees are discovered — reimbursing affected workers and working with suppliers to reform recruitment practices. 

3. Engage with suppliers on responsible recruitment 

Suppliers — particularly in sectors reliant on migrant labour — need support as well as requirements. Responsible recruitment is more expensive than recruitment through fee-charging agencies, and suppliers operating in highly competitive markets may need commercial signals from buyers that ethical recruitment practices are valued and will not be penalised through price pressure. 

ETI’s work on responsible recruitment emphasises the importance of buyer-supplier collaboration: working with suppliers to identify and transition to ethical recruitment agencies, including through sector-wide initiatives that share the work and cost across multiple buyers. 

4. Create genuine conditions for worker voice 

Migrant workers are among those least likely to disclose exploitation through standard grievance mechanisms or audit interviews. The barriers are significant: language, legal status, fear of deportation, debt to employers, and lack of knowledge about what help is available. 

Effective worker voice for migrant workers requires channels that operate in workers’ own languages; that are accessible outside the workplace and working hours; that are run by or through organisations workers trust — including civil society groups, trade unions, and diaspora networks — rather than by the employer or the employer’s auditor; and that have genuine non-retaliation protections that workers believe in. 

5. Address purchasing practices that create risk 

A drive to cut costs, maximise profit, and meet consumer demand for cheap, fast products has led to poor purchasing practices and multi-tier, outsourced supply chains, with damaging human rights impacts for migrants in factories across the world: buyers continue to set low prices and short lead times for products, squeezing suppliers and putting pressure on working conditions. 

Migrant worker exploitation in supply chains is not only a problem at the supplier end. Buyer purchasing practices — excessive price pressure, short lead times, last-minute order changes — drive suppliers toward informal labour arrangements and recruitment through fee-charging agencies. Addressing migrant worker risk requires examining what buyers do, not just what suppliers do. 

For guidance on responsible purchasing practices and their relationship to forced labour, see: Forced labour & modern slavery: a complete guide for business 

6. Support access to remedy 

When migrant workers have experienced exploitation — including fee-charging, document retention, wage theft, or more severe forms of forced labour — they are entitled to remedy. This includes, at minimum, reimbursement of recruitment fees paid, recovery of withheld wages, and safe exit from their situation. 

Remediation should be worker-centred and designed in consultation with the workers affected and with civil society organisations that have established relationships with the relevant communities. Immediate disengagement from a supplier — without ensuring that affected workers receive remedy — is rarely the right response, and may leave workers worse off. 

For detailed guidance on remediation approaches, see: Remediation: what to do when forced labour is found

Frequently asked questions 

Why are migrant workers more vulnerable to forced labour than local workers? It is not that migrant workers are inherently more vulnerable, but that the structural features of migration — the cost of recruitment, dependence on employers for legal status, language barriers, distance from support networks — create conditions that can be exploited. A local worker who experiences exploitation can walk away, access a support network, and understand their legal rights. Many migrant workers face significant practical and legal barriers to doing the same. 

Does the Employer Pays Principle mean we are responsible for all recruitment fees across our entire supply chain? In practice, implementing the Employer Pays Principle means: communicating the requirement clearly to direct suppliers; building verification into supplier due diligence; and taking meaningful action — including remediation — where fee-charging is discovered. The further you are from a worker in the supply chain, the harder it is to exercise direct control, but responsibility does not disappear with distance. Leading practice involves working collaboratively with suppliers to transition away from fee-charging recruitment agencies, which typically requires shared cost and commitment from buyers as well as suppliers. 

Is the Kafala system now reformed in the Gulf states? Reform has been announced across several GCC countries, most significantly Saudi Arabia’s announced abolition of the Kafala system in June 2025. Qatar, Kuwait, and others have also introduced changes. However, the gap between announced reform and lived experience for workers has historically been significant — some activists have questioned whether the reforms go far enough to deliver real change for migrant workers, and experts have urged that expressions of optimism be put on hold until full details, legal changes, and implementation timelines are clear. Companies sourcing from Gulf states should continue to apply rigorous migrant worker due diligence rather than assuming that structural risks have been resolved by policy announcements. 

How do we verify that workers in our supply chains have not paid recruitment fees? Verification is genuinely difficult. Document review can identify whether formal contracts include fee provisions, but fees paid informally before the worker arrived at the employer are not typically recorded in any document held at the worksite. The most effective approach is to combine: direct worker interviews conducted in conditions of trust and confidentiality, in workers’ own languages and away from the employer; review of recruitment agency contracts and fee schedules; engagement with civil society organisations that work with relevant worker communities; and tracing the recruitment pathway from sending country to worksite, including through engagement with embassies and migrant support organisations in origin countries. 

What should we do if we find that workers in our supply chain have paid recruitment fees? The priority is remediation for the workers affected. This means: reimbursing recruitment fees paid; working with the supplier and relevant recruitment agencies to reform practices going forward; not penalising the supplier in a way that results in workers losing their income and access to remedy; and documenting the response in a way that can be disclosed in your modern slavery statement. ETI can provide guidance on worker-centred remediation approaches appropriate to the specific context.  

Further reading in this cluster 

What is modern slavery? Definitions, forms and scale
How to identify forced labour in your supply chain
High-risk sectors and sourcing regions for forced labour
Remediation: what to do when forced labour is found 
Forced labour & modern slavery: a complete guide for business