Finding forced labour in a supply chain is not a failure of due diligence — it is often what effective due diligence can reveal. 

The companies that never find any problems in complex, high-risk supply chains are more likely to be looking inadequately than operating ethically.

What matters most is what happens next. And the most common first instinct — ending the supplier relationship as quickly as possible — is frequently the response that produces the worst outcomes for the workers affected.

This page sets out what effective remediation looks like when forced labour is identified in a supply chain: the immediate priorities, the decisions that need to be made, the distinction between private and state-imposed forced labour, the role of disengagement as a genuine last resort, and what workers are entitled to when things have gone wrong.

For guidance on identifying forced labour in the first place, see: How to identify forced labour in your supply chain.

Why remediation matters — and why it is the “forgotten pillar”

Access to remedy is the third pillar of the UN Guiding Principles on Business and Human Rights, alongside the state duty to protect and the corporate responsibility to respect. It has been described as the “forgotten pillar” — consistently the weakest area of corporate performance on human rights, and the area that makes the most direct difference to workers who have experienced exploitation.

The data bears this out. Research consistently finds that when forced labour is identified, remedy for affected workers is the exception rather than the rule. Of companies with allegations of forced labour in their supply chains, almost three quarters failed to provide evidence that impacted workers were remediated. Just 13% of companies with forced labour exposure disclosed repayment of recruitment fees to affected workers.

This is not primarily a reflection of bad intent. It reflects several structural problems: the instinct to exit quickly and limit reputational exposure; the difficulty of identifying and reaching affected workers once a supplier relationship has ended; the absence of clear internal processes for handling forced labour findings; and the lack of leverage over supplier labour practices in relationships that were already arms-length.

Effective remediation requires planning before a problem is found, not improvisation after it.

The immediate priorities

When forced labour indicators are identified — whether through worker disclosure, an investigation, a media report, or regulatory enforcement action — several things need to happen in the right sequence.

1. Prioritise the safety of workers

This is the non-negotiable first step. Workers who are in a situation of forced labour may be at immediate risk of retaliation if an employer believes they have disclosed their situation or cooperated with an investigation. Before any other action is taken, the question of worker safety must be assessed.

This means: not disclosing findings to the employer before workers are in a position of safety; engaging specialists — civil society organisations, trade unions, or experienced remediation advisors — who can assess risk and advise on how to proceed; and creating conditions in which workers can communicate safely about what they need.

2. Do not trigger immediate disengagement

The impulse to end the supplier relationship immediately — to stop placing orders, issue a termination notice, and publicly distance the company from the issue — can feel like the responsible response. In most situations it is not.

Abrupt disengagement causes direct harm to workers. The clearest example comes from the Thai shrimp sector: following reports in 2014 to 2016 linking Thai shrimp supply chains to forced labour, several Western retailers suspended purchases and major exporters rapidly ended all subcontracting to external shrimp processing sheds. The result was a sudden demand shock that saw an estimated 5,000 workers lose work overnight — workers who had often arrived in a situation of vulnerability and who lost their income without any access to remedy.

The EU Forced Labour Regulation is explicit on this point: changing one’s supply chain, in the sense of relying on different suppliers, cannot be considered a way to eliminate the forced labour regarding the product concerned. Disengagement does not remediate — it removes the buyer’s leverage and often leaves workers worse off.

3. Engage specialist support

Forced labour situations require specialist involvement. The skills needed — cultural knowledge, language, understanding of the specific forms of exploitation involved, trust relationships with affected worker communities — are rarely held within a company’s internal sustainability or legal team.

Relevant specialists include: civil society organisations with established relationships in the sourcing community; trade unions representing workers in the relevant sector; and in some contexts, national labour inspectorates or law enforcement agencies.

Engaging support early — before making any major decisions — produces better outcomes for workers and reduces the risk of well-intentioned actions causing further harm.

4. Secure evidence carefully

Documenting what has been found — who identified the indicators, through what process, what evidence exists, and what the response has been — matters for several reasons: it supports the remediation process itself; it enables transparent reporting in modern slavery statements and regulatory disclosures; and it protects the company in the event of regulatory investigation or civil proceedings.

Evidence should be secured in a way that does not compromise worker safety or the integrity of the investigation. Legal advice on document handling is advisable, particularly where regulatory enforcement (UFLPA, EU FLR) is a possibility.

The disengagement decision: engagement first, exit as last resort

The UNGPs and OECD Guidelines are clear that disengagement from a supplier relationship is a measure of last resort — to be considered only when engagement has failed or leverage is exhausted. The CSDDD aligns with this position, clarifying that disengagement from suppliers should only happen in a responsible manner when there is no reasonable expectation that leverage efforts would succeed.

File(s)

ETI Technical Guidance on Responsible Disengagement

Explores what responsible business practices entail in the context of sourcing changes, specifically when “disengaging” – that is, making substantial reductions in sourcing volumes or terminating supply chain business relationships.

Read more

When to stay engaged

In the majority of cases involving privately-imposed forced labour — exploitation by employers, recruiters, or labour agencies — staying engaged is the right response. A buyer retains leverage over a supplier as long as the commercial relationship continues: the ability to require corrective action, support the cost of remediation, commission independent monitoring, and give or withhold future orders depending on progress. Once a buyer exits, that leverage is gone.

Engagement-based remediation typically involves: agreeing a time-bound corrective action plan with the supplier; specifying the remediation actions required (including remedy for workers); providing technical and potentially financial support for those actions; commissioning independent monitoring of progress; and making future purchasing decisions contingent on demonstrated improvement.

The timeline for remediation should be realistic. One case documented in published guidance involved a supplier committed to repaying recruitment fees to migrant workers — a commitment that would take a year to fulfil given the scale of fees owed. A responsible buyer in that situation maintained the relationship and monitored progress rather than demanding immediate completion or exiting.

Escalation: when engagement should intensify

Where an initial response from the supplier is inadequate — where corrective action commitments are not met, where the severity of findings warrants stronger action, or where there is evidence of deliberate concealment — buyers should escalate engagement rather than defaulting to exit. This may include:

• Involving industry bodies, certification schemes, or multi-stakeholder initiatives to increase collective pressure
• Engaging government labour inspectorates or law enforcement where criminal exploitation is involved
• Commissioning independent investigation rather than relying on supplier self-reporting
• Increasing transparency — including public disclosure — as leverage to drive change

When disengagement is appropriate

There are circumstances in which disengagement is the right response. The UNGPs recognise that termination is appropriate where the severity of abuse is extreme and the buyer has no ability to change the situation. Responsible disengagement in these circumstances means:

• First ensuring that affected workers have received remedy — or have a credible pathway to remedy — before the relationship ends
• Engaging with workers, their representatives, and relevant civil society organisations about the exit and its consequences for them
• Providing a transition period and advance notice that allows the supplier to find alternative buyers and workers to secure alternative income where possible
• Documenting the process and disclosing it publicly

The phrase “cut and run” — exit without prior engagement, without remediation, without regard for worker welfare — should not be confused with responsible disengagement. One is a brand-protection exercise; the other is a genuine human rights response.

State-imposed forced labour: the exception

Where forced labour is state-imposed — where a government is compelling workers to labour as a matter of policy, typically in specific industries or involving specific ethnic or political groups — the standard engagement-first approach does not apply. In these situations, buyers have no ability to engage with the state actor driving the exploitation, cannot verify conditions are free from forced labour, and cannot leverage an employer to change practices that are government-mandated.

In cases of state-imposed forced labour, swift disengagement is the appropriate response. This is reflected in the position of the Coalition to End Forced Labour in the Uyghur Region regarding Xinjiang, and in the design of the US UFLPA, which treats Xinjiang-sourced goods as presumptively made with forced labour with no engagement pathway. 

Earlier drafts of the CSDDD expressly recognised that state-imposed forced labour may require immediate disengagement where there is no realistic prospect that mitigation efforts would succeed. While the final adopted Directive does not explicitly single out state-imposed forced labour in this way, it retains the broader principle that disengagement may be necessary in cases of severe adverse impacts that cannot effectively be prevented or remedied.

What remediation for workers looks like

The goal of remediation is to bring affected workers as close as possible to the position they were in before the harm occurred. Under the UNGPs and OECD framework, this can be achieved through restitution, compensation, rehabilitation, satisfaction, or guarantees of non-repetition — used individually or in combination, proportionate to the harm suffered.

In a forced labour supply chain context, effective remediation typically includes some or all of the following:

Reimbursement of recruitment fees

Where workers have paid fees to access employment, reimbursement is the most fundamental form of remedy. It is also one of the most consistently absent: only 13% of companies with forced labour exposure disclose recruitment fee repayment to affected workers.

Fee reimbursement should be paid directly to workers, not through the recruitment agency or employer that charged the fees. The amount should reflect fees actually paid — which may require interviewing workers individually — not a standardised figure.

Recovery of withheld wages

Where wages have been withheld — in whole or in part, or through unexplained deductions — workers are entitled to the wages owed. This requires calculating actual wages due against wages paid, accounting for any legitimate deductions, and paying the difference directly to workers.

Restoration of documents

Where identity documents have been retained, their immediate return to workers — without conditions — is a prerequisite for workers’ ability to exercise any other right, including the right to leave.

Access to support services

Depending on the severity and duration of the exploitation, affected workers may need access to legal support, healthcare, psychological support, or housing. Connecting workers with relevant services — through civil society organisations, trade unions, or specialist support bodies — is part of a comprehensive remediation response.

Guarantees of non-repetition

Remediation is not only about addressing past harm. Suppliers should be required to demonstrate that the practices that enabled forced labour have been identified, understood, and changed — not just temporarily suspended. This includes reforms to recruitment practices, management systems, worker communication channels, and — where appropriate — purchasing arrangements with the buyer.

Transparency and apology

Workers who have experienced forced labour are entitled to have that experience acknowledged. Formal apologies, where culturally appropriate, and transparent disclosure of what happened and how it has been addressed — in modern slavery statements and other public communications — are part of a complete remediation response.

Remediation and regulatory compliance

Remediation is increasingly not only an ethical expectation but a regulatory one, and the standards are rising.

Under the UK Modern Slavery Act: The March 2025 updated guidance explicitly encourages companies to disclose instances of forced labour identified and the remediation steps taken. Companies that find and remediate effectively — and are transparent about it — are treated more favourably than those that claim never to have found anything.

Under the US Tariff Act and UFLPA: Companies subject to Withhold Release Orders must demonstrate remediation of the ILO indicators of forced labour identified in order to have import restrictions modified or lifted. In this context, remediation is both a legal requirement and the pathway to restoring market access. Remediation should include provision of remedies to affected workers — not only operational changes at the facility.

Under the EU Forced Labour Regulation: Remediation is built into the enforcement mechanism. Where a product is found to have been made with forced labour, the economic operator must withdraw it from the market. The European Commission is developing guidelines on remediation under the EUFLR, to be published alongside compliance guidance by June 2026.

Under the CSDDD: Where a company has caused or contributed to an adverse human rights impact — including through purchasing practices that drove exploitation — it carries a direct responsibility to provide or participate in effective remediation. This goes beyond requiring suppliers to remediate: it places responsibility on the buyer where buyer behaviour contributed to the harm.

The role of worker voice in remediation

Remediation designed without meaningful input from affected workers frequently misses what workers actually need. Fee repayment schemes that take months to administer, support services offered in languages workers don’t speak, or remediation plans developed entirely between the buyer and supplier without worker involvement are common failure modes.

Worker-centred remediation means:

• Consulting workers — individually and, where possible, through their trade union or worker representatives — about what remedy they need and what form it should take
• Communicating with workers in their own language, through trusted intermediaries where necessary
• Building in time and process for workers to raise concerns about the adequacy of proposed remediation before it is finalised
• Ensuring that workers who participated in the disclosure process are protected from retaliation — including through monitoring after remediation is complete

ETI’s tripartite model — bringing together companies, trade unions, and NGOs — reflects the insight that effective remediation requires all of these perspectives. Trade unions with membership in the relevant workforce, and civil society organisations with established community trust, are essential partners in designing and delivering remediation that works for workers rather than simply for company compliance purposes.

Disclosure: how to report on remediation

Transparent disclosure of forced labour findings and remediation is increasingly expected by regulators, investors, and civil society — and is the right thing to do.

Effective disclosure covers: what was found; how it was identified; what immediate actions were taken; what the remediation plan consists of; what remedy affected workers have received; and what systemic changes have been made to prevent recurrence.

The instinct to say as little as possible — to characterise a finding as “an isolated incident” and avoid specifics — is understandable but counterproductive. Investors and civil society have become sophisticated at reading the gap between what is said and what is demonstrated. Specific, evidenced disclosure of a remediation response, even where the underlying finding is serious, is more credible and more protective of reputation than vague reassurance.

Disclosure should be made in the company’s modern slavery statement, and — where relevant — to regulators, investors, and public procurement bodies. For guidance on disclosure, see: How to write a modern slavery statement

Frequently asked questions

Is it better to exit a supplier quickly to limit reputational damage? In most situations of privately-imposed forced labour, no. Rapid exit without remediation leaves workers without income, without remedy, and without the buyer’s leverage — which was the most useful tool available to address the situation. It also increasingly fails regulatory standards: the EU Forced Labour Regulation explicitly states that switching suppliers is not remediation. The reputational calculus is also shifting: investors and civil society are paying close attention to what companies do when they find problems, and a well-handled remediation response — transparently disclosed — is more credible than a supplier exit with no follow-up.

What if the supplier refuses to cooperate with a remediation plan? Supplier non-cooperation is itself a significant indicator that the relationship may not be recoverable. Steps before exiting should include: escalating within the supplier’s organisation; engaging industry bodies or certification schemes to apply collective pressure; commissioning independent investigation; and increasing transparency as leverage. Where these steps fail, and where leverage is genuinely exhausted, responsible disengagement — with prior remediation for workers — becomes the appropriate response.

We found forced labour at a Tier 3 supplier we don’t directly contract with. Are we responsible for remediation? Under the UNGPs, responsibility is graduated by proximity and leverage. A company that is directly linked to harm through its value chain has a responsibility to use its leverage — direct or indirect — to address it. Where harm has occurred at a supplier you don’t directly contract with, the starting point is: what influence do you have, directly or through your Tier 1 supplier, over the situation? Remediation responsibility follows from contribution to harm — including through purchasing practices — not just from direct contractual relationships.

How do we handle a situation where forced labour is found but we cannot verify whether workers want to be identified? This is one of the most sensitive dimensions of forced labour remediation. Workers who are still employed by the supplier, and who fear retaliation, may not want to be identified in any remediation process. In these situations: engaging a trusted intermediary — a civil society organisation or trade union with existing worker relationships — to communicate with workers is usually more effective than direct company contact; designing remediation to be available to workers on an opt-in, confidential basis is preferable to a process that requires identification; and monitoring through independent channels after the immediate response is important to ensure workers who initially chose not to come forward can access remedy later.

What is the difference between remediation under the UNGPs and remediation under the UFLPA? The UFLPA uses “remediation” primarily to mean the removal of the ILO forced labour indicators at a facility — the operational changes needed to lift an import ban. The UNGPs use “remedy” to mean making things right for affected workers — through restitution, compensation, rehabilitation, or guarantees of non-repetition. These are related but distinct. A facility can remove the indicators of forced labour — improving systems, dismissing offending managers, ending document retention — without ensuring that workers who suffered harm have received any compensation. Best practice, and increasingly regulatory expectation, requires both.

Further reading in this cluster

How to identify forced labour in your supply chain
Forced labour and migrant workers
How to write a modern slavery statement
Modern slavery legislation: what businesses need to know
Forced labour & modern slavery: a complete guide for business