Analyst Insight: Every product in the supply chain depends on people, but most organizations have difficulty accurately identifying who manages the workers behind their goods. The multilevel touchpoints in the recruitment chain, including contractors, subcontractors, agencies and labor brokers, create layers of separation between an organization and its workforce. This leaves a visibility gap where forced labor thrives. As regulators increasingly target exploitative recruitment, closing this gap is both morally urgent and legally necessary.

When workers pay fees to secure employment, they enter debt bondage, a condition affecting more than half of all victims in forced labor situations in the private sector, according to the International Labor Organization. When contracts aren't provided in languages or terms workers understand, exploitation goes undetected. When third-party agencies operate without oversight, workers lose their autonomy and are at an increased risk of losing access to proper wages, benefits and protections.

Fair labor sourcing requires suppliers to prohibit recruitment fees, provide contracts in workers' native languages, disclose wages and conditions before departure, ensure third-party agencies meet the same standards, and guarantee cost-free repatriation. Without these protections, you're enabling the systems that fuel modern slavery.

Several countries are now mandating modern slavery regulations, including the U.S., Australia, Germany, Canada and the European Union. Emerging human rights due diligence regulations in Asia — including in South Korea, Indonesia, and Japan — underline the increasing global scope of these requirements. While the U.S. does not have federal legislation, states like California do have requirements around supply chain transparency.

The U.S. Uyghur Forced Labor Prevention Act (UFLPA) import restriction and enforcement legislation is quickly becoming a model that other countries are starting to follow, having reviewed over 12,500 shipments valued at $3.68 billion between January and August 2025.

In 2026, the U.K. is implementing UFLPA-style enforcement, New Zealand is enacting comprehensive modern slavery legislation, and the EU is layering additional forced labor regulations onto existing frameworks.

Even organizations with established supplier codes of conduct face challenges identifying risks beyond direct suppliers, where labor brokers and forced labor often hide. As regulations intensify. Take the following steps:

Map your recruitment network. Identify everyone involved in bringing workers into your supply chain, then document how workers move through your system. This reveals where exploitation risks hide, particularly in high-risk geographic areas where regulatory oversight is weak.

Implement rigorous supplier vetting. Examine actual day-to-day hiring processes rather than stated policies. Develop evaluation frameworks aligned with the International Labor Organization Fair Recruitment Initiative, UN Guiding Principles on Business and Human Rights, and Organization for Economic Cooperation and Development Due Diligence Guidelines.

Shift to capacity building. Facilitate training on why prohibiting recruitment fees prevents debt bondage. Create a dialogue that encourages transparency rather than concealing problems.

Embrace worker-centricity. Build direct communication with workers using channels with multi-language reporting systems and local advocacy partnerships. Anonymous mechanisms must genuinely protect worker safety.

Utilize real-time monitoring. Track worker journeys from recruitment through employment. Use artificial intelligence-powered risk analysis to identify patterns before they escalate. Create visibility across tiers simultaneously rather than sequentially.

Resource Link: https://www.bsigroup.com

Outlook: These tools work best as integrated systems, not standalone solutions. Modern slavery exists in supply chains because organizations don't know or don't look at who recruits workers. The workers in your supply chain deserve fair treatment, and your organization needs the transparency to prove it.