How to assess forced labour risk in your supply chain

What a forced labour risk assessment is for

A forced labour risk assessment is a structured way to decide where in a supply chain to look first and how closely. It does not establish that forced labour exists anywhere. Its output is a prioritised list of suppliers, sites and labour providers that deserve human attention, with the reasons written down.

• Prioritise by severity and likelihood, not by spend alone
• Assess sites and labour providers, not only the legal entity
• Record why each supplier was ranked where it was
• Repeat it — risk changes with recruitment cycles, seasons and new tiers

Step 1: map the supply chain you can see

Start with direct suppliers and the sites where they actually produce, then add known subcontractors and the agencies that recruit their workforce. Gaps in the map are themselves a risk signal and should be recorded rather than hidden.

Step 2: score structural risk factors

Structural factors describe the conditions under which forced labour is more likely. Libera scores each supplier on five named factors so the result can be explained to a colleague, an auditor or an authority.

• Country prevalence and government response (Walk Free Global Slavery Index 2023, static edition)
• Sector intensity, informed by ILO estimates and US DOL TVPRA listings
• Workforce size
• Use of recruitment intermediaries, treated as a distinct risk factor
• Live checks against OFAC sanctions and the DHS UFLPA Entity List at the time of the check

Step 3: look for the ILO indicators

The ILO's eleven indicators of forced labour — such as recruitment debt, withheld wages, retained identity documents, restricted movement and threats — are what turn structural risk into something specific. Questionnaires rarely surface them; the people affected often can.

Step 4: add worker voice

A confidential channel at the worksite lets workers raise indicators that never appear in supplier self-assessment. In Libera, individual reports stay confidential to designated reviewers and management sees only grouped indicator counts per site and supplier. Zero reports with unverified access is never treated as reassurance.

Step 5: human review, action and documentation

When structural risk and signals point the same way, a person reviews the evidence and decides what happens: engagement, investigation, remediation or monitoring. The assessment is only useful later if the decision, the evidence and the follow-up are recorded with dates and owners.

Modern slavery risk assessment

Modern slavery statements under the UK Modern Slavery Act and the Australian Modern Slavery Act ask companies to describe how they assess and address risk. The method is the same: prioritise by country, sector and recruitment model, look for indicators, give workers a way to speak, and document what was done. Libera supports that documentation; it does not write or approve a statement.

Where software helps — and where it stops

Software makes the assessment consistent, repeatable and explainable across hundreds of suppliers, and keeps the evidence trail in one place. It cannot conclude that forced labour occurred, replace an on-site investigation or audit, or determine your legal obligations. Libera's risk indicators are prompts for human review, not findings or accusations.