Libera Europe · FLR Investigation Pack
Synthetic demo data
Recruitment-fee indicators at Meridia Stitching (synthetic)
SYN-PILOT-001 · generated 29 Oct 2026 · 02:16 · Synthetic pilot workspace · demo data · fictional company · liberaeurope.com
1 · Supplier & site
- Supplier
- Meridia Stitching (synthetic)
- Supplier detail
- Türkiye · Textile & garments · 480 workers · Third-party labour agency · seasonal migrant workforce
- Site
- Gaziantep Stitching Hall (synthetic)
- Case status
- Monitoring
- Priority
- Critical
- Escalated from
- Confidential worker signals
- Case owner
- Compliance lead (synthetic)
- Opened
- 13 Oct 2026
- Target review
- 28 Nov 2026
- Closed
- —
2 · Risk summary & why this risk
Baseline screening score 44/100 (ELEVATED). Headline status HIGH, raised by confidential worker signals.
What increased the risk
- · Country-level forced-labour prevalence and state-response gap in Türkiye.
- · Textile & garments is a high-intensity sector for forced-labour indicators.
- · Workers are recruited through intermediaries, a recognised debt-bondage pathway.
- · 9 confidential worker signals across 5 indicators.
Evidence that supports it
- · Published country datasets referenced in the score breakdown.
- · Supplier record states recruitment via intermediaries.
- · Aggregated indicator counts from the confidential worker channel.
Evidence that is missing
- · Recruiter identities and recruitment-fee records.
- · Official-list screening result for this supplier.
What to review next
- · Request the recruiter list, recruitment contracts and any fee or deduction records.
- · Run sanctions and import-ban screening on the supplier name.
- · Review the grouped indicator pattern and decide whether a documented case is required.
Inherent country risk — Türkiye — published prevalence and state-response data (35/55 pts): Country prevalence: 15.6 people in modern slavery per 1,000 population · rank 5 of 160; State response gap: Government response rated moderate (49/100); ILO Forced Labour Protocol P029 not ratified
Sector risk — Textile & garments — sector exploitation intensity (22/25 pts): DOL TVPRA: garments, cotton and footwear listed for many sourcing countries
Supplier attributes & intermediaries — Recruitment via intermediaries recorded (14/23 pts): recruitment via intermediaries (ILO indicator: deception / debt bondage) · Missing: No recruiter list, recruitment contracts or fee records are recorded in the evidence register.
Official-list intelligence — No official-list screening recorded for this supplier (12/22 pts): Goods listed for this country & sector: Textile & garments goods from Türkiye appear on the US DOL forced/child labour list · Missing: Sanctions / import-ban screening has not been run and stored.
Confidential worker signals — 9 confidential signals · 1 marked severe: 3× recruitment fee or debt; 3× wages withheld or deducted; 1× identity documents withheld; 1× excessive or forced hours; 1× threats reported
Worker-access confidence — Access points verified at the last recorded check: 5/5 agreed access points available at the last recorded check · Asteron sourcing team (synthetic) · All agreed access points restored and photographed.
Remediation & case history — No documented case or remediation history for this supplier
3 · Indicators & aggregated worker signals
9 confidential signals · 1 marked severe · 5 indicators.
- · recruitment fee or debt
- · wages withheld or deducted
- · identity documents withheld
- · excessive or forced hours
- · threats reported
Aggregated counts only — individual worker messages are never included in this pack
4 · Official-list intelligence
No official-list event recorded for this supplier.
5 · Worker-access verification
Worker access verified
5/5 agreed access points available at the last recorded check · All agreed access points restored and photographed.
6 · Investigation actions & chronology
- 13 Oct 2026 · 11:16 — Case opened · Compliance lead (synthetic): Grouped worker signals across recruitment debt, wages and identity documents crossed the human-review threshold at one site.
- 13 Oct 2026 · 11:16 — Worker-signal pattern reviewed · Compliance lead (synthetic): Aggregated indicator counts reviewed. Individual worker messages were not accessed; only grouped counts per indicator are available to management.
- 14 Oct 2026 · 11:16 — Evidence requested · Compliance lead (synthetic): Recommended investigation steps accepted by a human reviewer: recruitment contracts, fee records and payroll for the last three months requested.
- 15 Oct 2026 · 11:16 — Supplier contacted · Responsible sourcing (synthetic): Supplier notified in writing and asked to nominate a contact for the documentation review.
- 20 Oct 2026 · 11:16 — Evidence received · Supplier (synthetic): Recruiter agreement, placement-fee schedule and payroll extract received from the synthetic supplier.
- 22 Oct 2026 · 11:16 — Follow-up review · Compliance lead (synthetic): Documentation review in this synthetic scenario indicates a third-party recruiter charged placement fees to incoming workers. Recorded as a control weakness for remediation; not a legal finding.
- 23 Oct 2026 · 11:16 — Remediation action created · Compliance lead (synthetic): Four remediation actions created with owners and due dates.
- 25 Oct 2026 · 11:16 — Evidence received · Responsible sourcing (synthetic): Worker-access follow-up check recorded 5 of 5 agreed access points available at the site.
- 27 Oct 2026 · 11:16 — Remediation completed · Responsible sourcing (synthetic): Fee reimbursement reconciled against the payroll extract and the recruiter agreement terminated.
- 28 Oct 2026 · 11:16 — Status changed · Compliance lead (synthetic): Case moved to Monitoring. Follow-up worker check scheduled and the confidential channel remains open at this site.
7 · Evidence index
- Aggregated worker-signal summary (synthetic) · Document · 13 Oct 2026 · source: Libera confidential channel — Indicator counts only. No individual worker message, identity or contact detail is stored in or accessible from this case.
- Worker-access check record (synthetic) · Document · 06 Oct 2026 · source: Buyer check — 2 of 5 agreed access points available at an unannounced check on day 7.
- Third-party recruiter service agreement (synthetic) · Contract · 20 Oct 2026 · source: Supplier submission — Fee-schedule annex lists a placement charge payable by the worker.
- Payroll extract, three months (synthetic) · Payroll record · 20 Oct 2026 · source: Supplier submission — Recurring deduction line consistent with repayment of a placement fee.
- Supplier written response (synthetic) · Supplier response · 21 Oct 2026 · source: Supplier — Supplier confirms the recruiter was engaged for seasonal hiring.
- No-worker-pays recruitment policy, signed (synthetic) · Policy · 26 Oct 2026 · source: Supplier — Signed policy annex added to the synthetic supplier agreement.
- Follow-up worker-access check record (synthetic) · Document · 25 Oct 2026 · source: Buyer check — 5 of 5 agreed access points available; photographs retained by the synthetic buyer.
Evidence metadata only · confidential worker submissions are never attached
8 · Findings / assessment
Human assessment recorded: Control weakness identified.
Synthetic pilot case. Repeated grouped worker indicators at a single fictional site pointed to placement fees charged by a third-party recruiter. Opened for human review; risk indicators only, not a finding of forced labour.
9 · Remediation actions
- Reimburse recruitment fees to affected workers · Verified · owner Supplier finance (synthetic) · due 27 Oct 2026 · completed 26 Oct 2026 · verification: Reimbursement reconciled against the payroll extract by responsible sourcing (synthetic).
- Terminate non-compliant recruiter relationship · Completed · owner Supplier management (synthetic) · due 26 Oct 2026 · completed 26 Oct 2026
- Verify identity documents are held by workers · Completed · owner Site management (synthetic) · due 28 Oct 2026 · completed 28 Oct 2026
- Independent follow-up worker check · Not started · owner Compliance lead (synthetic) · due 23 Nov 2026
10 · Effectiveness & monitoring
Unverified
- · 1 of 4 remediation action(s) are still open. Some verification is on file (1 verified), but effectiveness cannot be assessed until every action is complete.
- · The case is in monitoring, so the status will be reassessed at the next follow-up.
Factors considered
- · Remediation actions completed: 3 of 4
- · Actions marked verified: 1
- · Verification notes or evidence recorded: 1 action(s)
- · Follow-up review logged: 2 entries
- · Worker access at the site: verified
- · Relevant worker signals after completion: None recorded
- · Case status: monitoring
To strengthen the assessment
- · Complete the open actions, then verify each one independently.
11 · Evidence chain
- 1. Signal / indicator — complete: recruitment fee or debt; wages withheld or deducted; identity documents withheld; excessive or forced hours; threats reported
- 2. Source / evidence reviewed — complete: Aggregated worker-signal summary (synthetic) · Libera confidential channel; Worker-access check record (synthetic) · Buyer check; Third-party recruiter service agreement (synthetic) · Supplier submission; Payroll extract, three months (synthetic) · Supplier submission; Supplier written response (synthetic) · Supplier; No-worker-pays recruitment policy, signed (synthetic) · Supplier; Follow-up worker-access check record (synthetic) · Buyer check
- 3. Investigation step — complete: Worker-signal pattern reviewed; Evidence requested; Supplier contacted; Evidence received; Follow-up review; Remediation action created; Evidence received; Remediation completed
- 4. Finding / assessment — complete: Control weakness identified
- 5. Remediation action — partial: Reimburse recruitment fees to affected workers · verified; Terminate non-compliant recruiter relationship · completed; Verify identity documents are held by workers · completed; Independent follow-up worker check · not started · Gap: 1 remediation action(s) still open.
- 6. Verification / monitoring — partial: Verified: Reimburse recruitment fees to affected workers; Case is under ongoing monitoring · Gap: 3 remediation action(s) have no independent verification recorded yet.
12 · Audit trail
No audit entries available for this record.
