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What is Modern Slavery? Supply Chain Examples & Compliance

Written by Tiahna Broderick | Jan 12, 2026 4:00:00 PM

Modern slavery is a serious human rights violation that occurs when individuals are exploited and controlled for personal or commercial gain. It includes forced labor, human trafficking, servitude, and other practices where people cannot refuse or leave work due to threats, coercion, or abuse. Modern slavery in global supply chains is a direct compliance risk that affects companies across industries.

As regulators expand enforcement, organizations are increasingly accountable for labor conditions deep within their supplier networks. Understanding modern slavery in supply chains is now essential for maintaining market access and regulatory credibility. 

Forced labor vs. modern slavery

Modern slavery is an umbrella term. Forced labor is one of its most common and most regulated forms. A clear forced labor definition comes from the International Labor Organization (ILO): Forced labor is any work or service extracted under threat of penalty where the person has not offered themselves voluntarily. 

In practice, forced labor may involve: 

  • Confiscation of identity documents 
  • Recruitment fees or debt bondage 
  • Withheld or delayed wages 
  • Restrictions on movement 
  • Threats, intimidation, or surveillance 

For companies, understanding forced labor is critical because it is a primary focus of customs enforcement and trade regulations. 

Why modern slavery in global supply chains is a growing compliance risk

Modern slavery compliance is accelerating from a disclosure exercise to an enforceable business requirement. What once sat at the margins of ESG reporting is now firmly embedded in regulatory, legal, and commercial expectations. 

  • Several trends are accelerating risk: 
  • Expansion of modern slavery reporting obligations 
  • Increased border enforcement and import controls 
  • Heightened scrutiny of upstream supplier labor practices 
  • Greater expectations for documented and ongoing due diligence 

Modern slavery in global supply chains often occurs several tiers upstream, and many companies struggle to identify risk before enforcement action occurs. 

Examples of modern slavery in supply chains

Modern slavery often hides behind routine business practices, making it difficult to detect without clear indicators. In supply chains, it typically manifests through control, coercion, or restriction of worker freedom, rather than overt violence.

These examples of modern slavery in supply chains highlight what procurement, compliance, and sustainability teams should actively look for. 

Debt bondage through recruitment fees

Workers are charged high fees to secure employment, then forced to work to repay debt. This practice is common in cross-border hiring and outsourced labor models. 

What it can look like: 

  • Recruitment or placement fees paid by workers 
  • Ongoing wage deductions tied to unclear debts 
  • Contracts written in languages workers do not understand

Confiscation of passports or identity documents

Suppliers or labor brokers withhold identity documents to restrict worker movement. This removes a worker’s ability to leave or change employment freely. 

What it can look like: 

  • Passports held “for safekeeping” by employers 
  • Workers needing permission to leave facilities or housing 
  • Threats of deportation tied to job performance 

Withheld wages and coercive pay practices

Delayed or unpaid wages trap workers in unsafe or exploitative conditions. Without pay, workers often cannot afford to leave.

What it can look like: 

  • Chronic late or partial wage payments 
  • Final wages withheld until contract completion 
  • Financial penalties for quitting or reporting issues

Forced overtime and excessive production pressure

When overtime is enforced through threats or discipline, it becomes coercive. This risk increases during peak production cycles.

What it can look like: 

  • Mandatory overtime without worker consent 
  • Punishment for refusing additional shifts 
  • Unsafe working hours tied to unrealistic quotas

Employer-controlled housing and restricted movement

When employers control housing, food, and transportation, workers may become isolated and dependent. This can quickly escalate into exploitation. 

What it can look like: 

  • Crowded housing with strict rules and monitoring 
  • Transportation that limits workers’ ability to leave freely 
  • Surveillance or intimidation in living quarters 

These conditions are not only ethical red flags—they also expose companies to growing legal and regulatory risk.

Human rights laws addressing modern slavery in supply chains

Human rights laws are increasingly designed to address modern slavery risks through transparency, due diligence, and enforcement. Rather than voluntary commitments, companies are now expected to demonstrate how they identify and mitigate labor risks across their supply chains.

Below are the major human rights laws shaping modern slavery accountability today.

UK Modern Slavery Act

The UK Modern Slavery Act requires businesses above a revenue threshold to publish an annual modern slavery statement describing actions taken to prevent modern slavery in their operations and supply chains.

Statements must be approved at the board level and published annually, typically aligned to the organization’s financial year. While the law does not mandate a single filing date, statements are expected to be updated once every 12 months and remain publicly accessible. 

In practice, expectations around modern slavery act reporting have expanded. Regulators, investors, and customers increasingly look for: 

  • Clear identification of supply chain risk areas 
  • Documented due diligence processes 
  • Evidence of supplier engagement beyond tier-one 

For many organizations, the challenge is not publishing a statement on time. It is substantiating that statement with reliable supplier data year after year. 

Canada Modern Slavery Act

Canada’s Fighting Against Forced Labor and Child Labor in Supply Chains Act establishes a clear annual reporting deadline of May 31 for qualifying entities and certain government institutions.

Reports must describe steps taken during the previous financial year to prevent and reduce the risk of forced labor and child labor at any stage of production, whether goods are produced domestically or imported.

Required disclosures include: 

  • Supply chain structure and activities 
  • Policies and due diligence processes 
  • Areas of forced labor or child labor risk 
  • Measures taken to assess, mitigate, and remediate risk 
  • Training and effectiveness assessment

This structure exposes a common modern slavery challenge to supply chain management. If supplier data is fragmented or outdated, meeting the May 31 deadline becomes reactive. If data is structured and refreshed continuously, reporting becomes far more manageable.

Australia Modern Slavery Act

Australia’s Modern Slavery Act applies to entities with consolidated annual revenue above AUD $100 million that are based in, or operate in, Australia.

Modern slavery statements must be submitted within six months after the end of the reporting entity’s financial year and are published in a public registry. Unlike some disclosure regimes, Australia places strong emphasis on describing how organizations assess the effectiveness of their actions.

This has practical implications for companies managing modern slavery in global supply chains. One-time supplier questionnaires or static risk assessments rarely provide enough evidence to support effective compliance over multiple reporting cycles.

As a result, many organizations are shifting toward repeatable processes that track risk and outcomes over time.

The U.S. Uyghur Forced Labor Prevention Act (UFLPA)

The Uyghur Forced Labor Prevention Act demonstrates how modern slavery and forced labor risk translate directly into enforcement action.

Signed into law in December 2021, UFLPA enforcement began on June 21, 2022. Since then, U.S. Customs and Border Protection (CBP) has actively detained shipments suspected of containing forced labor-linked inputs.

Under UFLPA: 

  • Goods produced wholly or in part in the Xinjiang Uyghur Autonomous Region, or connected to entities on the UFLPA Entity List, are presumed inadmissible 
  • Importers must provide clear and convincing evidence to secure release 
  • Detentions occur at the border, often with little advance notice 

In the first year of enforcement, CBP detained over $522 million in goods, with more than 10,000 shipments valued at $3.5 billion stopped to date. Apparel, footwear, and electronics supply chains have been especially affected.

Modern slavery challenges to supply chain management

Identifying and managing modern slavery risk is inherently complex. Several modern slavery challenges to supply chain management continue to undermine even well-intentioned compliance programs.

One challenge is scale. Global estimates show that 50 million people were living in modern slavery worldwide in 2021, with forced labor accounting for more than half of those cases. Much of this exploitation occurs within private-sector supply chains, often several tiers upstream.

Common operational challenges include: 

  • Limited visibility beyond tier-one suppliers 
  • Heavy reliance on self-reported supplier data 
  • Inconsistent audit coverage across sourcing regions 
  • Static risk assessments that fail to reflect change

These gaps create blind spots, particularly when multiple forced labor and modern slavery regulations apply at the same time. When enforcement actions occur, companies often discover that the data needed to respond is not available.

What effective modern slavery due diligence looks like today

Regulators are signaling clearer and more consistent expectations for modern slavery compliance. Disclosure alone is no longer sufficient. Effective programs typically include:

  • Risk-based prioritization aligned to sourcing regions and materials 
  • Ongoing supplier data collection and validation 
  • Traceability extending beyond immediate suppliers 
  • Documentation aligned with enforcement standards 
  • Integration with broader ESG and supply chain compliance programs

The objective of modern slavery due diligence is not perfection. It is defensible, repeatable processes that support informed decision-making under real regulatory pressure.

The Source Intelligence perspective on modern slavery and supply chains

Modern slavery risk cannot be managed in isolation. It intersects with forced labor enforcement, ESG reporting, and product compliance obligations. Supplier data is often fragmented, outdated, or limited to tier-one relationships. Risk assessments rely on self-reported information, manual processes, or one-time audits that fail to capture real exposure. Meanwhile, regulations continue to expand in scope, depth, and enforcement expectations.

Source Intelligence helps organizations better address modern slavery by:

  • Identifying and monitoring forced labor risk across global supplier networks 
  • Collecting and validating supplier data beyond self-reported responses 
  • Aligning due diligence with evolving regulatory expectations 
  • Supporting scalable compliance across multiple programs and regions

This approach enables teams to move from reactive reporting to proactive risk management, while maintaining defensible records that stand up to audits, inquiries, and border enforcement.

Watch our on-demand webinar, How to Comply with Global Human Rights Regulations at Scale, for a practical breakdown of key requirements, non-compliance risks, and how to manage human rights compliance at scale with technology.


About the author

Tiahna Broderick, Senior Sustainability Consultant

 

Tiahna is a Senior Sustainability Consultant at Source Intelligence, based in the UK. She brings over a decade of experience in compliance data analysis, including seven years specializing in environmental compliance. With deep expertise in Extended Producer Responsibility (EPR), Tiahna serves as a trusted subject matter expert in global e-waste, packaging, and battery legislation. In her role, she supports organizations by evaluating EPR obligations and delivering outsourced reporting and compliance consultancy, helping companies navigate complex and evolving global regulations.