Data story: Tracking forced labor risks and due diligence outcomes across global supply chains

Why It Matters

An estimated 27.6 million people remain trapped in forced labor globally, a figure that rose by 2.7 million between 2016 and 2021 according to the International Labour Organization (ILO, 2022), and independent assessments suggest the number has continued to climb through 2025. For multinational corporations, the human toll intersects with escalating regulatory and financial risk: the EU Corporate Sustainability Due Diligence Directive (CSDDD), Germany's Lieferkettensorgfaltspflichtengesetz (LkSG), and the US Uyghur Forced Labor Prevention Act (UFLPA) collectively require thousands of companies to identify, prevent, and remediate forced labor across their supply chains or face penalties, import bans, and reputational damage. Despite this convergence of moral imperative and regulatory mandate, compliance rates remain patchy, enforcement is uneven, and deep-tier visibility is still the exception rather than the norm.

Key Concepts

Forced labor is defined by the ILO as work or service exacted under the menace of penalty and for which the person has not offered themselves voluntarily. It encompasses debt bondage, trafficking, and state-imposed labor across both private and public sectors.

Human rights due diligence (HRDD) is the ongoing process through which companies identify, prevent, mitigate, and account for adverse human rights impacts in their operations and supply chains. Frameworks such as the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct provide the baseline methodology.

Withhold Release Orders (WROs) are enforcement instruments used by US Customs and Border Protection (CBP) to detain imports suspected of being produced with forced labor. WROs have become one of the most consequential enforcement tools globally, with goods worth billions of dollars detained or denied entry since the UFLPA took effect in June 2022.

Social auditing refers to third-party inspections of supplier workplaces against labor standards. While widely used, traditional social audits have been criticized for failing to detect forced labor indicators such as document retention, wage withholding, and restrictions on movement.

The Data

The scale of the problem and the pace of regulatory response are both accelerating:

• The ILO's 2022 Global Estimates placed forced labor at 27.6 million victims, with 17.3 million in the private economy (ILO, 2022). The Asia-Pacific region accounted for approximately 15.1 million victims, more than any other region.
• US CBP blocked or detained over $3.6 billion worth of goods under the UFLPA between June 2022 and December 2025, with roughly 65 percent of enforcement actions targeting the solar, cotton/apparel, and electronics sectors (CBP, 2025).
• Germany's LkSG, enforced by the Federal Office for Economic Affairs and Export Control (BAFA), received over 730 complaints in its first 18 months of operation (January 2023 to June 2024). BAFA conducted compliance audits of approximately 350 companies and issued formal warnings to 48 (BAFA, 2024).
• KnowTheChain's 2025 benchmark assessed 120 of the world's largest food, apparel, and ICT companies against forced labor indicators. The average benchmark score was 26 out of 100, essentially unchanged from 24 out of 100 in its 2022 cycle, indicating systemic stagnation in corporate performance (KnowTheChain, 2025).
• The Corporate Human Rights Benchmark (CHRB), now integrated into the World Benchmarking Alliance, found that only 18 percent of assessed companies had grievance mechanisms meeting UN Guiding Principles effectiveness criteria in 2025, down from 21 percent in 2023 (World Benchmarking Alliance, 2025).

Trend Analysis

Enforcement is intensifying faster than corporate preparedness. The UFLPA shifted the enforcement paradigm from voluntary disclosure to active import detention. CBP's forced labor division expanded its staffing by 40 percent between 2023 and 2025, and the average review time for detained shipments shortened from 45 days to 28 days as processes matured (CBP, 2025). The EU CSDDD, adopted in 2024 with transposition deadlines beginning in 2027, will extend mandatory due diligence obligations to approximately 13,000 EU companies and thousands of non-EU firms with significant EU revenue. Companies that have not invested in HRDD systems face compounding compliance burdens.

Audit fatigue is driving a shift toward worker voice technology. Traditional social audits detect fewer than 30 percent of forced labor indicators according to research by the Fair Labor Association (FLA, 2024). Leading brands are supplementing or replacing audits with worker voice platforms that use mobile surveys, anonymous hotlines, and data analytics to capture real-time conditions. Unilever deployed its "Worker Connect" programme across 400 supplier sites by 2025, reaching over 150,000 workers in Southeast Asia and South Asia (Unilever, 2025). The data collected through these channels identified labor violations at three times the rate of traditional audits in comparable facilities.

Traceability technology is closing deep-tier gaps. Supply chain mapping beyond Tier 1 has long been the weakest link in HRDD. Platforms such as Sourcemap, TrusTrace, and Altana AI now offer multi-tier mapping using trade data, customs records, and supplier self-disclosure. Apple's Supplier Responsibility programme, which traced 100 percent of identified cobalt and lithium supply chains to the smelter/refiner level by 2024, remains a high-water mark for deep-tier transparency (Apple, 2025). However, such granularity is capital-intensive and remains rare outside technology and automotive sectors.

Regional Patterns

Asia-Pacific hosts the highest absolute concentration of forced labor victims. Manufacturing hubs in Malaysia, Thailand, Vietnam, and parts of China present elevated risks in electronics assembly, palm oil processing, fishing, and garment production. Malaysia's electronics sector faced multiple WROs between 2022 and 2025, prompting the Malaysian government to strengthen its National Action Plan on Forced Labour and expand labor inspection capacity.

Sub-Saharan Africa faces acute risks in artisanal mining, agriculture, and domestic work. Cobalt mining in the Democratic Republic of the Congo remains the most scrutinized supply chain, with the Responsible Minerals Initiative (RMI) reporting that 78 percent of industrial cobalt smelters participated in its assurance programme by 2025, though artisanal and small-scale mining remains largely unaudited (RMI, 2025).

Europe operates primarily as a regulatory driver and downstream market. The EU's combined framework of the CSDDD, the proposed Forced Labour Regulation (prohibiting the sale of goods produced with forced labor on the EU market), and the CSRD creates the most comprehensive due diligence architecture globally. However, enforcement depends on member-state transposition and supervisory capacity, which varies significantly.

North America centers enforcement on import controls. The UFLPA's rebuttable presumption framework places the burden of proof on importers to demonstrate that goods from the Xinjiang Uyghur Autonomous Region are free of forced labor. This mechanism has reshaped sourcing decisions in solar, cotton, tomatoes, and polysilicon supply chains.

Latin America presents risks in agriculture, fishing, and construction, particularly in Brazil, where government-led "dirty lists" of employers found using forced labor have been internationally recognized as an effective enforcement tool. Brazil's lista suja identified over 260 employers in its 2024/2025 cycle (Ministry of Labor, Brazil, 2025).

Sector-Specific KPI Benchmarks

Automotive companies score highest on KnowTheChain benchmarks, driven by established responsible mineral sourcing frameworks and OEM-led supply chain programmes. Food and agriculture companies consistently score lowest, reflecting fragmented supply chains with millions of smallholder producers.

What the Data Suggests

The data points to three structural conclusions.

First, legislation works as a forcing function but not yet as a guarantee of outcomes. Import detentions under the UFLPA and complaint-driven investigations under the LkSG are compelling companies to invest in traceability and due diligence systems. However, KnowTheChain's stagnant benchmark scores suggest that many companies are building compliance infrastructure without fundamentally changing sourcing practices or power dynamics within their supply chains.

Second, worker-centric approaches deliver better detection. Unilever's worker voice programme and similar initiatives by Marks and Spencer, which rolled out anonymous digital feedback channels across 500+ supplier factories by 2025, consistently identify more labor rights violations than traditional audit-only approaches. The data supports a growing consensus that effective HRDD must include channels through which workers themselves can report conditions without fear of retaliation.

Third, deep-tier visibility remains the critical gap. Most companies have reasonable oversight of Tier 1 suppliers, but visibility drops sharply at Tier 2 and beyond. The sectors with the highest forced labor risk, such as raw material extraction and agricultural production, sit at the deepest tiers of global supply chains. Closing this gap requires industry-wide data-sharing, regulatory incentives for upstream transparency, and investment in traceability technology that can operate in low-infrastructure environments.

Key Players

Established Leaders

• KnowTheChain — Publishes the leading corporate benchmark on forced labor due diligence, assessing 120+ companies across food, apparel, and ICT sectors.
• Fair Labor Association (FLA) — Accredits company compliance programmes and conducts independent assessments of supply chain labor conditions.
• Responsible Minerals Initiative (RMI) — Provides tools and assurance programmes for responsible mineral sourcing, covering cobalt, tin, tantalum, tungsten, and gold.
• Walk Free Foundation — Produces the Global Slavery Index and advocates for legislative and corporate action against modern slavery.

Emerging Startups

• Sourcemap — Supply chain mapping and traceability platform enabling multi-tier visibility for human rights due diligence.
• TrusTrace — Product traceability platform used by fashion and textile brands to verify supplier compliance from fiber to finished goods.
• Altana AI — AI-powered supply chain intelligence platform that maps global trade networks to identify hidden forced labor risks.
• Ulula — Worker engagement platform using mobile-based surveys and anonymous reporting to capture real-time labor conditions.

Key Investors/Funders

• Humanity United — Philanthropic organization funding technology and systemic approaches to combat forced labor and human trafficking.
• US Department of Labor (Bureau of International Labor Affairs) — Funds global research on child labor and forced labor through its ILAB programme, publishing the influential List of Goods Produced by Child Labor or Forced Labor.
• Laudes Foundation — Invests in fair labor practices and responsible supply chain transformation across fashion and built environment sectors.

Action Checklist

• Conduct a forced labor risk assessment across your entire supply chain, prioritizing sectors and geographies identified as high-risk by the ILO and the US Department of Labor's List of Goods.
• Map supply chains to at least Tier 2, and to the raw material level for commodities with known forced labor prevalence (cotton, cobalt, palm oil, polysilicon, seafood).
• Supplement or replace traditional social audits with worker voice platforms that enable anonymous, real-time reporting by supply chain workers.
• Establish a grievance mechanism that meets UN Guiding Principles effectiveness criteria: legitimate, accessible, predictable, equitable, transparent, rights-compatible, and a source of continuous learning.
• Review procurement contracts to ensure they include enforceable human rights clauses and responsible purchasing practices that do not create conditions conducive to forced labor (such as excessive price pressure or last-minute order changes).
• Prepare for CSDDD transposition by aligning internal HRDD processes with the directive's requirements for identifying, preventing, mitigating, and remediating adverse impacts.
• Publish annual human rights due diligence reports with outcome-level data, not just process descriptions, to demonstrate substantive progress to regulators, investors, and civil society.

FAQ

How many people are currently in forced labor globally? The ILO's most recent Global Estimates (2022) identified 27.6 million people in forced labor worldwide, a 12 percent increase from the 2016 estimate of 24.9 million. Of these, 17.3 million were in forced labor exploitation in the private economy, 6.3 million were in forced commercial sexual exploitation, and 3.9 million were in state-imposed forced labor. Independent researchers estimate the true figure is likely higher because of underreporting in conflict zones, authoritarian states, and informal economies.

Which industries face the highest forced labor risk? Agriculture and fishing, electronics manufacturing, garment and textile production, construction, mining, and domestic work consistently rank as the highest-risk sectors. Within global supply chains, the commodities most frequently associated with forced labor include cotton, cobalt, palm oil, sugarcane, rubber, seafood, and polysilicon. Risk levels vary by geography, with Southeast Asia, Sub-Saharan Africa, and parts of Central Asia presenting the most concentrated challenges.

Are social audits effective at detecting forced labor? Research consistently shows that traditional social audits detect fewer than 30 percent of forced labor indicators (FLA, 2024). Audits are typically announced in advance, conducted over one to two days, and rely on management-mediated worker interviews. They are effective at identifying visible workplace hazards and documentation gaps but struggle to detect coercion, debt bondage, wage theft, and restrictions on freedom of movement. Companies leading in this space are combining audits with worker voice technology, unannounced inspections, and deep-tier mapping to create layered detection systems.

What are the penalties for non-compliance with forced labor regulations? Penalties vary by jurisdiction. Under the UFLPA, goods can be detained, excluded from US markets, or seized entirely, with importers bearing the burden of proving that goods are not produced with forced labor. Germany's LkSG allows fines of up to 2 percent of global annual turnover for companies with more than EUR 400 million in revenue. The EU CSDDD, once transposed, will introduce civil liability provisions enabling victims to seek compensation, alongside administrative fines set by member states. Reputational costs can be equally significant: companies publicly associated with forced labor face consumer boycotts, investor divestment, and loss of government contracts.

How can companies improve deep-tier supply chain visibility? Start by mapping critical commodity supply chains from finished product back to raw material origin, focusing on the highest-risk inputs. Use trade data analytics platforms like Altana AI to identify undisclosed sub-suppliers. Participate in industry initiatives such as the RMI for minerals or the Fair Food Program for agricultural supply chains. Invest in supplier capacity building at Tier 2 and beyond, recognizing that many upstream suppliers lack the resources or knowledge to implement human rights management systems independently. Multi-stakeholder collaboration is essential because no single company can achieve full visibility across deeply fragmented global supply networks.

Sources

• ILO, Walk Free, & IOM. (2022). Global Estimates of Modern Slavery: Forced Labour and Forced Marriage. International Labour Organization.
• US Customs and Border Protection. (2025). UFLPA Enforcement Statistics: Shipment Reviews, Detentions, and Sector Breakdown (June 2022 – December 2025). CBP.
• BAFA. (2024). LkSG Implementation Report: Complaints, Audits, and Enforcement Actions (January 2023 – June 2024). Federal Office for Economic Affairs and Export Control, Germany.
• KnowTheChain. (2025). 2025 Benchmark Report: Forced Labour Due Diligence in Food, Apparel, and ICT Supply Chains. KnowTheChain / Business & Human Rights Resource Centre.
• World Benchmarking Alliance. (2025). Corporate Human Rights Benchmark: Methodology and Results 2025. World Benchmarking Alliance.
• Fair Labor Association. (2024). Beyond Social Auditing: Effectiveness of Traditional Compliance Assessments in Detecting Forced Labour. FLA.
• Apple. (2025). Supplier Responsibility Progress Report 2025: Mineral Supply Chain Traceability. Apple Inc.
• Unilever. (2025). Human Rights Report 2024/25: Worker Connect Programme Outcomes and Impact Data. Unilever PLC.
• Responsible Minerals Initiative. (2025). RMI Annual Report: Smelter and Refiner Assurance Coverage. RMI.
• Ministry of Labor, Brazil. (2025). Lista Suja: Employers Identified Using Conditions Analogous to Slavery (2024–2025 Cycle). Government of Brazil.