Slavery resources

As part of the expanding global landscape of business and human rights legislation, several countries have either implemented or are in the process of introducing import and product bans to prevent the market flow of goods made with forced labour.

While these legislative efforts are increasing, differing approaches are emerging as to whether and which forms of child labour should fall into the scope of product and import bans. There are important nuances that must be considered in developing tools to tackle child labour.

Increasingly, countries have, or are legislating, instruments to ban the import of products made by forced labour. These include the US, Canada and Mexico. The EU Forced Labour Regulation, which bans the sale, import and export of goods made using forced labour, is the most recent piece of such statute. Given that the EU single market is currently the world’s largest consumer market, the Regulation has the potential to influence business practices globally, to prevent, end or mitigate forced labour, and to stop companies profiting from forced labour in their supply chains. The Regulation could also drive progress in legislative efforts related to forced labour in other countries, whose companies may be impacted by robust enforcement of the Regulation. Importantly, the Regulation will address a significant gap in the EU legislative framework, as there has previously been no instrument in the EU that prohibits the market flow of products made with forced labour.

The Regulation provides that the Union seeks to eradicate the use of forced labour and promote decent work and labour rights worldwide. Article 11(f) states the European Commission shall make available guidance for economic operators on due diligence in relation to forced labour imposed by state authorities. The purpose of this briefing is to inform the due diligence guidance that the Commission will publish in relation to state-imposed forced labour. It provides what due diligence efforts are expected of companies to identify risks of state-imposed forced labour in operations and supply chains, when disengagement is necessary, and what steps should be taken to swiftly disengage. The draft due diligence provided herein aligns with international guidelines and established principles by international organisations including the ILO, the OECD and the United Nations. 

The briefing also provides a comprehensive explanation of how state-imposed forced labour is distinct from forced labour carried out by private actors. In the former, it is the State –  which has obligations under core human rights treaties and ILO Conventions to protect its population, including from forced labour – that is the perpetrator. This type of forced labour, therefore, requires a different response by companies as the  abuse is carried out in pursuit of government policy and is maintained by the state apparatus itself. This briefing also includes examples of how state-imposed forced labour is currently carried out in various geographic locations and across sectors.

Response to The Employer Pays Principle Feasibility Study within the Horticulture Value Chain

On 8 July 2025, the “Employer Pays Principle Feasibility Study within the Horticulture Value Chain” was published by Alma Economics following co-commissioning by the Department of Environment, Food and Rural Affairs and Seasonal Worker Scheme Taskforce. The Employer Pays Principle (EPP) states that no worker should pay for a job – the costs of recruitment should be borne by the employer not the employee. Respect for the principle is fundamental to combatting exploitation, forced labour and trafficking in global supply chains.

The UK government has a duty to safeguard the welfare and interests of migrant seasonal workers who play a crucial role in propping up the horticulture sector and the food supply chain more generally.  It also has a duty to other stakeholders in the horticulture supply chain, including growers. Private sector actors must be held more accountable for their role in upholding the welfare and human rights of workers on the SWV, but the UK government also cannot abdicate its responsibility on these issues. Indeed, the UK government’s recently updated “Transparency in supply chains” guidance states that companies wishing to undertake responsible recruitment “should follow the Employer Pays Principle”. The government therefore cannot sensibly call for anything but the mandatory implementation of EPP on the SWV if it takes its own commitments around responsible business conduct and human rights seriously. We therefore call on the government to swiftly coordinate the safe and ethical implementation of EPP on the SWV in a way that protects workers.

The platform economy, a business model centred on the use of digital platforms, is attracting growing attention from human rights and civil society organisations, trade unions, international organisations and governments. This business model is reshaping ways of working, which evolve with technological advancements. It allows businesses to cut operating costs and expand quickly. Consumers, in turn, should enjoy greater convenience, more choice and simplified transactions.

Despite the many possible benefits for platforms and consumers, emerging evidence has shown how this business model is also leading to platform workers experiencing human and labour rights violations. These are exacerbated by the limited legal protections in this non-traditional sector, where workers are mostly (mis-)classified as independent contractors, which denies them the enjoyment of basic labour rights.

In this paper, we support the argument that the platform economy is structurally exploitative, with risks of labour rights violations and potential risks to forced labour rooted in its core business model, particularly due to the nature of the relationship between platforms and workers and the use of algorithmic management to allocate work. Yet, we also acknowledge that these same elements make it difficult to capture the concrete manifestations in this sector of the concepts underpinning the definition of forced labour, i.e. involuntariness and coercion, making more research crucial to further unpack the findings and analysis this paper offers.

By having in-depth conversations with a small select group of workers in two jurisdictions, this paper hopes to contribute to the evolving discussions on decent work in the platform economy, to improve labour protections for workers by addressing the complexity of the risks to which they are exposed. It also hopes to encourage further research and analysis on how international forced labour indicators frameworks can be applied to this growing business model, including how to make sure that relevant frameworks can be contextualised and adapted to respond to the evolving and emerging business models and employer-employee relationships of the future.

Introduction 

Under international responsible business standards such as the UN Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines), and the ILO Declaration on Multinational Enterprises and Social Policy, businesses have a responsibility to respect human rights and to conduct appropriate due diligence to assess, prevent, mitigate, and remedy adverse human rights impacts, including forced labour.  

These non-binding standards are reinforced by the new mandatory due diligence frameworks that are emerging in jurisdictions across the world, particularly the European Union’s Corporate Sustainability Due Diligence Directive. Alignment with these standards is thus a growing imperative. 

State-imposed forced labour, which takes place when governments force people to work, is often present in global supply chains. It has distinct implications for businesses, including the lack of business leverage to change forced labour practices, and the inability to conduct safe and credible due diligence on the ground. In these cases, full and immediate disengagement from affected industries in regions where state-imposed forced labour takes place is necessary to meet responsible business standards. Companies should also recognise that continued sourcing from and involvement in state-imposed forced labour likely supports the upholding of these systems of abuse and perpetuates the status quo. 

This factsheet summarises Anti-Slavery International’s recommendations on how to effectively address state-imposed forced labour under responsible business standards. It is the result of years of collaboration with partners and practitioners that seek to address state-imposed forced labour, particularly with the Coalition to End Forced Labour in the Uyghur Region and the Cotton Campaign. 

This factsheet is broken down into two sections:  

• Factsheet One: What is state-imposed forced labour and the implications for business  
  Factsheet One is to support all readers to better understand what state-imposed forced labour is, how the nature of state-imposed forced labour creates specific implications for responsible business conduct, and how to apply the UNGPs and OECD Guidelines in this context. 
• Factsheet Two: Considering state-imposed forced labour in due diligence processes  
  Factsheet Two is to support business practitioners to take into consideration the implications of state-imposed forced labour when designing and implementing due diligence processes under international standards. Additionally, the factsheet also outlines the implications of relevant EU legislation, namely the EU Corporate Sustainability Due Diligence Directive (noting that in February 2025, a significant revision of the text was proposed and is currently being considered), and the EU Regulation Prohibiting Products Made with Forced Labour on the Union Market. 

National competent authorities under the EU Forced Labour Product Ban Regulation will have two core duties:

1. Investigating products made with forced labour within EU Member States,
2. Deciding on and enforcing product bans, with complementary obligations of cooperation with the European Commission and other EU Member States.

This note offers recommendations to designate such authorities based on criteria of effectiveness and efficiency.

The European Center for Constitutional and Human Rights (ECCHR) and Anti-Slavery International publish Understanding the EU Forced Labour Regulation: Assessment and Recommendations.  

This essential analysis explains the provisions of the final text and outlines what needs to be done for implementation. It aims to help civil society organisations and allies active in the sector to advocate for the effective implementation of the Regulation and support enforcement of the ban of forced labour goods. 

Targeted action is needed to eliminate forced labour, protect the most vulnerable groups and effectively address the root causes of forced labour. The EU Forced Labour Regulation, which entered into force on 13 December 2024, is part of a global shift towards targeted action to eliminate forced labour in global supply chains.  

Briefing for the Universal Periodic Review Pre-Session 47 (2024).

At Qatar’s last Universal Periodic Review in 2019, it received 52 recommendations related to the protection of migrant workers, supporting 39 and noting 13. Yet Qatar demonstrated a weak record of implementing recommendations, including on existing worker protection laws on recruitment fees and wage theft. As a result, migrant workers continue to experience significant rights violations – including discrimination, forced labour conditions, and exposure to serious health risks. Combined with barriers to freedom of association, migrant workers face intimidation, threats for reporting violations, and lack remedy and access to justice. In construction, hospitality, security, and domestic and care work, workers report abusive workplace conditions, particularly related to exposure to excessive heat without proper occupational health and safety precautions. Despite Qatar’s initiatives with the ILO to streamline grievance mechanisms and strengthen labour inspections, rights violations remain largely unchecked.

To fulfil its commitment to eliminate forced labour from global value chains, the UK must introduce
import controls on products tainted with forced labour. Anti-Slavery International calls on the UK
Government to introduce primary legislation to ban the import of goods tainted with forced
labour. The ban should cover products made (in whole or in part) or transported using forced
labour. This briefing document outlines the rationale behind this call, as well as the elements that the
proposed law must include.

Anti-Slavery International is campaigning alongside the Corporate Justice Coalition and other organisations to make the case for a new Business Human Rights and Environment Act (BHRE).

We have published a policy paper with an overview of the rationale behind our legislative call. We outline the UK’s current lack of mechanisms to hold companies accountable for a failure to prevent abuses, the need to level the playing field between businesses, as well as the urgency for guaranteeing access to justice for victims of corporate abuses. We also provide a series of recommendations to ensure the UK plays its part in addressing forced labour in value chains. This includes both the principal elements of the BHRE Act and a wider mix of additional measures.

Note this policy paper was updated in July 2024.