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MODERN SLAVERY

Risk-Based Modern Slavery Due Diligence

Risk-based due diligence identifies, prioritises, addresses and monitors modern slavery risk where harm is most likely and most severe. It's a decision-making model that links risk signals to action.

THE PROBLEM

"Due diligence" has become an overused term.

Sometimes it means onboarding checks. Sometimes contract terms. Sometimes a desktop review completed before statement season. 
 

That is not enough.

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A risk-based due diligence model asks a harder question: how does the organization decide where to look more closely, when to intervene, and what evidence shows the response was adequate?

PURPOSE

The purpose of due diligence

The purpose isn't to prove that risk doesn't exist. It's to show that the organisation:

01

What changed because of the review

02

Makes informed decisions about priority areas

03

Acts when red flags appear

04

Monitors whether action is working

05

Improves over time

THE SHIFT

The core stages

A practical modern slavery due diligence model should cover:

STAGE 1

Risk identification

STAGE 3

Action and mitigation

STAGE 2

Prioritisation

STAGE 4

Escalation and remediation

STAGE 3

Supplier and labour model review

STAGE 5

Monitoring and effectiveness review

STAGE 6

Reporting and governance

IN PRACTICE

What due diligence looks like in practice

Industry and category risk mapping

Country and labour model indicators

Supplier onboarding controls

Contract clauses linked to labour standards

Recruitment-fee review

Subcontracting visibility

Worker voice channels

Site-level escalation when indicators are serious

Executive oversight for high-risk decisions

WHY IT MATTERS

Why risk-based matters

Not every supplier requires the same treatment.

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Not every red flag indicates the same level of harm.

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Not every organisation has the same leverage.

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Risk-based due diligence allows organisations to focus effort where harm could be greatest while still maintaining a defensible enterprise-wide framework.

SECTOR COVERAGE

Industries We Serve

Senior-led ESG advisory across the sectors most exposed to environmental, social and governance risk — calibrated to each industry's regulatory and stakeholder profile.

Need a practical view of reform risk?

ESG Impact helps boards, legal teams and procurement leaders interpret reform developments and translate them into proportionate, workable action.

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