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Reasonable & Proportionate Modern Slavery Reporting​

Risk-based due diligence is the process of identifying, prioritising, addressing and monitoring modern slavery risk in a way that reflects where harm is most likely and most severe. It is not a box-ticking exercise. It is a decision-making model that links risk signals to action.

For many organisations, “due diligence” has become an overused term.

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

That is not enough.

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

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The purpose of due diligence

The purpose of due diligence is not to prove that risk does not exist. It is to show that the organisation:

• understands where exposure is most likely

• makes informed decisions about priority areas

• acts when red flags appear

• monitors whether action is working

• improves over time

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The core stages

A practical modern slavery due diligence model should cover:

• risk identification

• prioritisation

• supplier and labour model review

• action and mitigation

• escalation and remediation

• monitoring and effectiveness review

• reporting and governance

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What due diligence looks like in practice

In practice, this may include:

• 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

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Why risk-based matters

Not every supplier requires the same treatment.
Not every red flag indicates the same level of harm.
Not every organisation has the same leverage.

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

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Next Steps:

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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