THE PROBLEM
Vague language is the biggest weakness in modern slavery reporting.
Businesses say they are "committed." Policies say the right things. Statements describe intentions.
But when a board member, investor, regulator or journalist asks, "What did you actually do in response to identified risk?" — the answer is often thin.
This page sets out ESG Impact's framework for reasonable and proportionate action. We use that phrase deliberately. It avoids two common mistakes:
✕ Assuming every supplier requires the same level of scrutiny
✕ Using "limited leverage" as a reason to do too little
What reasonable action is
Reasonable action is action connected to the risk in front of you.
If risk is low, reasonable action may include supplier screening, contract controls, staff training, and targeted review.
​
If risk is elevated, reasonable action should become more operational — deeper due diligence, worker-centred inquiry, corrective action, board oversight, remediation pathways, and procurement intervention.
​
Reasonable action is not measured by how polished the statement sounds. It is measured by whether the response matches the nature and severity of the risk.
What proportionate action is
Proportionate action does not mean minimal action. It means calibrating effort to:
​
-
Severity of harm
-
Likelihood of occurrence
-
Level of business involvement
-
Leverage over the supplier or site
-
Maturity of the organisation's controls
-
Ability to influence outcomes over time
A proportionate response is still expected to be serious where the possible harm is severe.
EVIDENCE
What good evidence looks like
A strong response is supported by evidence such as:
What changed because of the review
Onboarding and tender controls
Audit or review outcomes
Corrective action records
Contract escalation pathways
Internal governance minutes
Remediation decisions
Repeatable risk criteria
THE SHIFT
Basic compliance vs leading practice
BASIC COMPLIANCE
Focuses on policy, annual questionnaires, training completion and statement production.
LEADING PRACTICE
Connects risk signals to business decisions. It shows:
How suppliers are prioritised​
What triggered deeper review
What changed because of the review
Who approved the response
How effectiveness is being tested​