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Reasonable & Proportionate Modern Slavery Reporting​

There is no one-size-fits-all response to modern slavery risk. Reasonable and proportionate action depends on the severity of the risk, the entity’s leverage, the nature of the relationship, and the decisions the business can actually influence. The goal is not perfect control. The goal is a defensible, risk-based response backed by evidence.

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One of the biggest weaknesses in modern slavery reporting is vague language.

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

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Section: 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. That may include 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.

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Section: 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.

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Section: 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

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Section: What good evidence looks like

A strong response is supported by evidence such as:

• supplier segmentation logic

• onboarding and tender controls

• audit or review outcomes

• corrective action records

• contract escalation pathways

• internal governance minutes

• remediation decisions

• repeatable risk criteria

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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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