Transport buyers and suppliers must exercise an active duty of care across recruitment, employment and subcontracting to ensure fair and ethical recruitment. Audit-based or compliance-only approaches are insufficient.
HREDD must actively prevent the conditions that enable coercion or control: identifying and prohibiting recruitment fees, deception about employment terms and conditions, document confiscation, withheld wages, excessive working hours, and any commercial or contracting practices that create debt, economic dependency or any condition that restricts workers’ freedom to leave abusive situations. This must extend across all operations and third-party relationships.
Effective prevention requires engagement with workers and their trade unions, including the ITF, to identify and monitor risks, and enforce protections through grievance and industrial relations mechanisms that help detect, prevent and eliminate forced labour and human trafficking risks in practice.
Where indicators of forced labour or human trafficking are identified, companies must act immediately to investigate, protect affected workers and deliver effective remediation. Failure to act carries severe legal, operational and reputational consequences.
Transport buyers and suppliers must be aware of and address forced labour indicators in supply chains
In transport supply chains, the following indicators may signal heightened risk and warrant closer due diligence:
Recruitment and employment practices
- Workers recruited through labour brokers or agencies who charge recruitment or placement fees.
- Misrepresentation of pay, working hours, job location or contract terms at the point of recruitment.
- Debt linked to licences, visas, training, equipment, accommodation or transport to work.
Control over workers and restriction of freedom
- Withholding of identity documents, seafarer books, passports or driving permits.
- Restrictions on workers’ ability to leave ships, vehicles, worksites, accommodation or employment.
- Threats of dismissal, blacklisting, deportation, or loss of future work if workers refuse assignments or raise concerns.
Pay, deductions, and dependency
- Delayed, irregular, or withheld wages, including withholding of final pay.
- Unexplained or excessive deductions for fuel, damage, recruitment costs, accommodation or administrative fees.
- Payment systems that make workers economically dependent on a single employer, client or platform, with no realistic alternative.
Working time, conditions, and isolation
- Excessive working hours or denial of rest that makes leaving work practically impossible.
- Long periods away from home, port, or country of employment without genuine consent.
- Isolation at sea, on the road, or in remote logistics sites with limited access to communication or support.
Abuse, intimidation, and retaliation
- Verbal abuse, threats, harassment or intimidation used to control workers.
- Retaliation against workers who raise concerns, seek representation, or contact trade unions or authorities.
- Barriers to accessing grievance mechanisms, trade unions or independent support.
Systemic risk factors
- Complex subcontracting or outsourcing chains that obscure responsibility.
- Heavy reliance on migrant, posted, or non-standard workers.
- Lack of effective worker representation or collective bargaining.
The presence of one indicator alone does not necessarily mean forced labour is occurring. However, multiple indicators, or indicators combined with worker dependency and lack of alternatives, significantly increase risk and require prompt attention.
Maritime Shipping
Warehousing + logistics
In transport supply chains, the following indicators may signal heightened risk and warrant closer due diligence:
Recruitment and employment practices
- Workers recruited through labour brokers or agencies who charge recruitment or placement fees.
- Misrepresentation of pay, working hours, job location or contract terms at the point of recruitment.
- Debt linked to licences, visas, training, equipment, accommodation or transport to work.
Control over workers and restriction of freedom
- Withholding of identity documents, seafarer books, passports or driving permits.
- Restrictions on workers’ ability to leave ships, vehicles, worksites, accommodation or employment.
- Threats of dismissal, blacklisting, deportation, or loss of future work if workers refuse assignments or raise concerns.
Pay, deductions, and dependency
- Delayed, irregular, or withheld wages, including withholding of final pay.
- Unexplained or excessive deductions for fuel, damage, recruitment costs, accommodation or administrative fees.
- Payment systems that make workers economically dependent on a single employer, client or platform, with no realistic alternative.
Working time, conditions, and isolation
- Excessive working hours or denial of rest that makes leaving work practically impossible.
- Long periods away from home, port, or country of employment without genuine consent.
- Isolation at sea, on the road, or in remote logistics sites with limited access to communication or support.
Abuse, intimidation, and retaliation
- Verbal abuse, threats, harassment or intimidation used to control workers.
- Retaliation against workers who raise concerns, seek representation, or contact trade unions or authorities.
- Barriers to accessing grievance mechanisms, trade unions or independent support.
Systemic risk factors
- Complex subcontracting or outsourcing chains that obscure responsibility.
- Heavy reliance on migrant, posted, or non-standard workers.
- Lack of effective worker representation or collective bargaining.
The presence of one indicator alone does not necessarily mean forced labour is occurring. However, multiple indicators, or indicators combined with worker dependency and lack of alternatives, significantly increase risk and require prompt attention.