Forced labour and human trafficking are among the most severe human and labour rights violations, prohibited under international law, the ILO forced labour conventions and many national level laws. Transport buyers and suppliers face serious legal, operational and reputational consequences where such violations occur.
Forced labour is work exacted under threat or coercion and not undertaken voluntarily. It manifests through exploitative recruitment, subcontracting and abuse of workers’ immigration or employment status to create dependency and control. In transport it is usually hidden, particularly where workers face debt bondage, restricted freedom of movement or barriers that prevent them from speaking up or leaving employment without penalty.
The risk factors are well established: the use of labour brokers or recruitment agencies, recruitment fees, confiscation of identity documents, withheld wages, excessive working hours, and threats of dismissal or deportation. These risks are driven by:
- Exploitative recruitment and employment practices
- Misleading workers on wages and conditions, or trapping them in debt through fees and employment related costs.
These risks are compounded by:
- Withheld wages
- Dependence on a single employer or platform
- Financial obligations tied to employment – such as housing – which can create situations of debt bondage.
The abuse of immigration or employment status, including threats of dismissal and deportation, is used to control workers and prevent them from reporting abuse, refusing unsafe work or leaving. Isolation and limited access to complaint mechanisms restrict workers’ ability to seek help or leave abusive conditions, while subcontracting, insecure work and barriers to worker representation further increase vulnerability and limit access to protection and remedy. Migrant and cross-border workers are the most exposed, especially where multiple jurisdictions are involved, and where regulation and enforcement are weak and fragmented.
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.
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.
