COPY PRE: 11 MARCH
The risk
Forced labour and human trafficking are among the most severe human and labour rights violations. Forced labour itself, as well as many of its contributing elements individually, are outlawed by human rights treaties. The two ILO forced labour conventions have almost universal ratification and must be respected by all ILO member states as fundamental principles. Companies and transport supply chain actors face severe legal, operational and reputational consequences in the event of such violations being found in their supply chains.
Forced labour involves work performed under a threat of a penalty without free and informed consent These abuses frequently manifest through exploitative recruitment practices, subcontracting arrangements, power imbalances between workers, employers and intermediaries, and the abuse of workers’ immigration or employment status to create dependency and control. In transport operations, forced labour may not be immediately visible, particularly where workers are subjected to coercion, debt bondage, restrictions on their freedom of movement or conditions that prevent them from speaking up or leaving employment freely and without penalty.
Common risk factors across transport sectors include the use of labour brokers or recruitment agencies, recruitment fees or debt bondage, withholding of identity documents, delayed or withheld wages, excessive working hours, and threats of dismissal, deportation or the loss of future work. Workers also experience restrictions on movement, limited access to communication and pressure to accept unsafe or unlawful conditions.
Migrant, posted or cross-border workers are particularly vulnerable to forced labour and human trafficking, especially where there are multiple jurisdictions involved, and fragmented and weak regulation and/or enforcement.
- In maritime transport, risks arise where seafarers are recruited through intermediaries, deceived about terms and conditions, subjected to delayed of non-payment wages, or prevented from leaving vessels at the end of contracts. Isolation at sea, long periods away from home and limited access to complaint mechanisms further heighten risks and restrict workers ability to seek help or leave.
- In road transport, including long-distance freight and passenger transport, risks arise from extended periods away from home, dependence on a single employer or platform, debt tied to licences or equipment. Debt bondage and non-payment of wages can leave drivers without the financial means to leave employment or repatriate themselves. Beyond this, threats and intimidation from employers and intermediaries linked to immigration or employment status can also prevent drivers from refusing unsafe work, reporting abuses or leaving employment.
- In warehousing and logistics, risks can arise through agency work, temporary contracts and outsourced operations, particularly where workers are recruited through labour brokers, housed by employers or dependent on continued employment to maintain immigration or legal status. Excessive overtime, threats of dismissal and barriers to worker representation can further increase vulnerability and limit access to protection and remedy.
Companies and supply chain actors are responsible for preventing, identifying and addressing forced labour and human trafficking across their transport supply chains. This requires companies to conduct HRDD and exercise active duty of care across recruitment, employment and subcontracting. Audit-based or compliance-only approaches are insufficient.
HRDD processes must actively prevent conditions that enable forced labour, particularly through recruitment and employment practices that create coercion or control. This includes identifying and prohibiting recruitment fees, deception about employment conditions, confiscation or control of identity documents, withheld or delayed wages, excessive working hours, and commercial or contracting practices that create debt, economic dependency or any condition that restricts workers’ freedom or traps them in abusive situations.
As highlighted in the section in this guidance on subcontracting, companies’ and supply chain actors’ HRDD obligations extend throughout contracted and subcontracted transport services: they must ensure clear allocation of responsibilities across contracting chains, maintain transparency in subcontracting relationships, and align commercial decisions with safe and decent employment practices.
Effective prevention requires ongoing engagement with workers and their trade union representatives to identify risks, monitor standards and ensure protections are applied consistently across the supply chain. Working with the ITF and our affiliated trade unions enables companies to access worker-led monitoring, trusted reporting channels and established 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 implement effective remediation. Failure to act exposes companies and supply chain actors to severe legal, operational and reputational consequences.
Maritime Shipping
