With more than half of high-risk suppliers serving the UK retail sector lacking formal worker grievance channels, Antoine Heuty, senior vice president for Human Rights at EcoVadis, explains why retailers must close the gap between human rights commitments and conditions on the ground.
Retailers cannot address labour abuse they cannot see, and they cannot gain a reliable picture of conditions within their supply chains if workers have no safe way to speak.
When employees are unable to report unpaid wages, excessive overtime, harassment or coercion, serious human rights violations can remain hidden until they cause lasting harm to workers and significant legal, operational and reputational damage to businesses.
Retailers have invested heavily in human rights policies, supplier codes of conduct and social audits. These are important foundations, but they cannot alone reveal what is happening within factories, farms and other workplaces deep within global supply chains.
An EcoVadis report highlights the scale of this gap. It assessed 2,899 suppliers to UK retail and consumer goods companies between 2023 and 2025, including 242 based in countries classified as presenting a high risk of labour and human rights abuses.
Although 72% of these high-risk suppliers had a written human rights policy, 56% provided no formal channel through which workers could safely report labour-related concerns. Only 61% had introduced operational measures such as worker training, whistleblowing systems or third-party audits. Just one in five had reached an advanced level of maturity, combining a formal policy with at least four practical worker protection measures.
At the same time, the proportion of procurement by UK retail and consumer goods businesses coming from high-risk countries increased by 22% over two years. Retailers’ exposure is therefore rising precisely where the systems needed to identify and address exploitation remain weakest.
From policy to practice
A human rights policy is the beginning of due diligence, not its conclusion.
A commitment approved at corporate level has limited impact when a worker does not know it exists, cannot access a reporting channel in their own language or fears dismissal or retaliation if they raise a concern.
Traditional social audits only provide a partial picture. They are just a snapshot in time, and workers may be reluctant to speak openly when they do not trust that their identity will be protected.
Effective grievance mechanisms provide a more continuous source of intelligence. They help businesses identify emerging problems before they develop into systemic exploitation, supply disruption, public controversy or situations that are costly to manage.
However, establishing a telephone line or online form is not enough. A grievance mechanism is only effective when workers know about it, can access it easily, trust it and see evidence that concerns lead to action.
UK regulation is moving towards greater accountability
These findings come amid growing policy scrutiny of labour exploitation and forced labour in supply chains.
The recently introduced Immigration and Asylum Bill strengthens transparency expectations around forced labour, while the Independent Anti-Slavery Commissioner has called for more robust government action to prevent exploitation and hold organisations to account.
The Bill gives further impetus for businesses and organisations to take action as the Asylum Bill proposes changes to the reporting regime under section 54 of the Modern Slavery Act 2015. These cover: the requirement for an accuracy statement from the relevant signatory; extended scope to public bodies above a budget threshold; and financial penalties for non-compliance – up to £1 million or 1% of total turnover, whichever is greater.
For retailers, the direction of travel is clear. Publishing a modern slavery statement or supplier code will increasingly be viewed as insufficient. Businesses will need to demonstrate how risks are identified, what safeguards are operating within their supply chains and whether those measures are producing meaningful outcomes for workers.
Three priority actions for retailers
- Move to performance – prioritise supplier action rates over statement compliance in procurement due diligence.
- Close the consistency gap – apply heightened scrutiny to high-risk geographies, not just high-risk product categories.
- Centre the worker – require evidence that shows workers can access, understand and use grievance mechanisms in their own language, and that what they raise leads to a response. A modern slavery framework that doesn’t centre the worker is incomplete by design.
It should be noted that a higher number of complaints is not necessarily evidence that conditions are worsening. It may show that workers trust the system enough to use it. The critical measure is whether concerns are investigated and resolved.
Worker grievance mechanisms should not be treated as peripheral ESG initiatives. They are essential business controls that help retailers identify risks conventional monitoring can miss.
The findings expose a dangerous mismatch: sourcing from high-risk markets is increasing, while many workers most vulnerable to exploitation still lack a safe route to report it. Closing that gap is fundamental to protecting workers, meeting growing regulatory expectations and ensuring retailers can substantiate the human rights commitments they make.
