Research by Ruby Jones and Zoe Jewell from the Australian National University.
Laws targeting modern slavery and other human rights abuses in supply chains are multiplying. Disclosure-based laws like the UK and Australian MSAs rely on corporate reporting, and the scrutiny it enables, to encourage action. Human Rights Due Diligence (HRDD) laws go further, imposing concrete obligations and requiring companies to report on how they meet them. Both types mandate disclosure, but the obligations differ significantly. This raises a key question: how does the type of law shape corporate reporting?
We conducted a comparative qualitative analysis of reports from twenty companies (or their subsidiaries) that reported under both the UK or Australian Modern Slavery Acts (MSA) and at least one European HRDD law — France’s Devoir de Vigilance (DDV), Norway’s Transparency Act (NTA), or Germany’s Supply Chain Due Diligence Act (LkSG). The companies span sectors including fashion, automotive, and electronics. Using Wikirate’s Beyond Compliance criteria, we assessed transparency across key areas: preventative measures, incident identification and remediation, whistleblowing mechanisms, and supply chain worker engagement.
Our analysis finds that reports under both disclosure-based and due diligence laws focus heavily on commitments and remain superficial when reporting actual actions and impacts, often omitting critical information such as incident reporting, remediation, and the accessibility of whistleblowing channels for supply chain workers. HRDD laws, despite stricter requirements, deliver modest improvements in transparency.
This matters because disclosures are meant to give governments, civil society, and investors insight into how companies manage modern slavery risks. When transparency is limited, stakeholders cannot assess the quality of corporate due diligence.
Do companies disclose incidents and remediation efforts?
Our analysis shows that companies that fail to report forced labour incidents under one framework usually do so under others as well: 85% reported no specific incidents under any regime. Germany’s LkSG is an exception, with reports providing comparatively more data on incidents due to the law’s prescriptive reporting requirements. HRDD reports generally include more information on the number of grievances submitted (e.g., recruitment fees, excessive working hours). However, most grievances are described imprecisely, with numbers tied to broad categories and little context on the nature or circumstances of specific violations, or whether they have been verified.
Remediation reporting shows similar inconsistencies in both depth and transparency. Patterns are stronger within companies than across jurisdictions: when a company’s MSA report is detailed, its HRDD disclosure tends to be of comparable quality. Some companies provide structured, quantitative data and clear descriptions of remedial actions, while others offer only broad or superficial statements.
This highlights an underlying tension: reporting should enhance transparency, but it can also create reputational or legal risks. As a result, disclosure could be treated as a threat rather than an opportunity. To make it meaningful, reporting should be framed as a proactive tool for accountability and improvement, not merely a compliance exercise.
Are grievance mechanisms accessible to supply chain workers?
Grievance mechanisms are essential for due diligence, yet they often remain inaccessible to supply chain workers due to language barriers, limited awareness, or the inability to identify buyer brands. Removing these barriers is crucial to ensure workers can lodge complaints and trigger remediation processes, as indicated by the UN Global Compact.
Across our sample, most companies failed to provide sufficient information on the accessibility of their grievance mechanisms or whistleblowing channels, regardless of the reporting regime. Reports rarely stated clearly that supply chain workers are entitled to file complaints, referring instead to “suppliers” or “stakeholders.” Only one-third of reports included even superficial information on how mechanisms were communicated to supply chain workers, and some shifted responsibility onto suppliers to conduct awareness-raising or put in place grievance mechanisms at the factory level. Two companies described mechanisms targeting specific worker groups — for example, migrant workers at Tier 2 suppliers in Taiwan — or reported the proportion of manufacturing sites covered by Worker Voice tools.
Do companies engage with supply chain workers?
Engagement with supply chain workers and/or their representatives is critical in helping companies identify issues that formal audits or management systems might overlook and to design more targeted remediation or preventative measures. Meaningful stakeholder engagement is a key component of internationally recognized standards such as the OECD Due Diligence Guidance for Responsible Business Conduct.
Only a small number of reports included references to engagement or maintaining regular dialogue with workers organizations or NGOs. Just five reports described specific interactions with supply chain workers. For instance, both of Samsung’s reports detailed off-site interviews with workers from nine suppliers, including migrant workers in Malaysia, while Nestlé’s MSA report outlined income diversification and training programmes in Côte d’Ivoire and Honduras.
Improving direct engagement with supply chain workers and their representatives is essential to ensure good working conditions and conduct meaningful due diligence. Companies should improve reporting on how they plan to accomplish this.
Are companies reporting on concrete actions to prevent modern slavery risks?
Preventative measures aim to address known modern slavery risks and typically include supplier vetting, employee and supplier training, auditing high-risk suppliers, and monitoring systems.
Companies varied in the range and detail of measures reported, though most disclosures were vague: generic human rights training, unclear audit conditions for high-risk suppliers, or simply restating commitment to a Supplier Code of Conduct. Compared with MSA reports, disclosures under the German Act were slightly more detailed, with two companies providing substantially more information. Comparisons with DDV and NTA reports showed less consistent patterns, with details varying largely on a company-by-company basis.
The focus on compliance undermines transparency
The gaps in reporting are striking and point to an urgent need to improve reporting quality across all jurisdictions. Weak disclosure appears consistently, even under human rights due diligence laws that require companies to establish and implement due diligence processes. These findings echo results from other research, such as Beyond Compliance, and voices within the sector showing that companies continue to approach reporting as a compliance exercise, providing only the minimum information necessary to meet legal obligations.
Although more prescriptive reporting requirements — such as structured formats and targeted questions — can encourage greater transparency, it is not clear that more stringent reporting standards will have the desired impact so long as companies do not move beyond a purely compliance-driven approach. This focus on compliance undermines the core purpose of disclosure: enabling civil society, investors, and the public to assess companies’ exposure to, and responses to, modern slavery.
The Wikirate team has reviewed the research and accompanying blog to ensure it supports our mission of providing evidence-based insights to our audience; however, the content does not necessarily reflect the views of Wikirate International.