The EU Forced Labour Regulation is a landmark step toward ethical global supply chains, but its success depends on how it is enforced. Global Rights Compliance is pleased to respond to the formal call for evidence of the European Commission to help shape the upcoming implementation Guidelines.
Our submission draws on our legal expertise to ensure the Regulation is both clear and realistic for all stakeholders. Key highlights of our submission include:
A two-tiered evidentiary approach that recognises both primary evidence and secondary/contextual evidence, especially in restricted environments where “perfect” proof of forced labour is unavailable.
Acknowledging state-imposed forced labour where traditional methods of evidence-gathering often fail in high-risk, state-controlled contexts. We’ve outlined how heightened due diligence and unique investigative tools are required to uncover these abuses.
Victim-centred enforcement: we emphasise that any investigative process must be trauma-informed and context-sensitive in order to protect the very individuals the Regulation aims to serve, and should not place a disproportionate burden on complainants to prove their case at the outset.
Training must empower economic operators to move beyond reactive, “one-off” compliance exercise by aligning internal risk management with the EU’s forced labour database, ensuring the Regulation lives on as a dynamic and permanent feature of business conduct.
🔗 Read our full submission here.