A global retailer needed to know whether a labor scheme then prevalent in southern India's spinning mills was present in its supply chain. Under the scheme, young women were recruited from villages, housed on site, and paid a lump sum only on completing a multi-year term. NGO reports had put the scheme, and the industry, under an international lens. A certificate from the supplier was never going to answer the question.
“The investigation looked at how the mills actually recruited, housed and paid their workers.”
The investigation, carried out during my tenure at a global investigations firm, worked both layers. The documentary layer was the supplier's corporate records and annual reports, read against the published NGO findings, so the inquiry began from evidence rather than allegation. The ground layer was investigation into how the mills actually recruited, housed, and paid: the operational facts that determine whether a scheme is present, whatever the paperwork says.
This work anticipated what US importers now face under the Uyghur Forced Labor Prevention Act (UFLPA), which requires clear and convincing evidence, with a documented trace of the supply chain, for an exception from its presumption. The method is the same as it was at those mills: treat the paperwork as something to test, verify at the source, and build the file as evidence that may later be examined.