How to map modern slavery risks in China supply
Map both the production route and the recruitment route behind your Chinese supplier. Record each site, subcontractor and labour provider, check the evidence behind their answers, and assign unresolved gaps to an owner. Start with suspected worker harm. Cambridge China Bridge has its own staff in China.
Map relationships behind the supplier
Home Office guidance says engagement with direct and indirect suppliers is crucial for mapping supply chains and assessing and mitigating risks. Build a working map for each product family, connecting the seller to production sites, outsourced processes, component makers and material sources. This is a practical mapping method, not a statement of reporting obligations.
Record the business name, site address, activity, upstream connection, evidence source and date checked. Distinguish supplier declarations from independently checked information. Keep delivery continuity work alongside this exercise through the supply-chain de-risking guide, while assessing possible harm to workers separately.
Follow how workers reach each site
Ask each production site who recruits, employs, pays and supervises its workers. Include temporary workers, agency workers and outsourced cleaning or packing teams. Request the names of labour providers and recruitment intermediaries, including anyone engaged by those providers. Ask where recruitment takes place and who pays recruitment, travel and accommodation costs.
Compare the answers with recruitment agreements, suitably redacted payroll and deduction records, and confidential worker accounts gathered by a suitably qualified person. Ask about recruitment debt, retained identity documents, withheld wages and freedom to leave. Avoid interviews arranged solely through supervisors, and do not put worker names in a supplier-facing map.
Expose subcontractors and missing tiers
Ask where every outsourced process happens, including overflow work during busy periods. Connect processing and transport records to named sites rather than accepting a general assurance that everything is made in-house. For production approval and change control, use the subcontracted production guide.
When a supplier refuses disclosure, record the missing activity, the reason given, the possible worker risk and the evidence needed next. Offer confidential disclosure to an agreed reviewer where appropriate. Trace selected higher-risk inputs further upstream. An unanswered question remains an evidence gap; it does not become low risk because the direct factory passed an audit.
Choose checks by possible worker harm
Prioritise signs of coercion, recruitment debt, wage withholding and restrictions on movement. Also investigate opaque recruitment routes, unexplained outsourcing and conflicting records. Keep potential harm and confidence in the evidence separate, so a well-documented supplier does not automatically receive a favourable assessment.
For each priority concern, define the question, evidence needed, responsible buyer, supplier contact and review date. Combine document checks with safe worker engagement and specialist support where needed. Review your own buying practices too: urgent changes and unrealistic delivery demands deserve scrutiny alongside supplier behaviour.
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Keep an action record and refresh the map
Maintain a record linking each concern to the affected activity, protective action, agreed remedy and evidence of follow-up. If exploitation is suspected, seek specialist safeguarding advice before approaching an alleged exploiter or making an abrupt exit. Consider how your decision could affect workers, and protect confidential accounts from retaliation. For customer reporting, see our guide to demonstrating modern slavery improvements to public buyers.
Refresh the map when production sites, materials, subcontractors or recruitment arrangements change. Record what remains unknown and what will be checked next. Keep supplier qualification decisions connected to the second-supplier qualification guide, without treating qualification or a completed questionnaire as proof that every tier is free from exploitation.
Frequently asked questions
Is a direct factory audit enough?
Use it as evidence about the site checked. Separately trace outsourced production, upstream inputs and recruitment routes, and record what the audit did not examine.
What should I ask a labour provider?
Ask who recruits, employs and pays workers, which intermediaries are involved, who bears recruitment costs, and what deductions or document-retention arrangements workers experience.
What if my supplier will not name subcontractors?
Record the refusal and affected processes. Offer confidential disclosure to an agreed reviewer, request supporting records and escalate the unresolved worker risk before approving changes.
How far upstream should I map?
Follow the routes with the strongest indications of worker harm or weakest visibility. Extend the map as evidence becomes available, and state clearly where tracing stops and why.