CONFIDENTIAL CONTACT
Does the subcontracting chain stop at the first contract?
Start with one site’s agreements, staffing and payment path under a defined lawful scope.
A low bid does not show who bears the cost. Workers on site may be employed by a second or third-tier contractor, with recruitment, pay and housing arrangements absent from your main agreement.
The question is not whether the supplier signed a policy. It is who recruits, directs and pays the people doing the work.
Establish the facts and gaps before deciding on investigation or legal action.
On 23 October 2026, the European Labour Authority and Europol reported a joint action across 34 countries. Authorities reported 27 arrests, identified 248 potential victims and opened 182 new trafficking investigations. The operation covered high-risk sectors including agriculture, construction and hospitality. Those figures do not establish wrongdoing by an unmentioned supplier.
For buyers, the practical issue is that direction, recruitment fees and wages may sit outside the first contract.
A low quote alone does not show exploitation. But if a labour-intensive service has no clear staffing, hours or payment explanation, review the arrangement.
Take one site and compare people working there, their supervisor, shifts, payment and complaint routes. A headquarters policy cannot answer every site-level question.
Workers may fear losing a job or immigration status. Interviews should not be managed by a potentially implicated supervisor. Use appropriate language, confidentiality and anti-retaliation safeguards with qualified advisers.
Avoid public accusations from a single anonymous report. Define verifiable questions and protective steps before broad circulation.
We can map public corporate and intermediary ties, supplier records, subcontracting levels and authorised exception timelines for businesses and counsel.
We cannot declare trafficking or guarantee that every tier has been checked. Where someone faces immediate danger, contact appropriate local authorities and support services first.
A signed supplier commitment is useful, but it does not establish the conditions of every worker.
Good diligence connects names, processes and payment evidence while allowing workers to speak safely.
Start with one site’s agreements, staffing and payment path under a defined lawful scope.
