A journalist calls about your supplier. What you do next defines whether your modern slavery statement is worth the paper it’s printed on.
Ashford Electronics, Birmingham. Sarah’s last call of the week was supposed to be a 1-1 with David Chen on Q3 supplier reporting. Instead, an external number is calling.
Reuters London. Supply chain desk.
The number isn’t on the press list. They never call sales.
“I’ve got documents from a worker named Bharath at Jaya Precision Components. I’m running this on Tuesday. I’d like a comment from Ashford by Monday 17:00.”
Sarah ends the call. Her desk phone is still vibrating with an internal extension. She lets it ring.
This is a supply chain investigation. You will be presented with evidence, make decisions, and face their consequences.
The Evidence Panel (left sidebar) tracks your case materials — documents, intelligence, and legal references accumulate as you progress. Review them before making decisions.
The Stakeholder Tracker (top-right) shows how your actions affect four groups: the Board, the workers at Jaya, the media, and regulators. Watch it shift after each decision.
There are no perfect answers. Every choice has a cost. Your final score reflects how well you balanced legal compliance, worker protection, and commercial reality.
Modern supply chains are layered. Your contracts are with Tier 1 — your direct suppliers. But your Tier 1 suppliers buy from Tier 2 sub-suppliers, who buy from Tier 3 raw material providers.
Most companies audit Tier 1. Few audit Tier 2. Almost none audit Tier 3. This is where forced labour hides — in the layers you cannot see and have no contractual relationship with. The ILO estimates 27.6 million people are in forced labour globally. The majority are in private sector supply chains.
Your desk phone rings. It’s Grace Hartley from the Financial Times. She’s writing a piece on labour conditions in Malaysian electronics component manufacturing. She has photographs of worker dormitories at Jaya Precision Components — a company you’ve never audited but which supplies PCB assemblies to Meridian Manufacturing, your Tier 1 contract manufacturer in Shenzhen.
The photographs show 12-person dormitory rooms. Hartley says she has payslips showing deductions labelled ‘recruitment processing fee’ — between 3 and 6 months’ wages. She has interviewed three workers who say their passports are held by the dormitory supervisor.
She wants a comment from Ashford by Thursday.
The ILO identifies 11 indicators of forced labour. One is a red flag. Multiple — like Hartley describes — constitute a strong presumption. Click the amber cards for the evidence at Jaya.
Grace Hartley’s deadline is Thursday. You have photographs suggesting forced labour indicators at your Tier 2 supplier. David doesn’t know yet. What is your first action?
The board is briefed by lunchtime. Amira Osman — external modern slavery counsel — is on the phone by 2 PM: “Don’t contact Jaya directly. Contact Meridian, invoke your contractual audit rights, request an unannounced site visit within 72 hours. If Meridian refuses, that tells you everything.”
David resists: “We’ve worked with Meridian for 8 years. We can’t just accuse them—” Amira: “You’re not accusing them. You’re exercising your contractual right to audit a sub-supplier. If your code doesn’t give you that right, that’s the first thing we fix.”
David calls his contact at Meridian. The response: “Jaya is one of our approved sub-suppliers. They passed our internal assessment last year. We have no concerns.” David relays this to you. “See? Meridian says it’s fine.”
You ask David: “What did the assessment cover? Did it include worker interviews? Recruitment practices? Dormitory conditions?” David doesn’t know. He didn’t ask. He trusted the relationship.
You’ve lost 6 hours. Meridian now knows you’re asking questions — which means Jaya may know too. An unannounced audit is no longer unannounced.
You spend Monday afternoon reviewing documentation. Jaya has no SA8000 or SMETA certification. Meridian’s last audit of Jaya was a questionnaire — 14 questions, all answered ‘compliant.’ No site visit. No worker interviews.
By Tuesday morning you have confirmed that Ashford has zero verified information about conditions at Jaya. The journalist’s photographs are the most detailed intelligence you have about a supplier that feeds 34% of your component volume. You have lost 24 hours and learned only what you should have already known: your Tier 2 due diligence does not exist.
Grace Hartley emails a follow-up: “I note Ashford’s modern slavery statement says you ‘conduct risk assessments across our supply chain.’ Can you confirm what risk assessment was conducted on Jaya Precision Components?”
Limited time. You can investigate three of the five sources below before Hartley’s Thursday deadline.
Choose carefully. What you don’t investigate stays unknown.
You review the evidence you’ve gathered. Some intelligence sources remain uninvestigated — that information is still unknown to Ashford. This is the reality of supply chain due diligence: you make decisions with incomplete information.
Meridian Manufacturing sends a formal written response. Read it carefully. Click on any phrase that raises a red flag — the rationalisations, deflections, and gaps. There are five to find.
Amira calls. One question: what leverage does Ashford have over a Tier 2 supplier it has no direct contract with?
Amira recommends a structured response sequence. The order matters — doing things out of sequence creates legal and operational risks. Drag the steps to put them in the correct order, then check your answer.
An independent social auditor using ILO methodology conducts an unannounced visit to Jaya. 18 workers interviewed confidentially, off-site, in their first language, without management present.
| Finding | Severity | ILO Indicator |
|---|---|---|
| Recruitment fees of 3–6 months’ wages paid to labour agents by migrant workers | Critical | Debt bondage — Indicator #9 |
| Passports held by dormitory supervisor. Workers must request access 48 hours in advance | Critical | Retention of identity documents — Indicator #7 |
| Systematic overtime of 14–18 hours/week above legal maximum. Off-the-books — not reflected in payroll records | Serious | Excessive overtime — Indicator #11 |
| Payroll records show legal hours; worker interviews reveal significant discrepancy | Serious | Deception — Indicator #2 |
| Workers report being told they will be ‘sent home’ (deportation threat) if they raise concerns | Critical | Intimidation and threats — Indicator #6 |
Amira walks you through the framework. The hardest decision in supply chain compliance — and the one most companies get wrong.
The audit confirms forced labour indicators at Jaya. David wants to cut Jaya immediately — “we can’t be associated with this.” Amira warns that cutting the supplier without remediation may worsen outcomes for the workers. What do you recommend to the board?
Ashford, Meridian and Jaya agree a corrective action plan. Passports returned within 7 days. A 12-month fee repayment programme is funded jointly by Jaya and Meridian (Ashford contributes via a temporary price adjustment).
An independent monitor runs quarterly off-site visits for 2 years. A confidential grievance hotline is set up in Bahasa Malaysia and Nepali.
Cost to Ashford: ~£140,000 over 2 years. The alternative — a Sunday Times headline reading ‘Modern slavery in Ashford’s supply chain’ — costs more.
You give Jaya 30 days. Passports are returned within 10 days — a positive sign. But the fee repayment programme stalls. Jaya’s management argues that recruitment fees were charged by independent agents, not by Jaya. They offer to ‘review’ the arrangement for future hires but will not reimburse existing fees.
After 30 days, the passport issue is resolved but debt bondage continues. You exit the relationship. Meridian finds an alternative sub-supplier within 6 weeks.
David contacts Meridian. “We’re out. Find another PCB supplier.” Meridian complies — they have other customers for Jaya’s capacity. Within 4 weeks, Ashford’s orders are sourced from a different sub-supplier in Thailand.
Grace Hartley publishes her article. The paragraph about Ashford reads: “Ashford Electronics told the FT it had ‘terminated the commercial relationship’ with the supplier. When asked what remediation measures had been taken for the affected workers, Ashford did not respond.”
Ashford’s annual modern slavery statement is due. The board wants to know what it should say about the Jaya incident. Amira has provided three drafts. Which do you recommend?
The statement is 14 pages — the longest Ashford has ever published. It names Jaya, describes the audit findings, the remediation programme (or exit and its limitations), and the systemic changes: Tier 2 supplier mapping, risk-based audit programme, contractual right-to-audit clauses in all Tier 1 contracts, confidential grievance mechanism, and a commitment to annual reporting on remediation outcomes.
The Business & Human Rights Resource Centre rates Ashford’s statement as ‘leading practice.’ Two institutional investors contact Ashford’s CFO to say the transparency influenced their ESG assessment positively. Grace Hartley publishes a follow-up noting Ashford’s response as ‘the most substantive corporate response to supply chain labour abuse we have seen in the UK electronics sector this year.’
The statement describes ‘a Tier 2 supplier in Southeast Asian electronics manufacturing’ where forced labour indicators were identified through investigative journalism. It details the six ILO indicators found, the independent audit methodology, the corrective action plan structure, and the systemic changes to Ashford’s due diligence programme. It does not name Jaya or Meridian.
The Business & Human Rights Resource Centre rates the statement as ‘good practice — substantive on process, limited on specificity.’ One institutional investor asks for more detail; Ashford provides it under NDA. Grace Hartley notes the statement is ‘more detailed than most — but stops short of the transparency that would set a precedent.’
The statement reads almost identically to last year’s. ‘Enhanced supply chain monitoring’ is the only new language. Grace Hartley’s article is now 3 months old. An NGO compares Ashford’s statement to the FT article and publishes a blog post: ‘Ashford Electronics: the gap between statement and reality.’
The post is shared 2,400 times on LinkedIn. Ashford’s Head of Communications calls Sarah: “Why does our modern slavery statement not mention the thing the Financial Times wrote about?”
Your three decisions created a cascade. Each choice shaped the next — and the consequences compounded. Below is your path through the case.