Overseas workforce risks
Concerns involving recruitment, labour contractors, pay, working hours or grievances require fact-finding and practical remediation.
ESG COOPERATION HUB · For Chinese companies operating globally
Forced Labour Risk GovernanceDual-Track Advisory
Ground improvements in facts. Support dialogue with evidence.
Labour risks across overseas operations can involve site management, headquarters, customer enquiries and public concern at the same time. ESG Cooperation Hub connects risk assessment, remediation, evidence preparation and stakeholder engagement to support lasting improvements for workers.
Two tracks · Clear responsibilities
Substantive improvement as a shared foundation
TRACK A
Governance & remediation
Clarify facts
Support remedy
Prepare evidence
TRACK B
Engagement
Frame issues
Prepare information
Follow up feedback
Worker protection and lasting improvement
Connect facts, action and dialogue
Start with your business context
Close the gaps between governance and engagement
For businesses committed to substantive improvement, starting with a site, a defined supply chain or a group-level need.
Due diligence and stakeholder enquiries
Buyers, investors or other stakeholders need consistent, accurate explanations supported by relevant facts.
Import restrictions and market readiness
Questions relating to U.S. Withhold Release Orders (WROs) or EU Forced Labour Regulation (FLR) readiness require coordination of governance, evidence and professional advice.
Our dual-track approach
Connect internal action with external engagement
We provide technical advice and project coordination for the enterprise, helping headquarters, site teams and relevant specialists work within an agreed scope.
Track A · Governance & remediation
From risk findings to progress you can track
Support risk identification, remediation and evidence preparation around actual working conditions.
- Risk assessment and fact-findingIdentify priority issues in records, labour arrangements and site conditions; arrange appropriately qualified investigation work where needed.
- Remediation and worker remedyHelp develop action plans, responsibilities and implementation arrangements that include worker protection and meaningful feedback.
- Evidence preparation and progress trackingOrganise factual and remediation records with their scope, sources and unresolved issues. Arrange appropriate separate providers where independent verification is needed.
Track B · External engagement
Support informed dialogue with accurate information
Prepare appropriate engagement and follow up feedback on the basis of supported facts and actual progress.
- Issues and communication preparationIdentify stakeholder concerns and prepare Chinese and English information materials, management briefings and Q&A support.
- Coordination and engagement supportCoordinate independent public-interest participation where appropriate. Commissioned public affairs work is undertaken by suitable professionals under clear mandates and applicable requirements.
- Bring feedback into governanceTranslate questions, differing views and requests for information into further fact-finding, remediation or referral to appropriate specialists.
Each participant retains their own judgement. Independent research and public-interest participation are distinct from commissioned public affairs and commercial endorsement. Communications should reflect verified progress and remaining limitations.
Working together
Start with a clear question and build useful outcomes
- 01
Clarify scope
Identify sites, affected people, business needs and existing work.
- 02
Agree arrangements
Define tasks, professional responsibilities and safeguards around the gaps.
- 03
Support action
Advance remediation, organise records and prepare appropriate engagement.
- 04
Follow up and hand over
Track feedback, update materials and support ongoing governance.
Timing depends on risks, records and site conditions. Urgent worker protection and necessary remediation should not wait for the full project process.
What you receive
Outputs for decisions, professional review and action
Deliverables distinguish established facts, unresolved questions and next steps within the agreed scope.
Risk baseline and remediation roadmap
A summary of issues and evidence gaps, recommendations for corrective action and remedy, responsibilities and progress tracking.
Evidence and engagement materials
An index of factual and remediation records, audience-specific Chinese and English information packages and Q&A support, tailored where needed to WRO response or FLR readiness.
Ongoing due diligence and capability
Recommendations for human rights due diligence (HRDD), grievance and feedback mechanisms, team training and follow-up review.
Formats, languages, depth and acceptance criteria are agreed for each project. Producing materials does not establish regulatory acceptance, the elimination of all risks or adequate remedy for workers.
Choose the support you need
From diagnosis to focused or integrated support
Start with gaps in current arrangements and coordinate with existing counsel, investigators and internal teams.
Diagnosis and scoping
For teams clarifying their needs
Assess needs, available information and existing arrangements to identify priorities.
Indicative output: a diagnostic summary and service recommendations.
Remediation support
For teams advancing practical improvements
Focus on the factual baseline, remediation, worker remedy and internal capability.
Indicative output: a roadmap, evidence preparation and follow-up support.
Integrated dual-track support
Where both tracks add value
Connect remediation, evidence preparation and external engagement.
Indicative output: coordinated work, governance outputs and engagement materials.
Ongoing governance support
For teams maintaining established systems
Track progress, update records and respond to new issues.
Indicative output: periodic reviews, feedback and capability development.
Modules may be commissioned separately; diagnosis does not require an integrated engagement. Scope, resources, fees and third-party services are confirmed separately.
Professional boundaries and accountability
Coordinate the work. Respect independent judgement.
Separate advice from independent verification
The Hub can support governance and evidence preparation. Independent verification of remediation in which it has participated should be undertaken by a suitably independent party that retains control of its conclusions.
Transparent roles and mandates
Public-interest participation, commissioned public affairs and legal services have distinct roles. Formal representation, legal opinions and proceedings require appropriate professionals and authorisation.
Protect workers and information rights
Prioritise safe participation, confidentiality and protection from retaliation. Use materials with appropriate permission, respect client and third-party intellectual property, and do not present participation as endorsement.
We are accountable for the quality, accurate presentation and necessary correction of our own work within the agreed scope. Regulatory decisions, purchasing decisions and third-party positions remain with the relevant bodies. We do not promise customs clearance, revocation of an order or endorsement. Read our transparency and engagement boundaries →
Frequently asked questions
Clarify expectations before engagement
Can we work with you if we already have counsel or investigators?
Yes, where there are relevant gaps in governance or coordination. Existing work can be reused subject to quality and permission. Additional services address defined gaps; an assessment may also conclude that no additional support is needed.
Does dual-track advisory include independent investigation, certification or regulatory representation?
These are not automatically included. Investigation, verification, public affairs and legal work require separately confirmed scope, personnel, conditions and mandates. This service does not provide a “forced-labour-free” certification.
How should we understand EU FLR and U.S. WROs?
Regulation (EU) 2024/3015 generally applies from 14 December 2027, with certain provisions applying earlier. U.S. WROs are CBP measures to detain imports suspected of being produced with forced labour. Their scope and procedures differ; case-specific legal assessment should be undertaken by qualified legal professionals.
Official sources: EU regulation text · U.S. CBP forced labour guidance
Checked on 8 September 2026. Each engagement should use the rules in force at that time.
What should we share when we first get in touch?
Start with your sector, operating countries or regions, main concerns and the support you seek. Exchange sensitive case files, worker information and internal documents only as needed after confidentiality and information-use arrangements are confirmed.
Start a conversation
Begin with the issue that matters most now
Tell us about your operating context and current concerns so we can discuss an appropriate scope and working arrangements.
Please share an overview first. Sensitive materials can follow once suitable arrangements are confirmed.