Can headquarters decisions reach the site?
Do teams have the authority, resources and responsibilities to put policy into practice?
ESG COOPERATION HUB · For Chinese companies operating globally
Forced Labour Risk GovernanceDual-Track Advisory
Ground improvements in facts. Support dialogue with evidence.
For overseas operations, cross-border supply chains and group-wide due diligence, we help connect headquarters decisions, site action, worker remedy and product-level evidence. Our support combines informed engagement with the roles and working arrangements needed for ongoing governance.
Two tracks · Clear responsibilities
Substantive improvement as a shared foundation
TRACK A
Governance & evidence
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 a specific business need
Turn gaps in governance into tasks people can act on
Start with a site, a labour or supply relationship, a group of products and a defined period. Establish what existing work covers and where further support is needed.
Do records reflect lived experience?
Can records explain actual conditions for current, former and returned workers?
Does remediation deliver real benefit?
Have measures taken effect, has remedy reached affected people, and do risks recur?
Can external statements be supported?
Which products, periods and improvements can the available evidence actually support?
Applications include overseas labour governance, buyer and importer enquiries, evidence preparation for relevant U.S. procedures, EU FLR readiness and ongoing due diligence. Qualified professionals determine the applicable procedures.
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 & evidence
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 · Engagement & feedback
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.
The white paper frames the two tracks as evidence work and European engagement. Public service descriptions use governance and evidence, and engagement and feedback. U.S. and EU rules provide distinct legal and information-use interfaces.
Evidence and worker remedy
Give every account of progress a scope that can be checked
Connect relevant products with labour facts, preserving what is known, unknown and still needs action. Assess remedy through the actual benefits experienced by affected people.
- 01Products and production scope
Products, locations and periods
- 02Labour facts and affected people
Tasks, relationships and worker groups
- 03Remediation, remedy and verification
Implementation, results and appropriate review
- 04Supported statements
Audience, purpose and remaining limitations
An illustration of the service approach. Each connection requires factual support; a relationship diagram or complete file set does not establish working conditions.
Keep asking three questions about remedy
Were measures implemented?
Change harmful practices and allocate responsibility and resources.
Did affected people benefit?
Check receipt, access, retention and other outstanding harm.
Can improvements last?
Observe recruitment, pay cycles and changes affecting workers.
Prepare public statements, controlled client communications and procedural materials for their own purposes and permissions. Shared facts do not establish mutual recognition across jurisdictions or permit unrestricted sharing of worker data and independent records.
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.
Supported capability development
Embed governance in real roles and sustain it over time
Adjust support to the task and the enterprise’s capability. The enterprise makes decisions within its authority; advisers provide appropriate methods and quality support while independent professional roles remain in place.
- 01
Demonstrate
Explain judgement, actions and limits through a defined task.
- 02
Work together
Enterprise teams and advisers contribute their agreed work.
- 03
Client leads
Observe actual handling of new tasks.
- 04
Review operation
Review performance through business cycles and exceptions.
- 05
Improve over time
Maintain systems, prepare deputies and update arrangements.
Can roles carry out their responsibilities?
Primary and backup roles need real authority, resources and access.
Can workers participate safely?
Protection, independent expression and unresolved remedy need continuity.
These are support arrangements, not fixed courses, automatic progression or capability certification. Task capability, project progress and legal deadlines are managed separately.
Scope-based service configuration
Identify the gap before choosing the engagement
Consider existing counsel, investigators, business systems and internal roles. Compare self-managed coordination, focused support and integrated work; reuse suitable existing work where quality and permissions allow.
Diagnosis and scoping
Suitable when：Needs or investment are unclear
Assess risks, requests and existing arrangements; recommend priorities and a suitable configuration.
Indicative outputs A diagnostic summary, configuration and next-step recommendations.
Enterprise contribution Define the business scope, available records and existing advisory work.
Remediation support
Suitable when：Facts and practical action need attention
Support fact-finding, root-cause analysis, remediation, remedy and related evidence preparation.
Indicative outputs An action roadmap, remedy and evidence preparation arrangements.
Enterprise contribution Provide responsible decision-makers, site conditions and implementation resources.
Integrated dual-track support
Suitable when：Both tracks have real tasks to coordinate
Connect governance work, evidence, professional engagement and feedback into action.
Indicative outputs Coordinated work, factual materials and feedback tracking.
Enterprise contribution Establish cross-functional authority and the roles of relevant specialists.
Ongoing governance support
Suitable when：An effective baseline and systems need maintenance
Track changes, review tasks, update materials and maintain continuity for unresolved matters.
Indicative outputs Periodic reviews, material updates and continuity plans.
Enterprise contribution Maintain operational roles, information permissions and continuing resources.
Diagnosis may recommend focused procurement, self-managed work or no additional service. Options can be agreed separately. Confirm scope, actual teams, capacity, fees and third-party work; identify worker remedy funds separately.
Unresolved matters need continuity beyond the contract
Within the agreed handover scope, identify what remains open, who accepts it, their authority and resources, lawful access to records and the next review date. Stronger enterprise capability does not transfer worker autonomy or independent professional judgement.
Outputs and assessment
Assess deliverables, client capability and actual outcomes separately
Agree the materials, languages, scope and assessment criteria for each engagement. Each category answers a different question; an overall score should not replace judgement on critical issues.
Deliverable quality
Risk baseline and action roadmap
Scope and issue summaries, evidence gaps, remediation and remedy recommendations, responsibilities and next steps.
Assessment focusCan sources be located, limits understood and agreed tasks verified?
Client task capability
Roles and ongoing operation
Task-based support, primary and backup arrangements, evidence maintenance and handover of unresolved matters.
Assessment focusCan the enterprise handle new tasks within its authority and recognise when professional support is needed?
Governance and worker outcomes
Governance and remedy follow-up
Track action, remedy and protection, keeping unresolved, disputed, uncovered and matters requiring independent review visible.
Assessment focusDo measures work in practice, do affected people benefit, and do risks recur?
Record independent opinions and external decisions separately
Independent providers retain control of their methods, scope and conclusions. Regulatory decisions, purchasing decisions and third-party positions are recorded against their sources. Explain deliverables, capability progress and remedy 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 →
White paper research
Understand the approach and its limits
Choose a reading path across 18 chapters. The guide offers research highlights, selected procurement and governance questions, official references and a correction channel.
Rules and dual-track governance
Understand gaps, distinct procedures and professional responsibilities.
Evidence, remedy and engagement
Explore product connections, actual benefit and feedback into action.
Capability and procurement
Examine ongoing operation, separate assessments and responsible handover.
The white paper uses public-source research. Its recommendations and public cases do not establish Hub client results or measured delivery capability.
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 can an enterprise prepare for EU FLR?
Regulation (EU) 2024/3015 generally applies from 14 December 2027, with certain provisions applying earlier. The Commission’s official guidance and portal support preparation of business scope, relevant facts and response capability. Qualified professionals provide case-specific legal assessment.
Official references: EU regulation · Commission portal and guidance · CBP request categories and portal notice
Listed official entry points checked on 1 November 2026. The research dates are stated in the white paper guide; each case must use current rules and notices.
Can WRO, cargo admissibility and UFLPA requests use the same response?
First identify the request. WRO/Finding modification, cargo admissibility, UFLPA applicability reviews and exception requests address different questions. Relevant facts may be reused with permission, while qualified professionals handle the distinct procedures, evidentiary requirements and formal submissions.
Can current remediation cover every historical product?
Distinguish when labour conditions occurred, when measures took effect, when products were made and how they are supplied to the market. Current improvement does not automatically cover all historical products. Preserve the relevant scope and unresolved facts.
Do advisory fees cover worker remedy and all independent professional work?
The mandate distinguishes governance advice, independent professional services, necessary support costs and worker remedy funds. A package name does not automatically include all third-party work or all remedy expenditure.
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.