How do I respond when a third-party audit finds evidence of modern slavery in my supply chain?

When a third-party audit finds evidence of modern slavery in your supply chain, you need to act quickly and systematically: notify key internal stakeholders, assess whether to suspend the supplier, engage with the affected workers, and report to relevant authorities depending on your jurisdiction. The most important thing is not to ignore or minimize the finding – delays can increase legal exposure and reputational damage for your brand and your customers. This article walks through each step you should take, from the moment you receive the audit report to how you communicate the outcome externally.

What counts as evidence of modern slavery in a supply chain audit?

Evidence of modern slavery in a supply chain audit may include indicators such as withheld wages, debt bondage, confiscated identity documents, restrictions on freedom of movement, excessive working hours without consent, physical or psychological coercion, or workers who appear unable to leave their employment voluntarily. Auditors typically flag these as high-risk findings that require immediate escalation rather than routine corrective action.

In the fishing industry specifically, modern slavery risk is heightened by remote working conditions at sea, long vessel trips, and limited oversight. Audit evidence might come from worker interviews, vessel logbooks, crew contracts, or discrepancies between declared wages and actual payments. Some findings are direct – a worker reports being held against their will – while others are indirect, like patterns in vessel movement that suggest crew are not returned to port as scheduled.

It is also worth noting that not all labor violations constitute modern slavery. Audits may surface a spectrum of issues, from poor working conditions to full forced labor. The severity of the finding shapes the urgency and nature of your response, but any finding that touches on coercion, deception, or restricted freedom should be treated as serious from the outset.

Who needs to be notified immediately after an audit finding?

After a modern slavery finding, your first notifications should go to your senior leadership team, your legal counsel, and your compliance or sustainability function. These three groups need to be aligned before any external communication happens. Depending on your company structure, your procurement lead and head of supply chain should also be looped in immediately, since they will need to make decisions about the supplier relationship.

Beyond internal stakeholders, you may have contractual or regulatory obligations to notify buyers, retailers, or brand partners who source from the same supply chain. Some retailer contracts include clauses requiring disclosure of material audit findings within a defined timeframe – check your agreements carefully.

In certain jurisdictions, notification to government authorities may also be required. In the UK, for example, the Modern Slavery Act creates reporting obligations for larger companies, and law enforcement agencies such as the Gangmasters and Labour Abuse Authority (GLAA) have a remit to investigate labor exploitation. In the EU, the Corporate Sustainability Due Diligence Directive (CSDDD) – which is being phased in from 2026 – places explicit obligations on companies to identify, address, and report on human rights risks in their supply chains.

Should you suspend the supplier or continue sourcing during an investigation?

Whether to suspend a supplier immediately or continue sourcing while an investigation is underway depends on the severity of the finding. If the audit evidence points to active forced labor or ongoing coercion of workers, suspension is generally the appropriate first step. Continuing to source from a supplier while known violations are unresolved may increase your legal exposure and signals to buyers and regulators that your due diligence is inadequate.

That said, immediate suspension is not always the right call for lower-severity findings or situations where the evidence is ambiguous. Some industry guidance – including frameworks from the Responsible Business Alliance and sector-specific bodies – suggests that abrupt disengagement can sometimes leave workers in a worse position, particularly in remote or economically isolated contexts. In those cases, a time-bound corrective action process with close monitoring may be more appropriate.

A practical approach is to make the decision based on two factors: the nature of the harm and the supplier’s demonstrated willingness to cooperate. A supplier who acknowledges the finding, engages openly with investigators, and takes immediate remediation steps is a different situation from one that obstructs the process or denies credible evidence. Document your decision-making process carefully – this record could be relevant if the finding later becomes subject to regulatory scrutiny.

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How do you build a corrective action plan for a labor violation?

A corrective action plan (CAP) for a labor violation should be specific, time-bound, and tied directly to the root cause of the finding. A good CAP identifies what went wrong, who is responsible for fixing it, what concrete steps will be taken, and how progress will be verified by an independent party. Vague commitments to “improve working conditions” are not sufficient – auditors and regulators will look for measurable actions with deadlines.

For modern slavery findings in the fishing industry, a CAP might include steps such as:

Conducting independent worker interviews to assess the full scope of the issue
Reviewing and reissuing crew contracts in workers’ native languages
Returning confiscated documents to workers immediately
Establishing a confidential grievance mechanism for crew members
Engaging a recognized labor standards body (such as FISH Standard for Crew or Fair Trade USA) to conduct a follow-up assessment
Setting a timeline for re-audit within 3 to 6 months

The CAP should be developed collaboratively with the supplier where possible, but the terms must be non-negotiable on the core remediation points. You should also build in a clear consequence for non-compliance: if the supplier fails to meet agreed milestones, sourcing will be suspended or terminated. That consequence needs to be stated explicitly in writing.

What are your legal obligations under modern slavery regulations?

Your legal obligations after a modern slavery finding vary depending on where your company is headquartered and where you sell your products. In jurisdictions such as the EU and the USA, regulatory frameworks are tightening significantly in 2026, and companies that source from high-risk supply chains face growing scrutiny.

In the EU, the CSDDD requires in-scope companies to conduct human rights due diligence across their supply chains, take action when violations are identified, and report publicly on their processes. The EU Forced Labour Regulation, which bans products made with forced labor from the EU market, adds another layer of risk: goods linked to forced labor could face import bans or market withdrawal.

In the USA, the Uyghur Forced Labor Prevention Act (UFLPA) established a rebuttable presumption that certain goods are made with forced labor, and the US Customs and Border Protection (CBP) has authority to detain shipments that cannot demonstrate clean supply chains. Seafood companies exporting to the US market may face additional scrutiny under SIMP (Seafood Import Monitoring Program) requirements.

In the UK, companies above a revenue threshold must publish an annual modern slavery statement under the Modern Slavery Act. A material audit finding that is not disclosed or acted upon could be seen as a failure of that obligation. Legal counsel familiar with the specific regulations in your operating markets should be consulted as soon as a serious finding is confirmed.

How can digital traceability evidence support your response?

Digital traceability evidence can support your response to a modern slavery finding in two ways: it helps you understand the scope of the problem quickly, and it gives you documented proof of the steps you took to address it. When an audit finding surfaces, being able to pull verified vessel records, crew data, discharge logs, and certification status for the affected batches in minutes – rather than days – puts you in a much stronger position with regulators, retailers, and legal counsel.

In the fishing industry, first-mile data is especially valuable. Satellite vessel monitoring system (VMS) and AIS records can confirm where a vessel was operating, how long trips lasted, and whether movement patterns are consistent with voluntary crew rotation. When this data is captured in real time and linked to a unique Raw Material ID at the point of discharge, it becomes a verifiable audit trail rather than a retrospective reconstruction.

Digital traceability also supports the corrective action process. When social compliance certifications – such as BSCI/Amfori, SMETA, or FISH Standard for Crew – are integrated directly into a batch’s traceability record, you can track remediation progress against specific lots and demonstrate to buyers that affected product has been isolated or removed. This level of documentation is increasingly what retailers and regulators expect to see.

How do you communicate an audit finding to retailers and consumers?

Communicating a modern slavery finding to retailers should be proactive, factual, and focused on the actions you are taking. Retailers generally respond better to a supplier who surfaces a problem and presents a clear response plan than to one who conceals a finding and is later exposed. Your communication should include what was found, when you were notified, what steps you have taken immediately, and what your corrective action timeline looks like.

For consumers, the approach depends on whether the affected product has already reached the market. If it has, and if the finding is serious enough to constitute a product integrity issue, you may need to consider a recall or withdrawal and communicate that through your standard consumer channels. If the affected batches have not yet reached retail, your communication can focus on the steps you have taken to prevent compromised product from entering the market.

In either case, avoid vague language that sounds defensive or evasive. Consumers and advocacy groups are increasingly sophisticated about supply chain issues, and a response that minimizes a finding or deflects responsibility tends to generate more scrutiny, not less. Transparency, paired with concrete evidence of remediation, is a more effective long-term strategy.

This is where platforms like SmarTuna can make a real difference. Our digital traceability platform links verified social-compliance data directly to every Raw Material ID, so when a finding occurs, you already have the documentation needed to respond quickly, communicate credibly, and demonstrate to retailers and regulators that your supply chain oversight is real and auditable.

Frequently Asked Questions

How long do we have to respond to a modern slavery audit finding before it becomes a legal liability?

There is no universal statutory deadline, but the general standard is that you should begin your internal escalation process within 24–48 hours of receiving a serious finding. Under frameworks like the EU CSDDD and the UK Modern Slavery Act, regulators look at whether companies acted promptly and proportionately — prolonged inaction is treated as a failure of due diligence in its own right. Some retailer contracts specify disclosure windows as short as 5–10 business days, so reviewing your commercial agreements immediately is essential. The safest approach is to treat the clock as running from the moment the audit report lands.

What if the supplier disputes the audit findings — how should we handle that?

A supplier disputing findings is common, but it should not pause your internal response process. You should acknowledge the dispute, document it formally, and commission an independent verification — either through a second audit or direct worker interviews conducted by a trusted third party — rather than simply accepting the supplier’s rebuttal. If credible evidence of a violation exists, the burden of proof sits with the supplier to demonstrate it is inaccurate, not with you to prove it is correct. In the meantime, treating the finding as credible and proceeding with a corrective action plan is the defensible position from both a legal and reputational standpoint.

How do we protect workers who may have provided testimony during the audit from retaliation?

Worker protection should be a non-negotiable condition of your corrective action plan. Practically, this means requiring the supplier to establish a confidential grievance mechanism, ensuring workers are not identifiable from the audit report (request anonymization from the auditor if needed), and conducting follow-up welfare checks through an independent body rather than through the supplier’s own management. In serious cases involving forced labor, coordinating with an NGO or labor rights organization that has on-the-ground presence can provide an additional layer of protection. Any supplier that retaliates against workers who cooperated with an audit should face immediate suspension.

Can we still sell product from the affected supplier while remediation is underway?

This depends on the severity of the finding and whether affected batches can be clearly isolated from clean ones. If your traceability system allows you to identify and quarantine specific lots linked to the violation, it may be possible to continue selling verified, unaffected product while remediation proceeds on the flagged batches. However, if your supply chain records are insufficiently granular to make that distinction reliably, the safer and more defensible position is to pause sales of all product from that supplier until the corrective action plan reaches a verified milestone. Retailers and regulators will scrutinize this decision, so documenting your rationale — and the traceability evidence underpinning it — is critical.

What role should NGOs or third-party labor rights organizations play in our response?

NGOs and labor rights organizations can play a valuable role at several stages: during worker engagement (where they can provide trusted, independent channels for testimony), during remediation verification (where they lend credibility that internal teams cannot), and in communicating outcomes to external stakeholders. Organizations such as the International Labour Organization (ILO), the Issara Institute, or sector-specific bodies like FISH Standard for Crew have established methodologies for assessing forced labor and supporting remediation. Engaging them proactively signals good faith to regulators and retailers, and their involvement often produces more reliable worker feedback than supplier-managed processes.

How do we prevent the same issue from recurring in this or other parts of our supply chain?

Preventing recurrence requires moving beyond one-off corrective actions toward structural improvements in your supply chain oversight. This means integrating social compliance screening into your supplier onboarding process, setting minimum audit frequency requirements for high-risk tiers, and embedding real-time traceability tools — such as vessel monitoring data and crew certification tracking — that surface risk signals before they become audit findings. After any serious finding, conducting a root cause analysis that examines not just what happened at the supplier level but also what gaps in your own due diligence allowed it to go undetected is essential. The findings from that analysis should feed directly into your next modern slavery statement and risk assessment cycle.

What should our modern slavery statement say about an audit finding that occurred during the reporting year?

Your modern slavery statement should disclose the finding in clear, factual terms — the nature of the issue, the supply chain tier and geography involved, the immediate actions taken, and the current status of remediation. Regulators and civil society groups that review these statements are increasingly able to identify vague or evasive language, and a statement that omits a material finding while claiming effective due diligence creates significant legal and reputational risk. Framing the disclosure around your response — what you found, what you did, and what systemic changes you made as a result — demonstrates accountability and is far more credible than a statement that presents only clean outcomes.

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