Forced labor and harmful working conditions can occur at every stage of production — from mining to component manufacturing and final assembly. For purchasers, this raises a key question: how can you make responsible choices when the most serious risks are hidden in the supply chain?
By Dmytro Kapotia, sustainable purchasing support in Eastern Europe.
A complex challenge
The vast complexity of the IT sector makes it difficult to know where materials come from and how workers are treated. This is why many purchasers choose to address social responsibility locally, often overlooking areas such as modern slavery, fair wages, and employment conditions connected to the products they source.
These problems often lie further up the supply chains, far from where the products are sold and used. As a result, there is a “psychological distance” between consumers, people experiencing modern slavery, and supply chain managers. Ignoring these risks can lead to supply disruptions, reputational damage, and future barriers to market access, but more importantly, we have a moral responsibility to the people affected.
A complex challenge
The vast complexity of the IT sector makes it difficult to know where materials come from and how workers are treated. This is why many purchasers choose to address social responsibility locally, often overlooking areas such as modern slavery, fair wages, and employment conditions connected to the products they source.
These problems often lie further up the supply chains, far from where the products are sold and used. As a result, there is a “psychological distance” between consumers, people experiencing modern slavery, and supply chain managers. Ignoring these risks can lead to supply disruptions, reputational damage, and future barriers to market access, but more importantly, we have a moral responsibility to the people affected.
By Dmytro Kapotia, sustainable purchasing support in Eastern Europe.
Common risk areas
- Raw materials – Cobalt and 3TG minerals (tin, tungsten, tantalum, gold), frequently linked to exploitation and child labor.
- Components and sub-assembly – Excessive overtime, debt bondage, recruitment fees paid by migrant workers, unsafe working conditions.
- Final assembly and logistics – Temporary or student labor with inconsistent protections.
Policy progress — but limited insight
The EU is introducing stricter requirements on human rights due diligence, and moving towards a ban on products made with forced labor. While these are important steps, actual enforcement remains difficult. Supply chains are often long, fragmented and largely invisible, with many sub-suppliers located in countries where labor laws are weak or not properly enforced.
Why it’s hard to act alone
Even for large buyers, monitoring compliance throughout the entire supply chain is extremely challenging. It would require costly audits, and tracking and following up on corrective actions is extremely resource-intensive.
Leverage is also an issue. One purchaser, or even a group of purchasers, rarely has enough influence to shift practices at factories that supply dozens of global brands.
Finally, as a recent article in the Journal of Purchasing and Supply Management points out, identifying (before even addressing!) modern slavery in supply chains requires the engagement and cooperation of various actors with a broad range of expertise, financing, access, and legitimacy. Certification and auditing bodies are recognized for playing an important role in such multi-stakeholder collaborations.
How TCO Certified helps address modern slavery risks
As a global sustainability certification, TCO Certified can extend the reach of social procurement requirements deeper into the supply chain than any individual buyer:
- Mandatory social criteria
Certified products must meet criteria based on local and international labor and health-and-safety laws, as well as the UN Convention on the Rights of the Child. - Independent verification
Compliance is verified and followed up by independent accredited experts – reducing the risk of “green-/bluewashing”, and helping to ensure that workers are actually protected. - Follow-up on corrective action
Non-conformities must be resolved within defined timeframes, helping ensure that problems are not only identified, but addressed. - Transparency and accountability
Criteria require naming key suppliers and assigning senior management responsibility for supply-chain compliance — enabling better detection and prevention of risks over time. - TCO Certified Accepted Factory List
Factories are placed in risk categories based on sustainability performance. Those that meet requirements remain approved; those that do not are removed. This encourages long-term improvements and enables IT brands to select more responsible factories, creating a business incentive for sustainability.
By making TCO Certified an integral part of the purchasing process, IT buyers can go beyond paper promises and take concrete steps to reduce modern slavery risks in the supply chain.
For more details on today’s supply chain criteria — and how they will expand in future generations — see our Roadmap for Sustainable IT.


