ERWAY

ILO indicators of forced labour under the EUFLR

The Regulation takes its definition of forced labour from ILO Convention No. 29. The Commission Guidelines take their risk vocabulary from the ILO's eleven indicators, and so does the platform.

The indicators are abuse of vulnerability, deception, restriction of movement, isolation, physical and sexual violence, intimidation and threats, retention of identity documents, withholding of wages, debt bondage, abusive working and living conditions, and excessive overtime. None alone proves forced labour; a pattern of them is what the ILO says to look for, and the Guidelines adopt that approach for the risk-identification step of their voluntary framework. In the platform every supplier question names the indicator it tests and the evidence that settles it — a recruitment-fee ledger for debt bondage, a document-retention policy and locker inventory for retention of identity documents, a payroll extract for withholding of wages. Every screening hit is tagged with one, so a count per indicator across all suppliers shows a pattern before any single case does. And the grade on the evidence follows the Guidelines: an assurance that fees are not charged is 'asserted'; the ledger is 'verified'.

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