When a serious labour or human rights issue emerges, the pressure on a company is immediate, high-stakes, and often very public. What may begin as an allegation can quickly escalate into a regulatory, legal, and reputational crisis if not handled with care, speed, and credibility.
These situations are commonly triggered by whistle-blowers, media investigations, NGOs, or critical audit findings. For many organisations, this may be the first time they are required to respond under intense scrutiny, while balancing legal risk, operational disruption, and the urgent need to protect workers.
In moments like these, companies need more than an assessment or a checklist. They need calm, experienced support that helps them understand what has happened, respond responsibly, and move forward with confidence.
The spectrum of labour and human rights crises
Labour and human rights crises exist along a broad spectrum, varying in both severity and impact. At one end are issues that, while serious, may initially surface through audit findings, worker complaints, or NGO engagement. These can include recruitment fees, unpaid wages, excessive working hours, child labour, worker protests, or gender-based violence and harassment. When identified early and addressed credibly, many of these issues can be resolved before they escalate.
At the other end of the spectrum are situations of the highest severity and scrutiny. These include regulatory enforcement actions such as Withhold Release Orders, where authorities may detain goods on the basis that they have been produced using forced labour. These cases typically arise where risks are systemic, unresolved, or highly visible, and they represent the most demanding test of a company’s human rights due diligence and crisis response.
How a company responds, at any point along this spectrum, can determine not only regulatory outcomes, but long-term trust with workers, regulators, and other stakeholders.
Responding well in a crisis
In any crisis situation, speed and rigour matter. The priorities are decisive action, credibility with regulators and stakeholders, and protection of workers.
Effective response requires a clear sequence of steps: rapid mobilisation, a rigorous understanding of root causes, practical and credible remediation, and sustained follow-through to prevent recurrence. This is not simply about managing risk. It is about demonstrating accountability and ensuring that affected workers experience meaningful and lasting change.
When scrutiny is at its highest
At the most extreme end of the spectrum, Withhold Release Orders represent the highest level of regulatory scrutiny a company can face. Issued by US Customs and Border Protection, a WRO allows authorities to detain goods where there is reason to believe they have been produced using forced labour.
While WROs remain relatively rare, their consequences can be severe. Companies may face detained shipments, significant financial losses, supply chain disruption, damaged relationships with regulators, and long-term reputational harm. Responding effectively in these circumstances requires highly specialised expertise, deep regulatory understanding, and the ability to deliver credible, worker-centred remediation under intense scrutiny.
Impactt’s leadership in WRO response and remediation
Impactt is widely recognised as a leader in supporting companies through Withhold Release Orders and other high-risk forced labour enforcement actions.
We have worked with multiple organisations subject to WROs, supporting them through investigation, remediation, and engagement with regulators, including cases that have resulted in the modification or lifting of enforcement actions. Our approach is grounded in deep technical expertise, extensive on-the-ground experience, and a clear understanding of regulatory expectations.
Importantly, Impactt’s work goes beyond compliance. We focus on credible, worker-centred remediation that stands up to scrutiny from regulators, governments, and civil society, while helping companies rebuild trust and strengthen their systems for the long term.
Proof in practice: Top Glove
Impactt’s work with Top Glove is featured by the United States Department of Labor as a best practice case example within its WRO information resources.
Following allegations of forced labour and the issuance of a WRO, Impactt worked closely with Top Glove over a 13-month period to investigate root causes and support credible remediation. This resulted in more than USD 36 million in remediation payments to over 12,000 migrant workers, alongside systemic improvements to worker accommodation and grievance mechanisms.
The US Department of Labor cited the transparency and effectiveness of this remediation as instrumental in addressing the identified forced labour risks.
Facing a serious labour allegation or a WRO?
Impactt has supported organisations across multiple sectors to respond to labour and human rights crises, including some of the most complex WRO cases globally. With more than 28 years of experience, we help companies move from crisis to credible, worker-centred remediation with confidence and care.
