In this Spotlight On, we’re speaking to David Rousseau, one of our Principal Consultants, about forced labour, one of the most entrenched challenges in global supply chains. This is particularly the case in high-risk, high-pressure environments like energy and heavy industries, including renewable energy development.
While traditional approaches have relied on compliance-driven audits and supplier assessments, we know at Impactt, these strategies alone are not enough. The financial structures underpinning procurement—low supplier margins, aggressive cost-cutting, and unsustainable pricing models—are often the biggest drivers of worker exploitation.
As industries navigate mandatory human rights due diligence regulations, the shift toward a Just Transition, and increasing scrutiny on supply chain risks, it’s time for companies to rethink their approach. Rather than treating forced labour as a compliance issue, businesses need to address the financial levers that shape labour conditions at the ground level.
Having worked in both on-the-ground settings and high-level policy discussions, David brings a cross-sector perspective to tackling deeply embedded labour risks. In this conversation, we explore: How companies are shifting toward financial solutions to address forced labour, the role of development finance in mitigating human rights risks in renewable energy supply chains, and practical strategies for improving human rights due diligence in the Energy & Heavy Industries sector.
So, how can businesses move beyond compliance and start tackling the financial root causes of forced labour?
David, how are companies addressing the financial root causes of forced labour, and what role does Impactt play in guiding companies toward more responsible procurement?
Many forced labour issues fundamentally stem from low supplier margins and product pricing structures. When suppliers operate on razor-thin profit margins, they struggle to invest in essential employment conditions, such as health and safety, reasonable working hours, quality accommodation, responsible recruitment systems, and so on.
To tackle these challenges, companies are addressing these root causes by reassessing their procurement models. Ultimately, it’s about connecting the financial bottom line with what is happening in the supply chain. This is a widespread issue in several sectors, but progress is being made through collaboration and cross-sector thinking. Addressing financial root causes can have wide-reaching benefits for workers. A simple yet effective step is for procurement teams to integrate human rights considerations into supplier selection, rather than focusing solely on cost, while also collaborating with suppliers to ensure that commercial agreements enable them to meet human rights expectations and provide decent working conditions.
Looking specifically at recruitment, one potential innovative solution in the food and agriculture sector is for companies to pilot small price increases, raising product costs by just a few pence, and then channelling the additional revenue to suppliers. This targeted investment can help suppliers implement responsible recruitment practices, ultimately reducing the risk of forced labour.
With our energy and heavy industries (EHI) clients, the Just Transition is on everyone’s minds. Development Finance Institutions are increasingly investing in large-scale renewable energy infrastructure projects in developing countries, helping to advance the transition in line with the UN’s climate goals. However, these projects are fraught with human rights risks, as renewable energy developers source raw materials and components for wind farms and solar panels that are tainted with forced labour.
These companies often have a low level of awareness of these risks and how to procure responsibly. As a result, Development Finance Institutions have increasingly commissioned Impactt to evaluate their practices and build their capacity to better avert forced labour risks in their supply chains and procure more responsibly.
With financial pressures playing such a critical role, companies must take a more strategic approach to human rights due diligence. So, what practical steps can businesses take to strengthen their human rights due diligence and drive meaningful change?
1. Collaboration and information sharing
Too often, we see EHI clients commissioning supplier assessments that have already been conducted by other companies. These repeat audits add limited value, particularly when labour rights issues in the sector are already well-documented. Instead of investing in duplicate assessments, EHI companies should collaborate on joint initiatives that address systemic risks and build supplier capacity to drive meaningful change.
Many assessments are commissioned as a tick-the-box compliance exercise, even when suppliers have already undergone multiple audits. A key issue is the lack of information sharing between companies, leading to audit fatigue for suppliers and redundant efforts.
Recognising this, we are shifting towards a “needs assessment” approach, focusing less on issue identification and more on addressing the structural root causes—such as capacity, internal processes, and resource constraints—that hinder progress. This approach integrates into broader capacity-building programs that deliver long-term impact.
2. Consider gap analysis
Instead of site-by-site analysis, businesses should consider the need to ensure strategic oversight of systems and match this with on-the-ground action through gap analysis.
Companies must re-evaluate their HRDD system in light of mandatory due diligence legislation, ensuring the right policies and governance structures for human rights are in place.
Looking at systems at a higher level, with strategic oversight, enables businesses to effectively identify, assess, and address risks in their operations and supply chains. This also supports findings being fed back into the HRDD system as a whole in an effective way.
3. Recruitment fee remediation
Many companies are committed to the employer pays principle but struggle with recruitment fee investigations and remediation. Fortunately, many more companies are now actively investigating recruitment fees and following up with remediation efforts.
We are keen to see more of these initiatives, supported by mediators such as Impactt, to ensure responsibilities between actors are carried out effectively.
Your career has spanned both on-the-ground investigations and high-level engagement with businesses, public sector funders, and NGOs. How has this cross-sector experience shaped your approach to tackling forced labour and strengthening human rights due diligence in EHI supply chains?
After studying International Development, I launched my career working for an energy procurement consultancy but felt this wasn’t closely aligned enough to my passion for human rights and international development. I made a radical decision and moved to Thailand to gain fieldwork experience, which I believe is essential for working in this space.
I was based in Samut Sakhon, a port where many Burmese migrant workers were trafficked. I worked with the Labour Rights Promotion Network (LPN), an NGO dedicated to protecting migrant workers in Thailand. This allowed me to engage with local organisations, multinational food retailers, and victims of human trafficking in the fishing sector.
These experiences provided invaluable insights into how forced labour manifests in practice and the devastating impact it has on workers. They laid a crucial foundation for my later career as a Lead Assessor, Senior Consultant, and now Principal Consultant at Impactt. Field experience is the golden thread throughout my career—it enables me to communicate worker issues effectively to senior stakeholders and develop solutions that are both practical and impactful.
Beyond traditional land-based supply chains, the maritime industry faces similar financial pressures that can lead to worker exploitation. Seafarers operate in some of the most complex and isolated environments, where cost-driven decision-making and subcontracting structures can obscure accountability for labour conditions. Given these challenges, how can companies in the EHI sector better address risks and improve protections for seafarers?
At Impactt, we recognise that addressing these risks requires a systemic approach—one that takes into account how financial pressures influence working conditions at sea. We are designing a new vessel assessment methodology tailored to the maritime sector, ensuring companies can leverage procurement relationships to drive better standards. By conducting assessments early in the voyage, vessels can implement corrective actions while still under contract, ensuring compliance incentives align with worker protections.
By conducting assessments early in the voyage, vessels can implement corrective actions while they are still under contract with the vessel management company, ensuring stronger compliance incentives.
Final Thoughts:
As industries face growing regulatory pressures and evolving stakeholder expectations, it’s clear that addressing forced labour requires more than compliance—it requires a fundamental shift in how financial decisions shape labour rights. From supplier engagement to procurement reform, the most forward-thinking companies are embracing a systems-level approach to human rights due diligence.
As David’s insights highlight, the key to lasting impact lies in collaboration, financial accountability, and proactive industry leadership. The question now is: how can businesses integrate these strategies into their own operations to drive real change?
