The guidance is directly relevant for APSCA Members because it recognises audit-related information as part of the evidence that may be requested or considered during an investigation.
It lists third-party independent audit reports as one type of information that may show what a company has done to identify, prevent, mitigate, bring to an end or remediate forced labour risks. It also lists social audits as one type of information on working conditions at the site of alleged forced labour.
The guidance also refers to worker interview transcripts, written testimonies, photos or videos of working conditions and dormitories, lists of workers, employment contracts, payrolls, financial records, surveys and remediation evidence. These are exactly the kinds of site-level information that competent social compliance auditors may be asked to collect, review or assess.
The important point is credibility. The guidance expects competent authorities to rely on objective, factual and verifiable information from reliable sources. For audit-related information, this brings the focus back to how evidence is collected, documented and assessed.
For APSCA Members, the practical message is clear: where audit-related information is used, its value will depend on credibility. That puts more weight on competent auditors, sound worker interview practice, clear documentation and a strong understanding of forced labour indicators.
This is also where APSCA’s Competency Framework is relevant. The EU guidance uses the ILO definition of forced labour and refers to forced labour indicators, including deception, debt, degrading working and living conditions, excessive working hours, restriction of movement, retention of identity documents, withholding of wages, threats, intimidation and abuse of vulnerability. These areas are closely reflected in APSCA’s competency expectations for social compliance auditors.
APSCA will continue monitoring the implementation of the EU Forced Labour Regulation and related guidance. We also plan to organise a more specific member engagement on this topic in due course, including how the guidance may affect the way audit-related information is understood and used in forced labour investigations.
