When companies in Ireland think about human rights risks in their supply chains, they tend to think about what’s happening at the supplier end. Forced labour. Unsafe conditions. Excessive overtime. Problems that exist over there, in someone else’s operations, that need to be detected through audits and managed through corrective action plans.
That framing is comfortable. It’s also incomplete – and increasingly, it’s the thing that will get companies into trouble.
This is an operational risk, not a CSR issue
Let’s start with what’s changed. Human rights problems in your supply chain are no longer just a reputational or ethical concern. They are operational risks with direct commercial consequences.
The EU Forced Labour Regulation means goods linked to forced labour can be detained at the EU border. Not flagged. Not reported. Detained — your shipment doesn’t arrive, your production schedule slips, your customer doesn’t get served. UFLPA in the US is already doing this: shipments held, burden of proof on the importer to demonstrate the goods are clean. The EU’s Corporate Sustainability Due Diligence Directive creates legal obligations to identify and address human rights risks – and specifically requires companies to examine their own purchasing practices as part of that process.
And the litigation trajectory is clear. Recent court cases — (in the UK) Dyson settling a forced labour claim linked to a Malaysian supplier, (in France) Yves Rocher convicted under French duty of vigilance law — focus on what the buyer did or failed to do. Not just what happened at the factory.
If your supply chain has a human rights problem, it is your operational problem. That much is settled.
The harder question: are you causing it?
Here’s where it gets uncomfortable. The evidence – across sectors – increasingly shows that buyer purchasing practices are a primary driver of the human rights risks that companies then spend significant resources trying to detect downstream.
When your pricing on a contract manufacturing job doesn’t cover the cost of the safety and labour standards you require, your supplier cuts costs where it’s hardest for you to verify — hazardous tasks performed without adequate protective equipment, maintenance deferred on heavy machinery, workers pushed into excessive hours to hit throughput targets. When your project timelines compress or specifications change late, contractors and subcontractors absorb the pressure through migrant workers recruited at speed by agencies you’ve never vetted – workers who may be carrying recruitment debts, who may have had documents retained, who have no realistic route to raise a grievance. When your payment terms stretch to 90 or 120 days, the component supplier or raw material processor whose cash flow you’ve constrained defers the costs that have no immediate commercial consequence for you: payment of wages, worker welfare, safety investment, facility maintenance. And when you source the minerals, metals, or electronic components that feed your product lines from regions affected by conflict or weak governance, the opacity of those supply chains means the most severe risks — forced labour, community displacement, exploitation linked to armed groups — are precisely the ones your standard audit toolkit is least equipped to detect.
These aren’t problems that originate solely at the supplier. They’re conditions that buyer behaviour creates. International frameworks — the UN Guiding Principles, the OECD Guidelines — distinguish between causing harm, contributing to it, and being directly linked to it. Most buyers, if they examined their purchasing practices honestly, would find themselves in the “contributing” category. And the new legislation is built on exactly that framework.
There’s an operational dimension to this too, beyond enforcement. A supplier under impossible commercial pressure is a less reliable supplier. They tell you what you want to hear rather than what you need to know. They subcontract without telling you. Problems don’t surface until they’re crises. The human rights risk and the supply chain reliability risk are the same risk — you just see them at different points in the chain.
It’s hardest in high-risk regions
All of this is intensified when you’re sourcing from conflict-affected or high-risk regions – and if you’re in manufacturing or technology, the supply chains for critical minerals, electronic components, and specialist capacity frequently pass through exactly those contexts. Standard audit methodologies break down in situations where workers can’t speak freely and governance is weak or complicit. Buyer decisions about where to source and on what terms carry consequences well beyond the commercial relationship.
Come to the conference!
I’ll be speaking on exactly this at Ireland’s National Manufacturing & Supply Chain Conference and Exhibition at the RDS Simmonscourt, Dublin on 28th May. The session — “Buyer Behaviour as a Driver of Supply Chain Risk” (11.20am) – is aimed at procurement, supply chain, and operations professionals. No prior expertise in human rights frameworks assumed or required.
The argument is simple: buyer behaviour is a significant variable in determining whether human rights risks in supply chains are effectively managed or not. If you’re responsible for sourcing decisions, supplier relationships, or supply chain risk, this is about how your function operates — and how it will be assessed and regulated going forward.
Attending is FREE – click here to register: Home – National Manufacturing & Supply Chain Expo
Claire Lynch is the founder of Claire Lynch Consulting, a business and human rights advisory practice specialising in human rights due diligence, responsible purchasing practices, and supply chain accountability.
