Behind the screens of our smartphones and the powerful servers driving the digital economy lies a complex global supply chain, one that, all too often, hides serious human rights and labour abuses. From children mining cobalt in Congolese pits to factory workers enduring forced overtime or worse, the tech sector’s procurement network faces profound social ESG (Environmental, social and governance) challenges. Ireland, France, and the UK, as leading tech hubs and major markets, are increasingly demanding ethical standards in both public and private procurement. This article delves into the “Social” aspect of ESG in tech procurement, examining labour practices in supply chains and how regulations and companies are responding. Backed by data and recent developments, we’ll see how these countries are working to eliminate exploitation and uphold human rights from raw material sourcing to final assembly.
Labour Risks from Mines to Manufacturing
Technology supply chains span the globe and often reach into regions with weak labour protections. A stark fact underscores the scale of the issue: on any given day in 2021, an estimated 27.6 million people worldwide were in forced labour situations, according to the International Labour Organisation, a number that has risen in recent years. The electronics industry is identified as especially high-risk. In fact, electronics are the highest-value product category at risk of forced labour among goods imported by G20 countries. This means the devices and components flowing into markets like Europe frequently carry a hidden human cost. One of the most troubling examples is the mining of cobalt, a metal essential for lithium-ion batteries used in smartphones, laptops and electric cars. The Democratic Republic of Congo (DRC) produces over 70% of the world’s cobalt, making it a linchpin of the tech supply chain. But much of this cobalt comes from small-scale “artisanal” mines where oversight is scant. It’s estimated that of the 255,000 Congolese miners digging for cobalt, around 40,000 are children, some as young as six.
These child miners and adult workers labor in extremely unsafe conditions, facing risk of tunnel collapses, toxic exposure, and exploitation by middlemen. The DRC’s cobalt riches thus come at a grave human cost: widespread child labour, life-threatening safety issues, and often violent conflict over mining areas. The cobalt example illustrates a broader point: many raw materials in tech (from rare earths to lithium to tin) originate in regions where labour rights abuses and even modern slavery can occur. Further up the supply chain, manufacturing stages have also drawn scrutiny. Factories assembling electronics in some countries have been linked to forced labour and harsh working conditions. In China’s Xinjiang region, for instance, reports in recent years have uncovered forced labour programs involving ethnic minorities, raising alarms that components (such as silicon chips, batteries or textiles) made with coerced workers could be finding their way into global tech products.
More generally, excessive overtime and debt bondage are perennial issues in electronics manufacturing across Asia. There have been cases of workers in supplier factories forced to work 70-80 hour weeks or give up their passports until production quotas are met. These abuses tend to hide in the lower tiers of the supply chain, where subcontractors might flout codes of conduct. The challenge for procurement is that visibility drops off deep in the chain, making it difficult to trace and police labour practices at mines or sub-supplier workshops. Nonetheless, awareness is growing that every smartphone or computer could carry “embedded” labour rights violations, unless proactive steps are taken.
Regulatory Responses: From Transparency to Due Diligence
In response to these issues, governments in Ireland, France, and the UK have enacted regulations to push companies toward cleaner supply chains. A pioneering law in this area was the UK’s Modern Slavery Act 2015. This Act requires any large company operating in the UK (over £36 million in turnover) to publish an annual Modern Slavery Transparency Statement disclosing the steps it is taking to ensure no slavery or human trafficking exists in its business or supply chain. While the Act doesn’t impose fines for findings of forced labour, the “transparency in supply chains” provision relies on public and investor scrutiny to pressure companies into action. It effectively made the UK the first country to demand supply chain accountability on modern slavery from the private sector at scale. In government procurement, the UK has also tightened the reins: suppliers convicted of offences related to modern slavery are subject to mandatory exclusion from public contracts. Moreover, in 2023 the UK government issued Procurement Policy Note 02/23, instructing all departments to identify and manage modern slavery risks in their supply chains as a formal part of the contracting process.
France took a more sweeping approach with its Duty of Vigilance Law (2017). This law compels large French companies (employing 5,000+ domestically or 10,000+ globally) to establish a “plan de vigilance” – a vigilance plan – to identify and prevent human rights and environmental violations throughout their supply chains. The vigilance plan must include a risk mapping of operations, procedures to regularly assess subsidiaries and suppliers, actions to mitigate risks, and mechanisms for whistleblowing and monitoring.
Companies that fail to implement an adequate plan can face civil penalties up to €10 million and liability for damages. France’s law was one of the first anywhere to impose a broad due diligence obligation on corporate supply chains, moving beyond mere transparency to requiring concrete prevention measures. Crucially, it covers not just first-tier suppliers but also indirect suppliers and subcontractors – reinforcing that multinationals must take responsibility for their entire “chain of activities.” This approach has since inspired other jurisdictions and paved the way for EU-wide legislation.
Indeed, in 2024 the European Union approved the Corporate Sustainability Due Diligence Directive (CSDDD), a landmark law that will mandate human rights and environmental due diligence for large companies across all member states. Set to be phased in from 2027, the directive will oblige in-scope companies (both European firms above certain size thresholds and non-European firms with significant EU turnover) to identify and assess human rights risks in their operations and supply chains, prevent or mitigate those risks, and publicly report on their due diligence efforts.
Importantly, the EU directive creates legal teeth: member states must impose sanctions (including fines up to at least 5% of a company’s global turnover) for non-compliance, and it provides for civil liability if companies cause harm by not exercising due diligence. In scope are issues like forced labour, child labour, inadequate workplace health and safety, and environmental harms. This means that a tech company operating in Europe will soon be legally required to trace and address abuses such as the ones in the DRC or in far-flung factories, rather than treating them as distant uncertainties. Ireland, France, and Germany already have national laws, but the CSDDD will harmonise these rules and raise the bar across the EU. As of mid-2025, companies are gearing up for these requirements, mapping their supply chains more deeply and setting up programs to audit and improve conditions at suppliers. The directive represents a paradigm shift: ethical supply chain management will no longer be voluntary goodwill, but a regulatory expectation. Other measures complement this trend.
For example, the EU’s Conflict Minerals Regulation (in force since 2021) requires importers of tin, tantalum, tungsten, and gold (3TG minerals often used in electronics) to conduct due diligence to ensure those minerals are not financing armed conflict or human rights abuses. While 3TG are outside our main region focus, the regulation directly addresses issues like armed groups exploiting mines – again pushing transparency and responsible sourcing. There are also discussions at the EU level about banning products made with forced labour from the European market entirely, similar to the U.S.’s Uyghur Forced Labor Prevention Act. Meanwhile, in the UK, there are calls to strengthen the Modern Slavery Act by adding mandatory due diligence (not just reporting) and expanding enforcement, as recommended by a 2019 parliamentary review. In summary, the legislative landscape in Europe is moving from soft transparency towards hard accountability. Ireland, France, and the UK are collectively signaling that procurement – whether by governments or corporations – must integrate human rights considerations. Suppliers that violate labour standards risk losing access to contracts or even markets. This regulatory pressure is a crucial backdrop driving change in procurement practices in the tech sector.
Industry Action: From Codes of Conduct to Supply Chain Overhaul
Regulations alone, however, are only part of the solution. The tech industry itself has been under increasing pressure from consumers, investors, and civil society to clean up its supply chains. Many leading tech companies have adopted detailed Supplier Codes of Conduct setting forth labour standards (banning forced labour, child labour, discrimination, unsafe working hours, etc.), which their suppliers are contractually obligated to follow. Organisations like the Responsible Business Alliance (RBA) – a coalition of electronics companies, have developed common standards and audit protocols that member companies use to assess factories. For instance, buyers now conduct regular factory audits to check compliance on metrics like worker age verification, working hours, wages, and health & safety conditions. When violations are found, suppliers are typically required to remediate (e.g. paying back any unlawful recruitment fees to workers, or upgrading safety equipment) or face blacklisting. High-profile companies report on these efforts annually. Apple, for example, publishes a Supplier Responsibility Progress Report each year detailing findings from hundreds of audits. In recent years Apple has claimed 100% of identified cases of bonded labour (where workers had paid recruitment fees) were corrected with fees reimbursed, and that it actively removed underage workers from hazardous work and helped them return to schooling.
They also have a policy of cutting ties with suppliers that show repeated unwillingness to improve. Similarly, HP Inc. has been noted for disclosing its list of smelters and refiners for minerals and pushing for only conflict-free certified sources. Supply chain transparency is becoming an emerging norm – with some tech companies even publicly listing their top-tier suppliers by name and address, a practice once unheard of outside the apparel industry. This openness allows NGOs and workers’ groups to monitor factories and report abuses more easily.
Procurement teams within tech companies are increasingly central to these efforts. By incorporating ESG criteria into supplier selection and contract clauses, they leverage business incentives for suppliers to uphold labour standards. For example, buyers may require bidders to demonstrate their commitment to fair labour practices or possess certain social responsibility certifications. In one case, the City of London (though a public entity, its approach is illustrative) included a requirement in a recent IT services tender that bidders show their investment in “social value,” which made up 10% of the evaluation score. The winning supplier’s promise to run apprenticeships and digital skills programs in disadvantaged communities helped clinch the deal. While that example is local social impact, it reflects a wider principle: procurement decisions can reward suppliers who act responsibly and contribute positively to society. In the global context, that means preferring suppliers with good labour practices records. Technology is also being harnessed to improve supply chain ethics. Some companies use blockchain and advanced traceability tools to track raw materials from mine to product, aiming to verify they are sourced without abuse. Others are collaborating in initiatives like the Fair Cobalt Alliance to formalise small mines and eliminate child labour in the DRC.
Additionally, third-party platforms such as KnowTheChain rank ICT companies on their efforts to combat forced labour, creating reputational incentives for improvement. Public procurement is joining in: for instance, the UK’s Crown Commercial Service provides guidance and toolkits on identifying modern slavery risks among government suppliers, and Ireland’s National Action Plan on Business and Human Rights encourages state agencies to include human rights criteria in purchasing. Each of these steps helps build momentum. When large buyers demand ethically sourced components – whether it’s a government requiring proof that its laptop supplier has no forced labour in the supply chain, or a phone maker insisting its battery suppliers source cobalt responsibly, it forces change down the line. Tier-1 suppliers, in turn, pressure their own sub-suppliers to comply, creating a cascade of improved practices. But of course, some challenges remain and audits can be superficial or announced in advance, allowing problems to be hidden.
Lower-tier suppliers can be numerous and change frequently, complicating oversight. Remedying deep-rooted issues like poverty (which drives child labour) is beyond any single company’s scope. Nonetheless, the trajectory is clear: ethical procurement is becoming a standard expectation. Consumers now often ask questions like, “Was anyone harmed in making this device?” Investors evaluate companies on ESG indices that include labour rights. And employees within tech firms are themselves pushing corporate leadership to uphold values in all operations. Conclusion: Ensuring human rights and fair labour in tech procurement is a complex but non-negotiable mission in the 21st century. Ireland, the UK, and France are contributing to this mission through a mix of legislation that compels transparency and due diligence, and through leadership by example, as when public bodies choose ethically sourced products. The tech sector’s supply chain, once notorious for opaque practices, is gradually being illuminated: from Congolese mines to Chinese factories, the demand for accountability grows. While no single policy or audit will erase abuses overnight, together these efforts form a web of pressure and support for better practices.
Procurement leaders and teams now play a frontline role in safeguarding human rights, by choosing suppliers carefully, embedding strict standards in contracts, and collaborating internationally to enforce those standards. The message is resonating: the people who make our tech, whether digging minerals or assembling chips, deserve dignity and safe, fair conditions. Ethical tech procurement seeks to make this a reality, ensuring that innovation and progress are never tainted by exploitation.
Sources:
France passes law requiring supply chain due diligence – Supply Chain Dive
Landmark EU “Corporate Sustainability Due Diligence Directive” Imposing Human Rights and Environmental Due Diligence Obligations on EU and Non-EU Companies Approved by European Parliament – Gibson Dunn
Modern Slavery Act: House of Lords Select Committee recommends that UK adopts supply chain due diligence requirements and import bans – Norton Rose Fulbright
