How do I know if my supply chain is actually transparent?
We hear this from sourcing managers every single week. And the honest answer is: you don't, not fully. No one does. What you can do is build a defensible paper trail that shows you asked the right questions and acted on the answers. That's what transparency means in practice. It's not a dashboard. It's a record of decisions.
If you're looking for the one move that separates serious programs from performative ones, it's this: map your supply chain to the raw material level for your top three commodities, then publish what you find. Not what you wish you found. What you actually found.
What does supply chain transparency actually mean?
It means knowing who touched your product at every stage, from the farm or mine to the finished good, and being able to prove it. The term 'ethical sourcing' itself describes the process of ensuring products are made under humane, environmentally sound conditions with fair pay for workers. Transparency is the evidence layer on top of that promise.
In practice, transparency has three components: traceability (can you follow the material?), disclosure (do you tell people what you found?), and verification (can a third party check your work?). Miss any one and you're just telling stories.
Isn't certification enough? We buy certified, so we're covered.
This is the myth we push back on hardest. Certification is a tool, not a shield. A Nature Food review found that while sustainability standards can improve production-process sustainability in some cases, they are insufficient to ensure food-system sustainability at scale, and their economic benefits for farmers are often modest. That's from researchers who study this for a living, not from critics with an agenda.
Certified cropland grew about 11% per year from 2000 to 2012 but still covered only about 1.1% of global cropland, concentrated in traded commodities like coffee, cocoa, tea, and palm oil. So even if every certified acre were perfect, you'd be looking at a rounding error against global production.
Certification tells you a farm or facility met a standard on the day of the audit. It doesn't tell you what happened the other 364 days. Use it as one input, not the whole answer.
What do the regulations actually require?
The compliance floor is rising fast, and if you sell into Europe or the US, you need to know where you stand. The EU Directive on corporate sustainability due diligence (Directive 2024/1760) entered into force on 25 July 2024. As amended by the Omnibus I simplification, it applies to large EU companies with at least 5,000 employees and EUR 1.5 billion net worldwide turnover, and to large non-EU companies with at least EUR 1.5 billion turnover in the EU (European Commission CSDDD).
Separately, the EU Deforestation Regulation covers cattle, wood, cocoa, soy, palm oil, coffee and rubber and derived products such as leather, chocolate, tyres and furniture, and repeals the EU Timber Regulation. Under the amended timeline, large and medium operators must comply from 30 December 2026, and micro and small operators from 30 June 2027 (European Commission EUDR).
In the UK, Section 54 of the Modern Slavery Act 2015 requires certain commercial organisations to publish an annual statement setting out the steps they take to prevent modern slavery in their business and their supply chains. In the US, CBP enforces forced-labour import prohibitions through Withhold Release Orders, Findings, the UFLPA and CAATSA. As of 2026 there were 58 active WROs and 9 active Findings.
Here's how the main transparency approaches compare:
| Approach | What it proves | Best for | Main limitation |
|---|---|---|---|
| Certification (Fairtrade, Rainforest Alliance, etc.) | Standard met at audit | Commodities with established schemes | Point-in-time snapshot; modest economic benefits |
| Direct supplier audits | Conditions at a specific facility | Tier 1 and key Tier 2 | Expensive; misses sub-tier |
| Traceability technology (blockchain, etc.) | Chain of custody data | High-value or high-risk inputs | Data quality depends on inputs |
| Regulatory disclosure (CSDDD, MSA) | Legal compliance | All large operators | Minimum bar, not a guarantee |
How do we prioritize where to look first?
Start with risk, not with volume. The commodities that carry the most human rights exposure are also the ones where the numbers are starkest. An estimated 50 million people were living in situations of modern slavery on any given day in 2021, according to the Global Estimates of Modern Slavery released in September 2022 by the ILO, Walk Free, and IOM (Walk Free Global Slavery Index). Of those, approximately 27.6 million were in forced labour and 22 million were in forced marriage.
Migrant workers were three times more likely to be in forced labour than non-migrant workers. More than half of all forced labour, and a quarter of all forced marriages, can be found in upper-middle-income or high-income countries. That last point surprises people. This isn't only a distant-farm problem.
Child labour is equally concentrated. UNICEF estimates that 160 million children around the world are engaged in work that threatens their health and safety or interrupts schooling, and 70 per cent of them are in the agricultural sector. In some regions such as sub-Saharan Africa, more than one child in four aged five to 17 is engaged in child labour, with poverty as the key driver.
For a concrete example: an estimated 1.5 million children aged five to 17 are working on cocoa farms in Côte d'Ivoire and Ghana alone. If cocoa is in your product, that number is your problem, whether or not your specific supplier is implicated.
What does a good disclosure look like?
Good disclosure is specific, honest about gaps, and tied to action. Bad disclosure is a glossy PDF that says 'we are committed to ethical sourcing' without naming a single supplier, region, or remediation step.
We recommend publishing three things: your supplier list down to Tier 2 where feasible, your audit findings including failures, and your remediation timeline with named owners. The UK Modern Slavery Act statement is a legal floor, not a ceiling. Companies that treat it as a ceiling get caught flat-footed when a journalist or an NGO does the mapping they didn't.
Where should a small or mid-sized brand start?
You don't need a blockchain pilot. You need a spreadsheet and uncomfortable conversations. Start with the highest-risk commodity in your highest-volume product. Map it to the first point of aggregation. Ask your direct supplier who they buy from, then ask that supplier the same question. Repeat until you hit a farm or mine or you hit a wall. Document the wall.
Then join something. The UN Global Compact is the world's largest corporate sustainability initiative, with more than 20,000 companies based in over 160 countries. If minerals are in your product, the Responsible Minerals Initiative, founded in 2008, has templates and tools you can adopt without reinventing them.
One more thing: pay attention to what certification actually delivers on the ground. Fairtrade cocoa producers earned EUR 57 million in Fairtrade Premium in 2023, and the global Fairtrade Premium exceeded EUR 211 million by 2023, supporting people in more than 75 countries. That's real money. But it's also a fraction of what farmers need, which is why the Nature Food finding about modest economic benefits matters. Certification helps. It doesn't solve.
Bottom line
Map your top three commodities to the raw material level, publish what you find including the gaps, and set a remediation timeline with names attached. Do that before you buy another certification logo.
Sources
- Fairtrade International - https://impact.fairtrade.net/about
- McKinsey & NielsenIQ (2023) - https://www.mckinsey.com/industries/consumer-packaged-goods/our-insights/consumers-care-about-sustainability-and-back-it-up-with-their-wallets
- Meemken et al. (Nature Food, 2021) - https://www.nature.com/articles/s43016-021-00360-3
- Tayleur et al. (Conservation Letters, 2017) - https://doi.org/10.1111/conl.12314
- Walk Free Global Slavery Index - https://www.walkfree.org/global-slavery-index/findings/global-findings/
- European Commission (CSDDD) - https://commission.europa.eu/business-economy-euro/doing-business-eu/corporate-sustainability-due-diligence_en
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