Modern Slavery and Human Rights Risks in Digital and Consulting Supply Chains

The Hidden Risks in Digital Transformation

Modern slavery and human rights abuses are often associated with traditional industries such as manufacturing, agriculture, or construction. However, the digital transformation and consulting sectors face their own unique—and sometimes overlooked—risks. As organizations increasingly rely on global technology vendors, contingent labor, and complex project delivery models, the potential for exploitation, forced labor, and human trafficking can arise in unexpected places. The rapid pace of technological change, the use of temporary or remote workers, and the global reach of digital projects create vulnerabilities that demand vigilance and proactive management.

At Publicis Sapient, we recognize that digital progress must go hand-in-hand with ethical responsibility. Our commitment is to ensure that every link in our supply chain upholds the highest standards of human rights and dignity, setting a benchmark for responsible digital transformation.

Why Vigilance Matters in Non-Traditional Sectors

While digital and consulting supply chains may appear low risk compared to more traditional sectors, they are not immune to modern slavery. Technology vendors, software developers, and professional services providers may operate in regions with varying labor standards. The use of temporary, remote, or low-skilled workers—often through third-party agencies—can obscure employment relationships and increase the risk of exploitation. These factors make due diligence and ongoing monitoring essential for any organization committed to ethical sourcing.

Publicis Sapient’s Approach: Setting the Standard

Supplier Code of Conduct

Our Supplier Code of Conduct is the cornerstone of our approach to ethical sourcing and responsible business. It sets out clear, non-negotiable expectations for all suppliers, partners, and affiliates, including:

Prohibition of forced, bonded, or involuntary labor: All work must be voluntary, and workers must be free to leave employment with reasonable notice. Suppliers must not require workers to pay recruitment fees or surrender identity documents.
Ban on child labor and discrimination: Suppliers must comply with local laws on minimum age and ensure no worker is subject to discrimination, harassment, or abuse.
Safe and healthy workplaces: Suppliers are required to provide safe working conditions, comply with health and safety laws, and take proactive steps to prevent workplace accidents.
Fair pay and benefits: All workers must receive at least the minimum wage required by law, with overtime being voluntary and compensated appropriately.
Respect for human rights and dignity: Every worker must be treated with respect, and suppliers must uphold the right to freedom of association.
Environmental and ethical business conduct: Suppliers must comply with environmental laws, avoid bribery and corruption, and protect personal data.
Cascading standards: Suppliers are expected to ensure their own suppliers and subcontractors comply with these principles, amplifying our impact throughout the supply chain.

Best Practices: Due Diligence, Supplier Engagement, and Employee Training

Supplier Onboarding and Acknowledgement
All new suppliers must read and acknowledge our Supplier Code of Conduct as part of the onboarding process. This ensures a shared understanding of our standards from the outset.
Responsible Procurement and Risk Assessment
During the tendering process, suppliers complete a self-assessment questionnaire covering human rights, labor, and environmental practices. High-risk suppliers—such as those operating outside the UK or EEA, or employing temporary low-skilled workers—undergo enhanced due diligence, including detailed reviews and feedback to address any concerns.
Ongoing Monitoring and Auditing
Compliance is not a one-time check. We use platforms like EcoVadis to audit suppliers’ corporate social responsibility performance, including labor practices and ethics. Only suppliers who demonstrate commitment to our standards progress to the final selection stage. Annual audits by legal, procurement, and internal audit teams ensure ongoing compliance and continuous improvement.
Supplier Engagement and Remediation
Suppliers are encouraged to report any ethical concerns through confidential channels. All reports are investigated promptly, and in cases of material breach, we reserve the right to terminate business relationships to protect the integrity of our supply chain. Whistleblowers are protected from retaliation.
Employee Training and Awareness
Our employees are trained to recognize and respond to modern slavery risks. Our Anti-Slavery & Human Trafficking policy is included in the employee handbook and communicated to all new joiners. Ongoing training ensures that our people remain vigilant and empowered to act.

Transparency and Accountability: Annual Modern Slavery Statements

Publicis Sapient publishes annual Modern Slavery Statements, providing transparency on our actions and progress. These statements detail our risk assessment, supplier engagement, employee training, and continuous improvement efforts. We regularly review and update our processes to reflect evolving best practices and regulatory requirements.

Practical Guidance for Digital Procurement Leaders

Understand and Acknowledge the Code: Ensure your organization’s leadership and employees are familiar with the Supplier Code of Conduct and its requirements.
Complete Self-Assessment and Certification: Provide honest, thorough responses to self-assessment questionnaires and certify compliance annually.
Implement Robust Policies: Establish and maintain policies on human rights, environmental responsibility, and anti-slavery that meet or exceed the standards set out in the Code.
Monitor Your Own Supply Chain: Cascade these standards to your own suppliers and subcontractors, and monitor their compliance.
Engage in Continuous Improvement: Be proactive in identifying areas for improvement and work collaboratively with Publicis Sapient to address any gaps.

Leading by Example: Embedding Human Rights in Digital Transformation

Our approach goes beyond compliance. By integrating human rights considerations into every digital transformation initiative, we:

Mitigate operational and reputational risks
Build trust with clients, investors, and communities
Support ESG and regulatory compliance
Drive innovation and resilience through a transparent, accountable supply chain

We collaborate with clients and partners who share our values, influencing positive change throughout the digital ecosystem. Our leadership in responsible sourcing is recognized by clients and industry bodies alike, and we are proud to set a benchmark for ethical conduct in the digital and consulting sectors.

A Call to Action for the Digital Age

As digital transformation accelerates, so does our responsibility to ensure that progress does not come at the expense of human rights. Publicis Sapient invites procurement professionals, compliance officers, and clients to join us in advancing ethical business practices and eradicating modern slavery in all its forms. Together, we can build a digital future that is not only innovative, but just and humane.

For more information or to report a concern, please contact us through our confidential channels.

Publicis Sapient: Leading responsible digital transformation with integrity, transparency, and respect for human rights.