Modern Slavery Risks and Mitigation in Digital Transformation: Sector-Specific Guidance for Financial Services, Retail, Energy, and Public Sector

Digital transformation is revolutionizing industries, but with this progress comes a critical responsibility: ensuring that innovation does not come at the expense of human rights. Modern slavery—including forced labor, human trafficking, and exploitation—remains a risk across global supply chains, even in sectors not traditionally associated with these issues. At Publicis Sapient, we recognize that the risks and mitigation strategies for modern slavery differ across industries. Our sector-specific approach ensures that clients in financial services, retail, energy, and the public sector receive tailored guidance and robust frameworks to address their unique challenges.

Understanding Sector-Specific Modern Slavery Risks

Financial Services

While direct operations in financial services are often considered low risk for modern slavery, the sector’s complex supply chains introduce indirect vulnerabilities. Outsourced IT and software development—especially in regions with weaker labor protections—facilities management, and cleaning services that may rely on temporary or migrant labor are notable risk areas. Third-party service providers with opaque subcontracting chains can further obscure labor practices.

Best Practices:

Rigorous supplier onboarding, requiring adherence to a comprehensive Supplier Code of Conduct that prohibits forced labor and mandates fair working conditions
Annual supplier self-assessment questionnaires and certifications of compliance with modern slavery laws
Enhanced due diligence for high-risk suppliers, including those operating outside the UK or EEA or employing low-skilled, temporary workers
Ongoing monitoring through platforms like EcoVadis, which audit suppliers’ corporate social responsibility (CSR) standards

Retail

Retailers face heightened modern slavery risks due to their extensive, multi-tiered supply chains, often spanning countries with varying labor standards. Key risk areas include sourcing of raw materials and manufactured goods from high-risk regions, use of third-party logistics, and seasonal or temporary labor in warehousing and customer service.

Best Practices:

Supplier Code of Conduct that cascades ethical standards throughout the supply chain, not just direct suppliers
Responsible procurement processes, including CSR questionnaires and audits during supplier selection
Annual recertification and targeted reviews for suppliers in high-risk geographies or sectors
Training for procurement teams to recognize and address modern slavery indicators

Energy

The energy sector’s global operations and reliance on large-scale infrastructure projects introduce unique risks, particularly in construction, maintenance, and extraction activities. Vulnerabilities may include the use of subcontractors and labor agencies in regions with limited oversight, procurement of equipment and materials from countries with known labor rights issues, and temporary or migrant labor in remote or hazardous environments.

Best Practices:

Comprehensive risk assessments for all major projects, identifying high-risk suppliers and subcontractors
Mandatory supplier self-assessment and adherence to anti-slavery policies as part of contract terms
Regular audits and site visits for suppliers in high-risk categories
Collaboration with industry peers to share best practices and raise standards across the sector

Public Sector

Public sector organizations are held to high standards of transparency and accountability, but their diverse procurement needs—from IT services to facilities management—can expose them to modern slavery risks. Challenges include large, decentralized supplier networks, outsourcing of services such as cleaning, catering, and security, and pressure to deliver value for money, which can inadvertently drive cost-cutting at the expense of labor standards.

Best Practices:

Embedding modern slavery due diligence into procurement policies and tendering processes
Requiring all suppliers to acknowledge and comply with a robust Supplier Code of Conduct
Annual supplier declarations and targeted reviews for high-risk contracts
Employee training and clear reporting mechanisms for concerns related to modern slavery

Publicis Sapient’s Framework for Mitigation and Engagement

Across all sectors, Publicis Sapient’s approach is grounded in:

Supplier Code of Conduct: Setting clear expectations for ethical behavior, human rights, and environmental responsibility. All suppliers must acknowledge and adhere to these standards as part of onboarding.
Risk Assessment and Due Diligence: Comprehensive evaluation of suppliers, with enhanced scrutiny for those in high-risk regions or sectors. Annual self-assessment questionnaires and certifications are required.
Responsible Procurement: Integration of CSR considerations into supplier selection, with platforms like EcoVadis used to monitor ongoing compliance.
Employee Training and Awareness: Ongoing education for employees and management to recognize risks and understand reporting procedures. Confidential whistleblowing channels are available to all staff.
Continuous Improvement: Regular review and enhancement of policies, informed by audits, supplier feedback, and evolving best practices.

Regulatory Expectations and Ethical Leadership

Publicis Sapient’s anti-slavery efforts align with the UK Modern Slavery Act and international standards such as the United Nations Global Compact. Our annual Modern Slavery Statements provide transparency on our actions and progress, reinforcing our commitment to ethical business across all sectors. We encourage clients and partners to adopt similar standards, amplifying the impact throughout the value chain.

Why Sector-Specific Guidance Matters

Each industry faces distinct challenges in addressing modern slavery. By tailoring our frameworks and engagement strategies, Publicis Sapient helps organizations not only comply with legal requirements but also lead with integrity in their digital transformation journeys. Our sector-specific expertise ensures that clients can identify risks, implement effective controls, and build trust with stakeholders.

Ready to advance your organization’s approach to modern slavery in digital transformation? Connect with Publicis Sapient to learn how our sector-specific solutions can help you achieve ethical, sustainable, and future-proof business transformation.