Responsible Sourcing & Compliance

Forced Labor Policy

Prohibition of forced, bonded, trafficked, and involuntary labour across the supply chain.

Last updated: June 2026

Executive Summary

Plutonia Global Logistics Ltd prohibits forced, bonded, trafficked, and involuntary labour in any supplier or facility engaged through our network. This policy explains what forced labour is, the indicators we watch for, and the action we take when risk is found.

Forced labour is rarely advertised. It is identified through indicators — recruitment debt, document retention, restricted movement, and wage manipulation — that, taken together, show work is not truly voluntary. Our controls are designed to surface these indicators on a risk basis.

This policy is informed by recognised responsible business principles and complements our Modern Slavery Statement and Responsible Recruitment Policy.

Policy Scope

This policy applies across the order chain Plutonia coordinates, including:

  • Suppliers, manufacturers, and factories producing goods coordinated by Plutonia
  • Subcontractors and second-tier production sites used by those suppliers
  • Sourcing agents, trading companies, and intermediaries in the order chain
  • Logistics partners, freight forwarders, and warehouse and consolidation providers
  • Third-party inspection and testing partners engaged on a project basis
  • Plutonia team members involved in sourcing, verification, and logistics coordination

Core Principles

  • All employment must be voluntary.
  • Workers must be free to leave after reasonable notice.
  • No recruitment debt, deposits, or document retention.
  • No coercion, threats, or restriction of movement.
  • Labour brokers and intermediaries must meet the same standards.

Definition and Prohibition

Forced labour is any work or service exacted from a person under the threat of a penalty and for which the person has not offered themselves voluntarily. Plutonia prohibits all forms, including bonded and debt-bonded labour, indentured labour, trafficked labour, and prison labour that is involuntary. Prison labour, where it exists, must be lawful and genuinely voluntary; high-risk arrangements that cannot demonstrate this are not acceptable.

Freedom of Movement and Employment

  • Workers must be free to leave their employment after reasonable notice.
  • Workers must not be confined to the workplace or accommodation against their will.
  • Workers must not be required to lodge deposits or surrender identity or travel documents.
  • Employment must be based on freely agreed, understandable terms.

Recruitment Debt, Deposits, and Wage Manipulation

Recruitment practices must not create debt bondage. Workers must not be charged fees they must repay through labour, and wages must not be withheld, delayed, or subject to unexplained deductions as a means of control. Where fees have been improperly charged, suppliers are expected to remediate, including repayment to affected workers.

Labour Brokers and Intermediaries

Suppliers that use recruitment agencies or labour brokers remain responsible for ensuring those intermediaries follow these standards. Use of exploitative or unregulated brokers is a significant risk indicator.

Indicators We Act On

  • Workers cannot leave or must give up documents or deposits to work.
  • Recruitment debt, unexplained deductions, or withheld wages.
  • Threats, intimidation, or restriction of movement.
  • Use of unregulated labour brokers or undisclosed subcontracting.

Supplier Expectations

Suppliers engaged through the Plutonia network are expected to:

  • Ensure all employment is voluntary and terminable with reasonable notice.
  • Never retain workers' identity or travel documents.
  • Never require deposits or charge recruitment fees that bind workers.
  • Never use threats, coercion, or restriction of movement.
  • Pay wages in full and on time, with lawful deductions only.
  • Hold labour brokers and intermediaries to the same standards.

Our Due Diligence Approach

Plutonia applies this policy in practice on a risk-based basis, through:

Supplier profile review

We review the supplier's profile, product range, stated capacity, and history before engagement.

Business license check

We verify legal registration and business scope through available records.

Product document review

We review specifications, test reports, and certificates relevant to the product and destination market.

Factory photos / video

We request factory photos or video to confirm the facility and production capability where applicable.

Sample review

On a risk basis, we arrange product samples to confirm conformity before larger orders.

Third-party inspection

Where required by risk, buyer, or product category, we coordinate independent inspection.

Quality control checks

We apply quality control against approved specifications and samples during or before shipment.

Corrective action

Where issues are found, we require time-bound corrective action and re-verify.

Decision & monitoring

We approve, monitor, suspend, or reject suppliers based on findings, and continue monitoring active suppliers.

How This Helps International Buyers

Forced labour risk reduction. Clear prohibitions and indicators reduce a high-severity, high-exposure risk.

Tender and trade compliance. Support for forced-labour declarations and import-compliance expectations.

Supplier transparency. Visibility of recruitment, broker use, and wage practices.

Modern slavery alignment. Consistency with buyer modern-slavery reporting.

Grievance access. A confidential route for workers and partners to raise concerns.

Procurement records. Documented screening and action for governance.

Red Flags

On a risk basis, Plutonia watches for practical warning signs relevant to this policy:

  • Employer retention of passports or identity documents
  • Recruitment fees, deposits, or debt bondage
  • Workers unable to leave employment or confined on site
  • Withheld or delayed wages and unexplained deductions
  • Threats, intimidation, or signs of coercion
  • Use of unregulated labour brokers or hidden subcontracting

Corrective Action

Where risks or non-conformities are identified, Plutonia may take the following steps, proportionate to severity:

  1. Request clarification and additional information from the supplier
  2. Request supporting documentation, records, or evidence of compliance
  3. Recommend a time-bound corrective action plan with defined milestones
  4. Escalate the finding to the buyer where the order or project is affected
  5. Increase verification intensity, including inspection where warranted
  6. Suspend new orders pending remediation where risk is significant
  7. Reject or remove the supplier where serious issues are not remediated
  8. Record findings and actions where required for buyer or tender reporting

Reporting a Concern

Workers, suppliers, clients, logistics partners, and stakeholders may report concerns through Plutonia's grievance mechanism. Reports are treated confidentially, retaliation against good-faith reporters is prohibited, and concerns are reviewed on a risk basis.

Downloadable Resources

PDF documents are placeholders and will be made available here. Each policy can also be read in full online.

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Forced Labor Policy

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Supplier Declaration Form

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Supplier Self-Assessment Questionnaire

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Frequently Asked Questions

What counts as forced labour?
Forced labour is work exacted under threat of penalty that a person has not offered voluntarily. It includes bonded and debt-bonded labour, indentured labour, trafficked labour, and involuntary prison labour.
Is prison labour allowed?
Only where it is lawful and genuinely voluntary. High-risk arrangements that cannot demonstrate lawful, voluntary conditions are not acceptable in the Plutonia network.
Can employers hold workers' documents?
No. Retaining workers' identity or travel documents, or requiring deposits to work, are prohibited and are treated as forced-labour indicators.
What about recruitment fees?
Workers should not pay for a job. Recruitment fees that create debt bondage are prohibited. Where improper fees have been charged, suppliers are expected to remediate, including repayment.
Are suppliers responsible for labour brokers?
Yes. Suppliers that use agencies or brokers remain responsible for ensuring those intermediaries meet the same standards.
What does Plutonia do if forced labour is suspected?
Plutonia reviews the concern on a risk basis, prioritises worker welfare and remediation where possible, requires corrective action, and ends relationships where serious abuses are confirmed and not remedied.
How can someone report forced labour?
Through Plutonia's confidential grievance mechanism. Reports can be made with contact details or, where preferred, without identifying the reporter.

Disclaimer. Plutonia Global Logistics Ltd is continuously improving its responsible sourcing and compliance systems. This policy describes our expectations, due diligence approach, and improvement priorities. Specific verification, inspection, documentation review, and reporting activities may depend on buyer requirements, supplier location, product category, destination market, and project scope. Plutonia does not claim certifications, audit results, or compliance performance figures unless they are documented and verifiable.

Need This Documentation for a Tender or Buyer Review?

Plutonia can support international organizations, tender committees, NGOs, and corporate buyers with supplier verification, inspection, and reporting on a project basis.