Indicator 3.2.1

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Indicator 3.2.1

by Contact on 8 October 2026

Requirement

The UoC shall not engage in or support forced labour.

How Do I Interpret This Requirement?

  • Forced labour can take many forms and can include:

    • work that is exacted from any person under the threat of any penalty:

      • penalties do not need to actually take place for forced labour conditions to occur. The threat itself of the penalty or any other type of retaliation, as well as the penalty itself, constitutes forced labour

      • ILO (2015), Combating Forced Labour: A Handbook for Employers and Business. Available at: <https://www.ilo.org/media/441596/download> penalties and other types of retaliation include but are not limited to the following (adapted from ILO Handbook on Forced Labour):

        • isolation, restriction of movement, confinement or imprisonment

        • physical and sexual violence against employees, family or close associates

        • abusive working and living conditions

        • excessive overtime

        • financial penalties, withholding of wages

        • shift to even worse working conditions, removal of rights or privileges

        • exclusion from future employment

        • deprivation of food, shelter or other necessities

        • denunciation to authorities such as police or department of immigration, deportation

        • any other type of physical, mental or social harm

        • work for which the person has not offered himself or herself voluntarily, including where employees are not allowed to terminate employment at any time

        • the use of deception or other forms of coercion, including where employees are not informed of working conditions prior to or during employment

    • the use of exploitative loans to prevent employees from leaving their jobs. This is also referred to as debt bondage, which can occur when employees:

      • incur debts related to employer loans with high interest rates

      • are forced to pay off recruitment fees or associated costs

      • are forced to pay high portions of their salaries towards employer provided accommodation or supplies purchased at an inflated cost at employer-run stores.

  • The wording ‘or support’ in the indicator means that the UoC:

    • does not use any suppliers, subcontractors or other workers who are in any way involved in a system of forced labour

    • does not engage in forced labour through any other third parties or business relationships.

Evidence of Implementation

  • employee contracts

  • licences or certificates of any recruitment agencies used (see Indicator 3.2.3)

  • evidence that any recruitment agencies used are complying with relevant regulations (see Indicator 3.2.3)

  • records from internal audits.

Auditors Should Confirm

  • general risk factors for forced labour in a country (see useful resources section);

  • NGOs’ or other local organisations’ knowledge of any reports of forced labour in the sector in this region;

  • human resources personnel’s awareness of any issues in the workplace;

  • worker or union representative’s awareness of any issues in the workplace;

  • whether or not any migrant workers are working at the UoC whether local or international, as a heightened risk factor for forced labour;

  • whether or not recruitment agencies are being used, as a heightened risk factor for forced labour;

  • that employees are not threatened with any penalties or retaliation;

  • that employees are not in any form of debt bondage;

  • that employee contracts are clear and up-to-date and employees understand their terms and conditions of employment;

  • consistency with records related to other parts of the ASC Farm Standard that represent risk factors for forced labour, e.g.:

    • recruitment and workplace policies

    • wage and payroll records

    • overtime records

    • employee committee records

    • grievance mechanism records.

Useful Resources