The Centre for Child Rights and Business released its white paper Beyond First Tier – The Imperative for International Brands to Engage with Lower Tier Suppliers on Human Rights Due Diligence (March 2026). The study uses the Bangladesh apparel sector to draw broader learnings for supply chains, drawing on supply chain mapping across three multi-tier supply chains, each involving between 6,000 and 10,000 workers.
Human Level’s Take:
- Meaningful human rights due diligence is needed to tackle child labour deep in supply chains, yet it often doesn’t reach past Tier 1. Through the lens of the Bangladesh apparel sector, the Centre for Child Rights and Business identifies a number of reasons for this, which range from operational to structural.
- For example, as contracts grow more informal deeper in the supply chain, traceability and leverage are reduced. In addition, many company child labour policies are not aligned with legal standards, lack child-centred remediation, and are not shared with lower-tier suppliers.
- In parallel, monitoring, visibility and HRDD training are minimal beyond Tier 1, leaving suppliers without guidance on identifying or managing child labour risks. Underpinning all this is significant economic pressure on suppliers, especially in sectors like apparel, which undermines their ability to invest in needed measures to tackle child labour and other human rights risks.
- Together, these factors have created a pattern of low-paid, high-risk work in supply chains with limited opportunities for advancement and career development. This has negative impacts on workers themselves — especially young workers — but can also have cascading effects on their families and households, leading to poverty and higher rates of child labour.
- The Centre for Child Rights and Business outlines key recommendations for buying companies to combat these risks deep in their supply chains. Companies can increase investment in training and capacity-building for lower-tier suppliers, while incentivising their direct suppliers to map their sub-suppliers and take on shared responsibility for due diligence.
- In addition, companies can put in place channels to hear grievances from lower-tier suppliers and join with peers in multistakeholder initiatives to build their leverage in the supply chain.
Some key takeaways:
- Six systemic gaps: The white paper draws on the example of Bangladesh’s apparel sector to highlight a systemic supply chain risk: human rights due diligence (HRDD) weakens beyond first-tier suppliers in supply chains, potentially hiding child labour risks. The paper identifies six systemic gaps that contribute. First, company child labour policies may be misaligned with legal standards and do not include child-centred remediation processes. Less than half of the Tier 1 suppliers studied do not share their policies with their own suppliers and lower-tier suppliers often lack support and guidance to implement effective ones. Second, as contracts become more and more informal further down the supply chain, the risks of child labour go up due to limited traceability and leverage. Third, there is significantly less monitoring, visibility and oversight of supplier practices, especially beyond Tier 1; even at Tier 1, none of the interviewed suppliers had received HRDD training from their buyers. Fourth, companies may be relying too much on “approved” or “nominated” supplier status that is used as a substitute for due diligence. Fifth, there is a lack of workplace support, training and awareness on identifying and addressing child labour risks. As lower tier suppliers operate with constrained resources, they may be more likely to direct efforts towards reducing turnover and keeping up with order volumes. Sixth, the lack of structured training and guidance on child labour can result in suppliers misunderstanding the issue. For example, only 15% of factory mid-level managers and officers have representatives trained in child rights and child labour, and the majority of suppliers are using ineffective measures to verify worker age. Underscoring these gaps is the challenge of our current unstable economic climate, which is putting suppliers and local communities under more pressure than ever and limiting their capacity to tackle the issue.
- The result: systemic risks: The white paper identifies interconnected ways in which these systemic gaps are contributing to child labour risks in supply chains. For one, supply chain workers under time and cost pressures are often working excessive overtime during peak production times. Fifty-seven percent of Tier 2 and Tier 3 factories reported that they rely on overtime as a primary way to cope with demand surges. This in turn can increase risks, both by exposing young workers to harmful work practices and indirectly affecting children at home who lack their parents’ time and capacity for care. In addition, many factories are unable to provide professional development opportunities, like training or career pathways, which leaves workers unable to advance out of low-paying jobs. This can increase poverty at the household level, increasing the risk of school drop-outs and of child labour. The paper cites evidence showing that household poverty, in addition to poor monitoring of child labour, can lead to children entering hazardous or excessive work.
- Recommendations for buyers: The white paper offers several recommendations for buyers to strengthen lower-tier engagement and combat the risks of child labour. First, companies can invest in localised capacity building by providing or funding child labour training for management and workers of lower-tier suppliers. Second, they can incentivise transparency, encouraging direct suppliers to map and disclose their sub-suppliers and creating shared responsibility for due diligence. Third, they can implement channels to receive grievances from workers in lower tiers or join industry initiatives with shared grievance channels. Finally, they can consider joining multistakeholder initiatives designed to share resources and knowledge and build leverage in the supply chain.
