3. Supplier’s reporting obligation

Working conditions that pose a danger to life are not defined in the Supplier Code of Conduct. In your assessment, you need to consider both the risk of workplace accidents and long-term exposure to hazardous working environments.

According to the WHO and the ILO, around 1.9 million people die each year as a result of work-related diseases and accidents. The majority of these deaths are caused by work-related diseases, including those resulting from long working hours and exposure to particles, gases, and fumes.

The assessment should therefore include, for example:

• exposure to chemicals, particles, gases, and fumes,
• hazardous machinery and work tasks,
• risks of falls, fires, and explosions,
• long working hours and insufficient recovery time,
• access to protective equipment and safety procedures.

Environmental and human rights defenders are individuals or groups working to protect human rights or the environment. This may include, for example, Indigenous peoples, trade union representatives, journalists, land and environmental defenders, or anti-corruption activists.

Defenders may be exposed to:

• threats and death threats,
• violence and harassment,
• arbitrary detention,
• judicial harassment and so-called SLAPP lawsuits,
• disappearances and killings.

Business & Human Rights Centre documented 790 attacks against human rights defenders linked to business-related impacts during 2025, including 53 killings.

When conducting risk assessments, you should therefore pay particular attention to:

• operations in conflict-affected or high-risk areas,
• impacts on Indigenous peoples and local communities,
• land rights and natural resources,
• conflicts linked to mining, agriculture, energy, or infrastructure projects,
• risks of reprisals against individuals raising complaints or criticism.

You may, among other sources, use:

Civic Freedoms & HRD Data – Business and Human Rights Centre

The Observatory For the Protection of Human Rights Defenders

In 2024, an investigation by the BBC and Source Certain found that Italian tomato products labelled “Made in Italy” contained tomatoes originating from Xinjiang in China. The region has for a long time been subject to international criticism related to the forced labour of Uyghurs and other Muslim minorities.

The investigation also identified specific companies and supply chains. Suppliers purchasing such products could therefore be considered to have had reasonable grounds to assume that there was a risk of forced labour in the supply chain.

In 2015, Swedwatch reported that children were still working in the manufacturing of surgical instruments in Pakistan, despite several years of monitoring of the sector. Children carried out tasks such as grinding, polishing, and assembling surgical instruments, and were exposed to harmful substances and hazardous work processes.

Similar findings were later also reported by the Ethical Trading Initiative. Since the instruments were exported internationally, including to Sweden, suppliers could therefore be considered to have had reasonable grounds to assume that child labour was occurring in the supply chain.

In 2015, a worker died by suicide at Foxconn’s factory in Zhengzhou, China. The incident followed earlier reports of multiple suicides at the same facility and extensive criticism of the working conditions.

Investigations linked the incidents to excessive overtime, intense production pressures, and severe psychological strain. In light of the extensive international reporting, suppliers could therefore be considered to have had reasonable grounds to assume that working conditions posing a danger to life were occurring.

Since the 1970s, the pharmaceutical industry in Patancheru and Bollaram near Hyderabad, India, has been linked to extensive discharges of untreated or inadequately treated wastewater.

The pollution has caused serious impacts on local waterways, groundwater, and people’s livelihoods. Despite legal action and long-standing international attention, the problems have persisted for several decades.

Suppliers connected to pharmaceutical production in the area could therefore be considered to have reasonable grounds to assume that serious environmental harm is occurring.

In 2020, the UK Home Office published a report on Malaysia’s disposable glove manufacturing industry. The report described widespread corruption in the recruitment systems for migrant workers and linked this to debt bondage and forced labour.

As factories in Malaysia supply medical gloves to international markets, including Europe, suppliers could therefore be considered to have had reasonable grounds to assume that large-scale corruption was occurring in the supply chain.

In 2013, a British human rights defender was subjected to several civil and criminal proceedings in Thailand after contributing to a report by Finnwatch on alleged violations of workers’ rights at Natural Fruit Company.

The report described, among other things, child labour, underpayment, and hazardous working conditions. The legal actions against the human rights defender received international attention as an example of reprisals against individuals exposing abuses in global supply chains.

Suppliers connected to the sector could therefore be considered to have had reasonable grounds to assume that attacks against human rights defenders were occurring.