We clarify what you must do if you have reasonable grounds to assume that severe deviations are occurring or have occurred in your own operations or in your supply chain.


Reporting obligation

According to the contract clause, you are obliged to report severe deviations in your own operations and in the supply chains if you have reasonable grounds to assume that such are occurring or have occurred. Forced labour, child labour, working conditions that pose a danger to life, serious environmental harm, grand corruption, and attacks on environmental and human rights defenders are severe deviations.

Excerpt from the contract clause
If Supplier has reasonable grounds to assume that a severe deviation is occurring or has occurred in its own operations or supply chains, Supplier shall within [two (2)] weeks report the actual circumstances and the implemented and planned measures in accordance with sections 2.1 – 2.7, to [contracting organisation].

Severe deviations refer to forced labour, child labour, working conditions that pose a danger to life, serious environmental harm, grand corruption and attacks on environmental and human rights defenders. The severe deviations are defined in annex 1: Supplier Code of Conduct.

What is a severe deviation?

The severe deviations are defined in the Supplier Code of Conduct.​

Excerpt from the code of conduct

Forced labour, child labour, working conditions that pose a danger to life, serious environmental harm, grand corruption and attacks on environmental and human rights defenders are severe deviations.

Serious environmental harm is defined as damage caused by polluting activities that have a severe adverse impact on people, water areas or ground water, species and habitat.

Grand corruption is defined as involvement in bribery, embezzlement, trading in influence, abuse of functions, illicit enrichment, laundering of proceeds of crime, concealment or obstruction of justice:

a) as part of a scheme that involves a high-level public official, and

b) that results in or is intended to result in:

a gross misappropriation of public funds or resources, or

grave or systematic violations of the human rights of a substantial part of the population or of a vulnerable group.

Forced labour and child labour are described in sections 2.2 and 2.3 of the code of conduct.

Excerpt from the code of conduct

2.2 Employment is freely chosen

a) There is no forced labour, bonded labour or involuntary prison labour.

b) Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

Excerpt from the code of conduct

2.3 Child labour shall not be used

a) There shall be no new recruitment of child labour. Child labour is any kind of activity or work which is harmful to the intellectual, physical, social and moral development of persons under 18 and undermines their education, preventing them from going to school, constraining them to abandon schooling too soon or requiring them to work and study at the same time.

b) The employer develops or participates in and contributes to policies and programmes which provide for the transition of any child found to be performing child labour, to enable him or her to attend and remain in education until he or she is no longer a child.

c) A worker under 18 may nonetheless have the right to work if he or she meets the age requirements for the type of work in question:

For general work, the minimum age is 15.

For non-hazardous work, the minimum age may be temporarily set at 14 in countries whose school-leaving age is lower than 15.​

d) Persons under 18 shall not be employed at night or in hazardous conditions.

Working conditions that pose a danger to life and attacks on environmental and human rights defenders are not defined in the Supplier Code of Conduct. Below are circumstances to consider.

Working conditions that pose a danger to life

According to estimates from the World Health Organization and the ILO, 2 million people die annually from work-related causes. Diseases account for 81% of cases and injuries for 19%.

The biggest risk factors are long working hours, followed by exposure to particles, gases and fumes, and occupational accidents. These risk factors leads to lung diseases, stroke, heart disease and cancer, among other things.

When assessing working conditions that pose a danger to life, you therefore need to consider both the risks associated with prolonged exposure to substances that are hazardous to health – such as chemicals, particles, gases and fumes – and the risk of occupational injuries. In both cases, access to protective equipment is fundamental.

Attacks on environmental and human rights defenders

Environmental and human rights defenders are on the front lines of protecting our rights and our planet. They include indigenous peoples, trade union leaders, land and environmental defenders, anti-corruption activists, journalists and others who expose corporate irresponsible business practices and fight for human rights.

The most common form of attack is judicial harassment, such as arbitrary detentions and subpoenas. But defenders are also subject to threats and death threats, assaults, violence, disappearances and murders. In 2023, the Business & Human Rights Resource Centre documented 87 murders of human rights defenders working against corporate abuses.

The Business & Human Rights Resource Centre runs a database with information on attacks on human rights defenders around the world. In it you can, among other things, search for attacks by country.

Business & Human Rights Resource Center – Civic Freedoms & HRD Data

Another source is the Observatory for the Protection of Human Rights Defenders, which is run by the International Federation for Human Rights and the World Organisation Against Torture.

Observatory for the Protection of Human Rights Defenders

What does reasonable grounds to assume mean? ​

Reasonable grounds to assume means that there is good reason to suspect a severe deviation, meaning clear indications that a severe deviation may have occurred. Such information may emerge through audits, civil society organisations and research institutes, or through media.

Below are examples of situations where suppliers, if the current contract clause had been in effect, would have had reasonable grounds to assume that severe deviations were occurring.

Forced labour in Xinjiang linked to Italian tomato products

In 2024, an investigation by the BBC and Australian company Source Certain revealed that several Italian tomato products labelled “Made in Italy” contained tomatoes from Xinjiang, China. The region has been the subject of international criticism for human rights abuses, including the use of forced labour linked to the Muslim Uyghur minority.

The investigation found that Italian company Antonio Petti received over 36 million kilograms of tomato paste from Xinjiang between 2020 and 2023. Despite being labeled as Italian, some of Antonio’s Petti tomato sauces contained tomatoes from China, raising concerns about transparency and ethical sourcing. The Petti brand has expanded significantly and is now present in several European markets, including Germany, France, Norway, Denmark, Sweden and the UK.

Child labour in instrument manufacturing in Pakistan

In 2015, a study by Swedwatch – following up on several years of work on the same topic – noted some improvements in Pakistan’s surgical instruments sector. However, children as young as 10 could still be found working, performing tasks such as grinding, polishing and assembling surgical tools. This was also confirmed by the Ethical Trading Initiative a few years later.

The work involves exposing the children to harmful substances such as chromium and nickel, which leads to serious health risks. Children working in these environments also show significantly higher levels of these metals in their urine compared to children who do not work, which indicates a significant work-related exposure. The surgical instruments are exported globally – including to Sweden.

Working conditions that pose a danger to life at Foxconn

In August 2015, a male worker committed suicide at a Foxconn factory in Zhengzhou, a major supplier to Apple, by jumping from a building. The incident followed reports in 2013 that three workers at the same facility had taken their own lives within a 20-day period. Investigations showed that these tragedies were linked to extremely stressful working conditions, including extreme overtime, harsh production requirements, and a “silent work” policy that discouraged communication between colleagues. These factors contributed to severe mental and emotional stress among employees.

Serious environmental harm caused by the pharmaceutical industry in India

The Patancheru and Bollaram industrial areas, near Hyderabad in India, are important centres for pharmaceutical manufacturing. Since the 1970s, these areas have suffered extensive environmental degradation due to the discharge of untreated or inadequately treated wastewater from a large number of pharmaceutical factories. The pollution has led to severe contamination of local waterways, including the Nakkavagu River, and groundwater, rendering these water sources unfit for consumption and agriculture. Despite decades of legal action, remediation has been inadequate, and the affected communities continue to suffer from health risks and lost livelihoods.

Grand corruption in Malaysia's glove industry

In December 2020, the UK Home Office published a report on Malaysia’s production of disposable gloves. The report concluded that “corruption is endemic in the recruitment systems of Malaysia and migrant worker source countries, and touches every part of the recruitment supply chain.”

This systematic corruption has led to widespread exploitation of migrant workers, including debt bondage and forced labour. As suppliers to the UK NHS and the Swedish Regions often source from the same factories, it is highly likely that these corrupt practices also affect the Swedish supply chains for disposable medical gloves.

Attacks on British human rights defender in Thailand

In 2013, a British human rights activist faced multiple civil and criminal charges in Thailand after contributing to a Finnwatch report that revealed suspected violations of workers’ rights at the Natural Fruit Company factory.

The report documented the prevalence of child labour, underpayment, and dangerous working conditions. The legal action against the activist was widely perceived as an attempt to silence human rights defenders and discourage them from exposing abuses in global supply chains.

What does the reporting obligation cover?​

You shall report the actual circumstances and the implemented and planned measures in accordance with sections 2.1–2.7 of the contract clause, i.e. the process requirements. This means that you shall:

Investigate what constitutes an actual circumstance. This includes paying special attention to particularly vulnerable groups and, if possible, consulting in a meaningful way with affected rights-holders.

Cease activities that cause or contribute to the severe deviation, if it occurs in your own operations or if you contribute to it in your supply chains. 

Establish and follow up action plans to prevent and mitigate the severe deviation, if possible in meaningful consultation with affected rights-holders or their representatives.

Promote purchasing practices that do not make it difficult for the sub-supplier to comply with the commitments, if the severe deviation occurs in the supply chains.

Enable affected rights-holders, their representatives and environmental and human rights defenders to make complaints related to the severe deviation.

Establish and implement remediation plans, if you have caused or contributed to the severe deviation. If you are only linked to the severe deviation you should develop a plan for how you will use your leverage to get the party that caused or contributed to the severe deviation to remedy it.

Guidance for suppliers on fulfilling the contract clause

Introduction to the contract clause

We explain what the contract clause is, why it exists, which international frameworks it is based on, and the extent of your responsibility.

Supplier’s commitments ​​

We describe what is meant by human rights, workers’ rights, the environment, and business ethics.

Supplier’s due diligence

We explain what is included in identifying, assessing preventing, mitigating, and remedying adverse impacts.