TRW & Co · Supply chains and human rights
Sourcing from Bangladesh: Supply Chain Due Diligence for UK Buyers
Bangladesh supply chain due diligence for UK buyers combines Modern Slavery Act reporting, contractual demands from EU customers under the amended CSDDD, and Bangladesh-specific tools such as the RSC factory safety programme and recent labour law reforms. The legal duty is mostly transparency; the commercial test is whether your evidence and supplier contracts stand up.
Key pointUnauthorised subcontracting is where Bangladeshi supply chain risk most often hides: a factory covered by RSC safety inspections may pass work to a unit that is not, so subcontracting approval and site disclosure clauses matter more than another audit.
At a glance
UK reporting threshold
Commercial organisations carrying on business in the UK with total turnover of £36 million or more must publish an annual modern slavery statement.
Narrowed EU Directive
Omnibus I limits the CSDDD to the largest companies and pushes application to July 2029, but in-scope EU customers will still flow requirements down.
Factory safety programme
The International Accord's Bangladesh Safety Agreement, implemented by the RMG Sustainability Council, covers fire, electrical, structural and boiler safety for signatory brands' factories.
Labour law reformed
Bangladesh's Parliament passed labour amendments in April 2026 easing union registration and prohibiting anti-union and workplace discrimination, as reported.
Contracts carry the duty
Audit rights, subcontracting approval, remediation duties and responsible exit clauses turn a supplier code into enforceable obligations.
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Bangladesh supply chain due diligence: the short answer
Bangladesh supply chain due diligence means identifying, preventing and addressing forced labour, unsafe workplaces and other human rights and environmental harms in the factories, mills and subcontractors that make your goods. For UK buyers it is driven by three things: the Modern Slavery Act 2015, contractual demands from EU customers under the EU Corporate Sustainability Due Diligence Directive, and the commercial reality that customers, lenders and investors now ask for evidence.
Bangladesh is one of the UK's most important sources of ready-made garments, and the country's factory safety system has changed substantially since the Rana Plaza collapse in 2013. A credible programme therefore combines legal reporting duties with practical tools specific to Bangladesh: the International Accord's safety programme, Bangladeshi labour law, worker voice channels and supplier contracts that actually allocate responsibility.
As of October 2026, UK law still relies mainly on transparency rather than a general mandatory due diligence duty. That does not make due diligence optional. It makes the quality of your evidence, and of your contracts, the deciding factor.
The UK legal framework
Modern Slavery Act 2015
Section 54 of the Modern Slavery Act 2015 requires a commercial organisation that carries on business in the UK, supplies goods or services and has a total turnover of £36 million or more to publish an annual slavery and human trafficking statement. The threshold is set by regulations and counts the turnover of subsidiaries, including those operating wholly outside the UK.
The statement must set out the steps taken to ensure slavery and human trafficking are not taking place in the business or its supply chains, or state that no such steps have been taken. The Home Office's statutory guidance encourages reporting on structure, policies, due diligence, risk assessment, effectiveness and training, and encourages publication on the government registry. Our guide to the modern slavery statement covers drafting in detail.
Other UK exposure
Weak due diligence can create risk beyond reporting. Consumer protection law penalises misleading sustainability and ethical claims, and the failure to prevent fraud offence under the Economic Crime and Corporate Transparency Act 2023, in force since September 2025, can catch large organisations whose associated persons commit fraud for their benefit, for example by falsifying audit or origin records. Directors' general duties also require them to consider the impact of operations on the community and the environment.
EU rules that flow down to UK suppliers
The EU Corporate Sustainability Due Diligence Directive, Directive (EU) 2024/1760, was substantially narrowed by the Omnibus I amendments published in the Official Journal in February 2026 as Directive (EU) 2026/470. As amended, it applies to EU companies with more than 5,000 employees and over EUR 1.5 billion of worldwide turnover, and to non-EU companies with over EUR 1.5 billion of turnover generated in the EU. Member States must transpose it by July 2028, and it applies from July 2029.
Few UK importers will be directly in scope. Many more will feel it through their customers. EU retailers and brands covered by the Directive must run risk-based due diligence across their chain of activities, and they will expect UK distributors, agents and private-label suppliers sourcing from Bangladesh to provide information, accept audit rights and support remediation. The amended Directive removed the harmonised EU civil liability regime and the obligation to terminate relationships as a last resort, but national laws, such as Germany's supply chain law, continue to apply. See our guide to the EU CSDDD for UK companies.
Respond to customer questionnaires carefully. Answers given to an EU customer become contractual representations, and inconsistent answers to different customers are easy to spot. Keep one controlled set of information about your Bangladeshi suppliers, approved by someone with authority, and update it as your due diligence progresses.
What the Bangladeshi framework requires
Effective Bangladesh supply chain due diligence starts with local law, because a supplier's compliance gaps are often gaps under Bangladeshi law as well as under buyer codes.
- Bangladesh Labour Act, 2006. The principal statute on wages, working hours, leave, safety, welfare and industrial relations. In April 2026 Parliament passed the Bangladesh Labour (Amendment) Bill, 2026, converting a 2025 ordinance into law. As reported, it allows trade union registration with as few as 20 workers in smaller establishments, prohibits anti-union discrimination such as blacklisting, and introduces express prohibitions on direct and indirect discrimination.
- Factory safety. The International Accord's Bangladesh Safety Agreement is a legally binding agreement between more than 240 brands and the global unions UNI and IndustriALL. It is implemented in Bangladesh by the RMG Sustainability Council (RSC), which runs fire, electrical, structural and boiler inspections, safety training and a worker complaints mechanism.
- Export processing zones. Factories in export processing and economic zones operate under separate labour rules, which can affect union rights and grievance routes, so check where each supplier sits.
Ask every Bangladeshi garment supplier whether its factory is covered by the RSC or the International Accord programme, and request its corrective action plan status. A factory with open safety findings marked "behind schedule" is a clear, documented risk that should appear in your risk assessment.
A practical due diligence process
The steps below reflect the OECD-style, risk-based approach that both UK guidance and the EU Directive expect, adapted for Bangladesh supply chain due diligence.
- Map the chain. List tier 1 factories and, as far as reasonably possible, mills, dye houses, washing plants and subcontractors. In Bangladesh, unauthorised subcontracting is a recurring risk.
- Assess risk. Prioritise by severity and likelihood: building and fire safety, forced overtime, wage arrears, recruitment fees, child labour in informal tiers, and freedom of association.
- Gather evidence. Combine RSC or Accord inspection data, independent social audits, wage and hours records, and worker interviews conducted away from management.
- Contract for it. Embed obligations, audit rights, subcontracting controls and remediation duties in your supply agreements and purchase order terms.
- Remediate. Agree time-bound corrective action plans with suppliers, and consider your own purchasing practices, such as lead times and price, that may cause excessive overtime.
- Provide grievance routes. Make sure workers can raise concerns safely, through the RSC mechanism, union channels or your own confidential line.
- Monitor and report. Track indicators over time and report accurately in your modern slavery statement and to customers, avoiding claims you cannot evidence.
Evidence to keep
Regulators, customers and courts judge Bangladesh supply chain due diligence by the record it leaves. Keep a dated risk assessment for each supplier, copies of inspection and audit reports, corrective action plans and evidence of follow-up, records of grievances and how they were resolved, and the board or committee minutes that show senior oversight. If a problem later surfaces, a file that shows you identified the risk and acted on it is your strongest defence, commercially and legally.
Data protection matters too. Worker interview notes and grievance records contain personal data, so agree with suppliers and auditors how that data is collected, transferred to the UK and stored, and limit it to what you need.
Due diligence tools compared
| Tool | What it shows | Limits |
|---|---|---|
| RSC and International Accord safety inspections | Structural, fire, electrical and boiler safety findings and remediation progress | Focused on safety, not wages, hours or recruitment practices |
| Commercial social audits | A snapshot of labour compliance against a code or standard | Announced audits can be prepared for; quality varies widely |
| Worker voice and grievance data | Issues workers actually raise, including harassment and wage problems | Depends on trust, confidentiality and protection from retaliation |
| Supplier self-assessment questionnaires | Policies, subcontractors, certifications and management systems | Self-reported; must be verified |
| Contract audit and information rights | Access to records, sites and subcontractors on demand | Only as good as your willingness to use them |
Contract clauses that make due diligence work
Most UK buyers source from Bangladesh on purchase order terms or a framework supply agreement. Those documents should carry your due diligence obligations, not just a link to a code of conduct.
- Compliance warranties with Bangladeshi labour law, your supplier code and named international standards.
- Subcontracting controls requiring prior written approval and full disclosure of every production site.
- Audit and information rights covering announced and unannounced visits, worker interviews and access to wage records.
- Remediation duties with timelines, cost-sharing where appropriate, and cooperation with the RSC.
- Responsible exit provisions that allow suspension or termination while considering the impact on workers.
- Shared responsibility for buyer practices, such as reasonable lead times and order changes.
- Governing law and disputes, usually English law with arbitration seated in London, because an award is easier to enforce in Bangladesh than a foreign court judgment.
See our guides on English law in Bangladesh contracts and on how to enforce a London arbitration award in Bangladesh.
Pricing, trade terms and LDC graduation
Due diligence clauses sit alongside commercial terms that are themselves changing. As Bangladesh approaches graduation from least developed country status, tariff preferences in some markets may change, and suppliers may seek to reprice. Build review mechanisms into long-term agreements so that cost pressure is discussed openly rather than absorbed through overtime or unauthorised subcontracting, which would undermine your Bangladesh supply chain due diligence.
Illustrative scenario
This scenario is illustrative only and does not describe a real client. A UK fashion brand with turnover above the Modern Slavery Act threshold sources knitwear from four factories near Dhaka. Its largest customer, a German retailer, sends a supplier questionnaire and new contract terms reflecting German and EU due diligence rules.
The brand discovers that one factory has subcontracted finishing work to a smaller unit that is not covered by the RSC programme. It suspends new orders to the unit, agrees a corrective plan with the tier 1 factory, and adds a subcontracting approval clause to its purchase order terms. It also reviews its own late order changes, which had been driving weekend overtime.
The brand also checks that the questionnaire answers it gives its German customer match what its own records show, and that nobody in the business has certified more than the evidence supports. Where its information on lower-tier mills is incomplete, it says so and explains how it is filling the gap, rather than giving an unqualified assurance it may later have to withdraw.
Its next modern slavery statement describes the finding, the steps taken and the remaining gaps. That candour is more defensible to customers and regulators than a statement claiming no risk was found.
Risks and common mistakes
Relying on audits alone
A clean social audit is a snapshot, often announced in advance. In Bangladesh, the most serious risks often sit in unauthorised subcontractors, informal tiers and wage practices that audits miss. Combine audits with safety inspection data, worker voice and your own site visits, and treat a perfect audit history as a reason for curiosity rather than comfort.
Making claims you cannot prove
Statements that products are "ethically made" or "slavery-free" can be challenged as misleading under UK consumer protection law, and inaccurate customer certifications can create contractual liability. Describe the steps you take and the evidence you hold. A modern slavery statement that discloses findings and remediation is stronger than one with generic assurances.
Ignoring your own purchasing practices
Very short lead times, late changes and prices that do not cover legal wages can push suppliers into excessive overtime or unauthorised subcontracting. Both UK guidance and the EU framework expect buyers to look at their own contribution to harm. Record how you set prices and lead times and how you respond when suppliers raise capacity concerns.
Treating due diligence as a one-off exercise
A supplier onboarding check completed years ago says little about today's factory. Ownership changes, new subcontractors, wage revisions and the 2026 labour law amendments all alter the risk picture. Bangladesh supply chain due diligence should be refreshed at least annually and whenever there is a trigger, such as a fire, a strike, a change of ownership or a sudden capacity increase. Record each review and what changed as a result.
Exiting abruptly when a problem appears
Cutting a supplier immediately may look decisive, but it can leave workers unpaid and remove your leverage to fix the problem. Contract for staged responses: remediation first, suspension of new orders where needed, and termination as a considered step with regard to workers' wages and severance.
Checklist for UK buyers sourcing from Bangladesh
- Confirm whether you meet the Modern Slavery Act £36 million turnover threshold, including subsidiaries.
- Identify customers who are in scope of the EU Directive or national laws such as Germany's, and what they will ask of you.
- Map tier 1 factories and known lower tiers, including any subcontracted processes.
- Check RSC or International Accord coverage and corrective action status for each factory.
- Update supply agreements with audit rights, subcontracting controls and remediation duties.
- Review purchasing practices that may drive overtime or subcontracting.
- Prepare a modern slavery statement that reflects real findings and actions.
- Track trade changes affecting Bangladesh, including LDC graduation and UK trade preferences.
TRW & Co's London office is authorised and regulated by the Solicitors Regulation Authority. With colleagues in Dhaka and Chattogram, our Bangladesh supply chain and business and human rights teams help buyers design Bangladesh supply chain due diligence programmes, update supplier contracts and respond to incidents. To discuss your programme, contact us at info@trw.co or +880 1779 127165, or visit Holborn Gate, 330 High Holborn, London WC1V 7QH.
Frequently asked questions
01Do UK companies have a legal duty to carry out supply chain due diligence?
Not a general one, as of October 2026. The Modern Slavery Act 2015 requires organisations with £36 million or more in turnover that carry on business in the UK to publish an annual statement on the steps they take, or state that they have taken none. In practice, customers, investors, lenders and EU business partners expect real due diligence, and misleading claims can create consumer law and contractual exposure.
02Does the EU CSDDD apply to UK companies sourcing from Bangladesh?
Only the largest. As amended in 2026, the Directive applies to non-EU companies with more than EUR 1.5 billion of turnover generated in the EU, from July 2029. Many more UK businesses will be affected indirectly, because in-scope EU customers must conduct due diligence across their chain of activities and will ask UK suppliers and distributors for information, audit access and contractual commitments.
03What is the RSC in Bangladesh?
The RMG Sustainability Council is the Bangladeshi body that implements the International Accord's Bangladesh Safety Agreement in garment and textile factories. It carries out fire, electrical, structural and boiler safety inspections, monitors remediation, provides safety training and runs a complaints mechanism for workers. Buyers should check whether their suppliers are covered and review the status of each factory's corrective action plan.
04What should a supplier contract with a Bangladeshi factory include?
At a minimum: warranties of compliance with Bangladeshi labour law and your code of conduct, a ban on subcontracting without prior written approval, audit and information rights including worker interviews, remediation obligations with timelines, cooperation with safety programmes, and staged rights to suspend or terminate. English governing law with London arbitration is common, because arbitration awards are generally easier to enforce in Bangladesh than foreign court judgments.
05What changed in Bangladesh labour law in 2026?
In April 2026 Bangladesh's Parliament passed the Bangladesh Labour (Amendment) Bill, 2026, converting a 2025 ordinance into law with changes. As reported, it lowers the minimum number of workers needed to register a trade union in smaller establishments, prohibits blacklisting and other anti-union practices, adds express prohibitions on discrimination, and revises layoff compensation rules. Buyers should update codes, audits and grievance processes accordingly.
Sources and official materials
- Modern Slavery Act 2015, section 54 — Transparency in supply chains duty
- Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 — Sets the £36 million turnover threshold
- Publish an annual modern slavery statement, Home Office — Who must report and what to include
- Directive (EU) 2024/1760 on corporate sustainability due diligence — Original CSDDD text, amended by Directive (EU) 2026/470
- International Accord: Bangladesh — Bangladesh Safety Agreement and RSC implementation
- Failure to prevent fraud offence guidance, Home Office — Guidance on the ECCTA 2023 corporate offence
General information only, current as at 21 October 2026. It is not legal advice and does not create a solicitor–client relationship. It reflects the law of England and Wales unless stated otherwise; Scotland and Northern Ireland have separate legal systems, and the law changes frequently. Check current official sources and take advice on the facts of your matter.