TRW & Co · UK–Bangladesh Corridor
Bangladesh Sourcing and Supply Chain Compliance
Bangladesh garment supply chain due diligence lets UK brands and importers find and fix labour, safety, bribery and fraud risks in their sourcing, and prove it. Modern slavery reporting, the failure to prevent fraud offence in force since September 2025, Bangladeshi labour reforms, LDC graduation and new EU rules all raise the stakes in 2026.
Key pointEnglish courts have allowed claims by overseas workers against UK companies to proceed in London, so the buyer's own purchasing practices and records, not just supplier audits, now shape legal exposure.
At a glance
£36m reporting threshold
Commercial organisations in the UK with total turnover of at least £36 million, including subsidiaries, must publish an annual modern slavery statement.
Fraud offence now live
The failure to prevent fraud offence under the Economic Crime and Corporate Transparency Act 2023 took effect for large organisations on 1 September 2025.
London as the forum
In Limbu v Dyson the Court of Appeal held England was the proper forum for forced labour claims by workers at an overseas supplier.
LDC graduation in 2026
Bangladesh is scheduled to leave least developed country status on 24 November 2026, with a three-year UK transition before Enhanced Preferences apply.
EU ban from 2027
The EU Forced Labour Regulation applies from 14 December 2027, banning products made with forced labour from the EU market and EU exports.
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What Bangladesh garment supply chain due diligence covers
Bangladesh is one of the world's largest exporters of ready-made garments, and UK retailers, brands and importers rely heavily on its factories. Bangladesh garment supply chain due diligence is the legal and practical process of identifying, preventing and responding to labour, safety, environmental, bribery and fraud risks in that sourcing, and of being able to prove it to regulators, investors, customers and courts.
It is no longer a reputational exercise alone. UK law requires larger organisations to report on modern slavery, makes companies criminally liable for failing to prevent bribery and, since September 2025, fraud by associated persons, and English courts have shown willingness to hear claims by overseas workers against UK companies. EU rules now reach UK exporters selling into Europe.
The businesses we advise include UK fashion and homeware brands, wholesalers and importers, private label suppliers to supermarkets, buying agents, investors in Bangladeshi manufacturers, and Bangladeshi exporters who need to meet UK buyers' compliance demands. The questions differ but the core is the same: what is happening in the factories, what does the contract require, and what will a regulator or judge expect you to have done?
TRW & Co is headquartered in Dhaka with a London office authorised and regulated by the Solicitors Regulation Authority, so we can advise on the UK obligations and the Bangladeshi factory-level reality together. Our business and human rights and ESG and sustainability teams cover the wider framework.
The UK legal framework
Modern Slavery Act 2015
Under section 54 of the Modern Slavery Act 2015, a commercial organisation that supplies goods or services and carries on business in the UK must publish a slavery and human trafficking statement for each financial year if its total turnover is at least £36 million. The threshold is set by the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015, and turnover includes that of subsidiary undertakings.
The statement must describe the steps taken to ensure slavery and trafficking are not occurring in the supply chain or the business, or state that no steps were taken. The Act suggests covering structure, policies, due diligence, risk assessment, effectiveness and training. The government guidance explains publication on the modern slavery statement registry. Section 54 does not itself impose penalties for poor content, but a misleading statement creates litigation and consumer protection exposure.
Failure to prevent bribery and fraud
Section 7 of the Bribery Act 2010 makes a commercial organisation guilty of an offence if an associated person, such as an agent, buying house or subsidiary, bribes another person to obtain or retain business for it, subject to a defence of adequate procedures. Facilitation payments to customs, inspection or utility officials are within its reach.
Section 199 of the Economic Crime and Corporate Transparency Act 2023 created the offence of failure to prevent fraud, which came into effect on 1 September 2025 according to the Home Office guidance. It applies to large organisations where an associated person commits a specified fraud offence intending to benefit the organisation, unless reasonable prevention procedures were in place. False sustainability certificates, misdescribed origin and falsified audit reports in a garment supply chain are obvious risk areas.
Civil liability in the English courts
Two Court of Appeal decisions matter for Bangladesh sourcing. In Begum v Maran (UK) Ltd [2021] EWCA Civ 326, a claim by the widow of a worker killed while breaking up a ship in Chattogram was allowed to proceed against the UK company that had arranged the sale of the vessel. In Limbu v Dyson [2024] EWCA Civ 1564, the court held that England was the appropriate forum for forced labour claims by migrant workers at a Malaysian supplier against UK-domiciled companies. Neither case decided liability, but together they show that overseas supply chain claims can be litigated in London.
Consumer and marketing law
Claims that products are ethically made, sustainably sourced or produced in audited factories are subject to consumer protection law, including the unfair commercial practices provisions of the Digital Markets, Competition and Consumers Act 2024, which the CMA can now enforce directly. Bangladesh garment supply chain due diligence must therefore feed into marketing sign-off, not sit in a separate compliance file.
| Rule | Who it catches | What it requires | Consequence of failure |
|---|---|---|---|
| Modern Slavery Act 2015, s54 | Commercial organisations in the UK with turnover of at least £36 million | Annual slavery and human trafficking statement, approved and signed at board level | Injunction to comply; reputational and contractual exposure from inaccurate statements |
| Bribery Act 2010, s7 | Commercial organisations with a UK business connection | Adequate procedures to prevent bribery by associated persons | Criminal offence for the organisation; unlimited fine |
| ECCTA 2023, s199 | Large organisations, including subsidiaries | Reasonable procedures to prevent fraud by associated persons | Criminal offence; in force from 1 September 2025 |
| English tort law | UK companies with control or assumed responsibility over supplier conditions | No statutory duty; liability depends on the facts and the company's own conduct | Damages claims, often as group litigation |
| EU Forced Labour Regulation | Operators placing products on, or exporting from, the EU market | No products made with forced labour; cooperation with investigations | Withdrawal and disposal of products; applies from 14 December 2027 |
The Bangladeshi framework: labour law, safety and trade status
Factory conditions are governed principally by the Bangladesh Labour Act 2006 and its rules, with a separate labour regime for export processing zones. The law has been in significant flux. A labour ordinance issued in 2025 was followed by the Bangladesh Labour (Amendment) Bill 2026, passed by parliament in April 2026, which reportedly lowers the minimum number of workers needed to apply for trade union registration to 20, strengthens protection against anti-union discrimination and adds express prohibitions on workplace discrimination. Buyers should check the final enacted text and implementing rules before relying on any specific provision.
Building, fire and electrical safety remain central after the 2013 Rana Plaza collapse. The International Accord for Health and Safety in the Textile and Garment Industry is a legally binding agreement between brands and the global unions UNI and IndustriALL. In Bangladesh its programme is implemented by the RMG Sustainability Council, which inspects factories and runs a worker complaints mechanism. A brand that is a signatory has contractual obligations that interact with its own supplier contracts.
Trade status is changing too. Bangladesh is scheduled to graduate from least developed country status on 24 November 2026. Under the UK's Developing Countries Trading Scheme, the British High Commission has indicated that existing access will continue for a three-year transition, after which Bangladesh moves to the Enhanced Preferences tier. Rules of origin determine whether garments qualify, so origin documentation is part of due diligence. Our article on LDC graduation and UK trade preferences explains the detail.
Designing a Bangladesh garment supply chain due diligence programme
There is no single compliant template. Regulators and courts look at whether the programme is proportionate to the risks and whether it actually operates. The key design choices are these.
Mapping depth
Most brands know their Tier 1 cut-make-trim factories. Fewer know who supplies fabric, yarn, dyeing, washing and trims, or which factories receive subcontracted work at peak times. Unauthorised subcontracting is a recurring source of serious abuses. Mapping should extend at least to the processes where risk concentrates.
Audits and worker voice
Social audits are useful but limited: announced audits can be prepared for, and auditors may not interview workers safely. Combining audits with grievance mechanisms, union engagement and data on wages and hours gives a more reliable picture.
Purchasing practices
Short lead times, late order changes and prices that do not cover legal wages create the conditions for excessive overtime and unauthorised subcontracting. Courts and regulators increasingly look at the buyer's own conduct, so buying teams must be part of the programme.
Environmental and wet-processing risk
Dyeing, washing and finishing units carry environmental risks, including wastewater discharge and chemical handling, that also affect workers and neighbouring communities. Brands making product-level environmental claims need evidence from these units, not only from the sewing factory. Good Bangladesh garment supply chain due diligence therefore asks for effluent treatment records, chemical inventories and relevant Bangladeshi environmental clearances, and treats gaps as risk indicators rather than paperwork issues.
Agents and buying houses
Many UK buyers source through agents or buying houses in Dhaka. They are often the people who place orders, approve subcontractors and handle inspections, so they are likely to be associated persons for bribery and fraud purposes. Their contracts, remuneration and controls deserve the same scrutiny as the factories themselves.
Contract terms
Supplier agreements should contain enforceable compliance obligations, audit and information rights, subcontracting controls, remediation duties and proportionate exit rights, governed by a law and dispute forum that actually work. Our commercial contracts team drafts these terms, and our page on London arbitration for Bangladesh contracts explains why many buyers choose arbitration.
A supplier code that the buying team's own prices make impossible to follow is not due diligence. It is evidence of what the buyer knew.
Building the programme: a practical sequence
- Assess exposure. Identify which UK and EU rules apply to the group, including turnover tests, EU sales and any Accord commitments.
- Map the supply chain. List factories, subcontractors and material suppliers in Bangladesh, with ownership, location, worker numbers and certifications.
- Prioritise risk. Rank suppliers by severity and likelihood of harm, focusing on safety, forced labour indicators, child labour, wages, freedom of association and environmental discharges.
- Update contracts. Amend supplier and agency agreements to include compliance, transparency, subcontracting, audit and remediation clauses with workable dispute resolution.
- Verify on the ground. Combine audits, Accord or RSC inspection data, grievance reports and local legal advice to test what suppliers say.
- Remediate before exiting. Agree corrective action plans and support them; responsible disengagement should be a last resort and planned to protect workers.
- Report accurately. Prepare the modern slavery statement, sustainability disclosures and marketing claims from the same evidence base, and have the board approve them.
- Review annually. Track legal changes in both countries and the EU, and test whether fraud and bribery prevention procedures remain reasonable.
Documents and evidence to hold
If a regulator, NGO, journalist or claimant asks what you did, the answer will be in your records. Effective Bangladesh garment supply chain due diligence produces a documented trail, including:
- A current supplier and subcontractor map, with dates of verification.
- Risk assessments and the reasons for prioritisation decisions.
- Signed supplier agreements, codes of conduct and subcontracting approvals.
- Audit reports, Accord or RSC inspection records and corrective action plans with evidence of closure.
- Grievance logs and how complaints were investigated and resolved.
- Training records for buyers, sourcing agents and compliance staff.
- Board minutes approving the modern slavery statement and fraud and bribery prevention procedures.
- Origin documentation supporting any preferential tariff claim.
Write audit findings and internal assessments on the assumption that they may be disclosed in litigation. Where a serious allegation arises, involve lawyers early so that investigation reports can be structured to maximise legal professional privilege where it is available.
Risks and common mistakes
Relying on certificates without verification
Certificates and audit summaries are only as reliable as the process behind them. Forged or recycled certificates, audits of a showcase factory while production runs elsewhere, and auditors paid by the supplier all undermine the picture. Under the failure to prevent fraud offence, a UK organisation that benefits from falsified compliance documents produced by an associated person may face liability unless its prevention procedures were reasonable. Verify certificates with the issuing body, cross-check audit dates against production records, and use unannounced visits where the risk justifies them.
Ignoring unauthorised subcontracting
When orders spike, Tier 1 factories may push work to smaller units that have never been inspected. Those units are where the worst safety and labour abuses tend to occur. Contracts should require prior written approval for subcontracting, with the right to inspect approved subcontractors and to terminate for breach. Buying teams should also check whether order volumes and lead times are realistic for the approved factory's capacity, because an impossible order is a strong predictor of hidden subcontracting.
A modern slavery statement that overstates reality
Statements are public documents signed at board level. Claims that a supply chain is fully mapped, slavery-free or regularly audited can be used against the company if workers, NGOs or customers later show otherwise. They may also support consumer protection complaints if repeated in marketing. Describe what has actually been done, acknowledge known risks and gaps, and explain how they are being addressed. A candid statement that improves year on year is far safer than an aspirational one.
Cutting and running when a problem is found
Terminating a supplier immediately after finding abuse can feel like the safe response, but it often harms the workers concerned and leaves the underlying issue unresolved. International standards expect buyers to use their leverage to remediate first, and courts may examine whether the buyer's own conduct contributed. Plan responsible exit procedures in advance, including notice, payment of outstanding orders and wages, and communication with unions, so that disengagement is defensible if it becomes necessary.
Contract clauses that cannot be enforced
A compliance clause is only useful if you can enforce it against a Bangladeshi supplier. English court judgments are not automatically enforceable in Bangladesh, whereas Bangladesh is a party to the New York Convention on arbitral awards. Choose a governing law and dispute forum with enforcement in mind, include clear audit and information rights, and make sure remedies such as price reductions, remediation costs and termination are spelled out. Our UK–Bangladesh trade and finance team advises on the commercial terms.
The EU, other markets and the Bangladeshi supplier's perspective
Many UK brands also sell into the EU, which brings additional regimes. The EU Forced Labour Regulation will apply from 14 December 2027 and prohibits placing products made with forced labour on the EU market or exporting them from it, with no exemption for smaller operators. The EU Corporate Sustainability Due Diligence Directive is being scaled back and delayed through the EU's simplification package, so in-scope UK groups should track the final thresholds and dates. Our article on EU supply chain due diligence rules tracks the position.
From the supplier side, Bangladeshi manufacturers face overlapping demands from UK, EU, US and other buyers, each with its own code. Exporters that build one robust compliance system, with good records, functioning grievance channels and lawful union relations, are better placed to win and keep business. Where buyer and supplier fall into dispute over cancellations, chargebacks or compliance-related termination, our UK–Bangladesh disputes team can act for either side, subject to conflicts.
How TRW & Co helps
Regulatory mapping
We identify which UK and EU obligations apply to the group and to particular product lines, and set out what each requires in practice for Bangladesh garment supply chain due diligence.
Supplier contracts
We draft and renegotiate supplier, agency and buying house agreements with enforceable compliance, subcontracting, audit, remediation and dispute resolution clauses.
Bangladeshi law advice
Through our Dhaka office we advise on the Labour Act, recent amendments, factory regulation and local enforcement, so UK policies reflect what Bangladeshi law requires.
Statements and disclosures
We review modern slavery statements, sustainability reports and marketing claims against the underlying evidence to reduce legal exposure.
Investigations
When allegations surface we plan and run privileged investigations across both countries and advise on remediation, regulators and communications.
Fraud and bribery procedures
We assess and update prevention procedures for the failure to prevent fraud and bribery offences, focusing on agents, inspectors and certification. See our anti-bribery and corruption page.
Checklist for boards and sourcing leaders
- Confirm whether the group meets the £36 million modern slavery turnover test and which EU rules apply.
- Map Bangladeshi suppliers beyond Tier 1, including subcontractors and wet processing.
- Align purchasing practices with the standards in the supplier code.
- Update contracts with enforceable compliance, audit and subcontracting terms and an enforceable forum.
- Review fraud and bribery prevention procedures for agents, auditors and certification bodies.
- Track Bangladeshi labour law amendments and LDC graduation effects on origin and tariffs.
- Make sure every public statement is supported by evidence.
- Plan remediation and responsible exit before a crisis forces the decision.
Read our practical guide to sourcing from Bangladesh and our note on modern slavery statements. To review your Bangladesh garment supply chain due diligence, contact our London office or explore our practice areas.
Frequently asked questions
01Does my company have to publish a modern slavery statement?
If your organisation supplies goods or services, carries on business in the UK and has total turnover of at least £36 million, including the turnover of subsidiary undertakings, section 54 of the Modern Slavery Act 2015 requires an annual slavery and human trafficking statement. It must be approved by the board and signed by a director or equivalent, and published on your website with a prominent homepage link. Smaller companies are not required to publish but are often asked for equivalent information by larger customers, so many prepare one voluntarily.
02Can workers in Bangladesh sue a UK brand in the English courts?
Potentially, yes. English courts have jurisdiction over companies domiciled in England, and the Court of Appeal in Limbu v Dyson held that England was the appropriate forum for forced labour claims by workers at a Malaysian supplier. Begum v Maran allowed a claim concerning a shipbreaking death in Chattogram to proceed against a UK company. Whether a brand is actually liable depends on its own involvement and control, so contracts, purchasing practices and how the brand exercised oversight become central evidence.
03How does the failure to prevent fraud offence affect sourcing?
Since 1 September 2025, a large organisation commits an offence if an associated person, such as an employee, agent or subsidiary, commits a specified fraud intending to benefit it, unless it had reasonable fraud prevention procedures. In sourcing, the risks include falsified compliance certificates, misdescribed country of origin to obtain tariff preferences, and false sustainability claims to customers. Procedures should cover how certificates are verified, how agents are overseen and how marketing claims are approved.
04What has changed in Bangladeshi labour law?
Bangladesh's labour framework has been reformed in stages. A 2025 labour ordinance was followed by an amendment bill passed by parliament in April 2026, which, according to reports, lowers the minimum number of workers needed to apply for union registration to 20, strengthens protection against anti-union discrimination and adds express non-discrimination provisions. Implementing rules and practice are still developing. Brands should check the enacted text with local counsel and update supplier codes and audit protocols, particularly on freedom of association.
05What does LDC graduation mean for garments imported into the UK?
Bangladesh is scheduled to graduate from least developed country status on 24 November 2026. Under the UK's Developing Countries Trading Scheme, the British High Commission has indicated that current access continues for a three-year transition, after which Bangladesh moves to the Enhanced Preferences tier. Garments must still satisfy the scheme's rules of origin to qualify, so importers should check origin evidence, especially where fabric is sourced from third countries, and plan pricing for the post-transition position.
06Is joining the International Accord a legal obligation?
No. The International Accord is a voluntary but legally binding agreement between signatory brands and the global unions UNI and IndustriALL. Once a brand signs, it takes on contractual commitments, including supporting safety inspections and remediation at covered factories, with disputes resolved under the agreement's own procedures. In Bangladesh, the programme is implemented by the RMG Sustainability Council. Signatories should make sure their supplier contracts and purchasing practices are consistent with those commitments.
07Should supplier contracts with Bangladeshi factories use English courts or arbitration?
Often arbitration. English court judgments are not automatically enforceable in Bangladesh, whereas Bangladesh is a party to the New York Convention and its Arbitration Act 2001 provides for enforcing foreign arbitral awards. A London-seated arbitration clause, with clear compliance, audit and remediation obligations, gives the buyer a more reliable route to enforcement against a supplier's assets in Bangladesh. The right choice depends on where the supplier's assets are and what remedies you need.
Sources and official materials
- Modern Slavery Act 2015, section 54 — Transparency in supply chains statements
- Publish an annual modern slavery statement — Government guidance and statement registry
- Offence of failure to prevent fraud introduced by ECCTA — Home Office guidance on reasonable procedures
- Begum v Maran (UK) Ltd [2021] EWCA Civ 326 — Duty of care claim over shipbreaking in Chattogram
- Limbu v Dyson [2024] EWCA Civ 1564 — England as forum for overseas supply chain claims
- Developing Countries Trading Scheme — UK trade preferences and rules of origin
- International Accord for Health and Safety — Binding brand–union safety agreement and Bangladesh programme
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.