Labour Risk Assessment for Woolworths Group
Context
“In F26, we partnered with external human rights experts, Humantics, to conduct a broader FLRA to identify where risks and potential control gaps are visible today”
Woolworths Group engaged Humantics to conduct an independent labour risk assessment across its trade and non-trade supply chains. Woolworths Group operates a complex supply chain comprising more than 14,500 direct suppliers across at least 48 countries, as well as tens of thousands of indirect suppliers at lower tiers.
This was Woolworths Group’s third assessment and came at a point when its responsible sourcing programme was evolving. The business wanted to confirm whether its existing responsible sourcing priorities remained focused on the most significant risks, while providing a clearer view of potential blind spots and emerging areas of vulnerability.
Challenge
Woolworths Group already held extensive supply chain, audit, grievance and responsible sourcing data. The challenge was to find a new way to connect and interpret this evidence, using it not only to understand known risks but also to identify potential blind spots.
Rather than a static ranking of high-risk countries and sectors based on public data, Woolworths Group needed a more tailored and dynamic picture of where risks in their supply chain might be emerging, overlooked or insufficiently understood. This meant examining where datasets aligned, where they revealed unexpected patterns, and where the data pointed toward potential blindspots.
Woolworths Group needed an assessment that would:
reflect the scale and specific characteristics of its supply chain
test whether existing priorities remained appropriately targeted
examine where audit findings might not reflect inherent forced labour risk
identify emerging risks across trade and non-trade activities
support practical decisions about where additional due diligence should be directed
Solution
“Humantics developed an interactive forced labour risk model that enables risk to be analysed across countries, product categories, audit schemes and forced labour indicators continually.”
Humantics developed a bespoke methodology combining inherent risk data with Woolworths Group’s own supply chain, audit, and grievance data. This enabled risk to be assessed against the realities of Woolworths Group’s sourcing footprint, rather than relying solely on global country, sector or product-level indicators from external sources.
We examined where inherent risk aligned with the issues being identified through existing systems, and where the data might point to blind spots or areas requiring further investigation.
Humantics translated this methodology into a dynamic risk assessment model that enables risk to be analysed across countries, product categories, audit schemes and labour indicators continually. This provides greater insight into where risk is emerging, where assurance mechanisms may have limitations and where additional validation or due diligence activities should be prioritised.
Alongside the tool, we developed:
an emerging social and labour risk outlook, identifying developments that could reshape the company’s risk exposure over time; and
a prioritisation framework and practical recommendations, helping Woolworths Group determine where to focus its programme and strengthen due diligence.
Together, these outputs moved the assessment beyond a static snapshot. They gave Woolworths Group an ongoing capability to monitor changes in its risk profile, identify potential blind spots, anticipate emerging risks and direct resources towards the areas requiring the greatest attention.
Read more in Woolworths Group’s 2026 Modern Slavery Statement on pages 8–9. Humantics is recognised by Woolworths Group as an external advisory partner supporting its programme through strategic input and specialist risk analysis on pages 14, 33, 40 and 44.