Exposure assessment
Size your exposure
before you size the programme
The evidence customs and regulators now ask for cannot be assembled after goods are held. An exposure assessment tells you where that evidence is needed first, what it would cost not to have it — in revenue held and in remedy owed — and how long it takes to build.
What it is
A fixed-scope assessment of exposure by product, commodity and country, counted on both sides: revenue at risk from detention, product-level bans and tariff differentials, and the remedy that would be owed to workers if forced-labour indicators were found — recruitment fees, wage arrears, retained documents — which is usually the condition of release. Each comes with the time needed to build a defensible evidence file. It leads with exposure and treats revenue reward as upside, because that is the order in which risk, legal and procurement functions decide.
What you get
An exposure map; a detention scenario for your highest-exposure product (time to release, remediation cost, customer impact); a gap analysis against what US Customs and the EU Forced Labour Regulation ask for; and a prioritised build plan sequenced to the dates that bind.
How it works
Four steps, six to eight weeks
01
Map the exposure
- Products, commodities and countries against entity lists, withhold release orders, the US Department of Labor lists and the EU risk database as it develops
- Tariff differentials that already apply by country of origin
- Where the CSDDD, national laws and customer requirements reach your group
02
Price the failure
- Remedy that would be owed to workers if indicators are found — recruitment fees, wage arrears, document return — benchmarked against published cases
- The time that remedy takes, which sets the time to release
- Revenue held, lost or delayed under a detention or a product-level ban
- Customer penalties, insurance and financing consequences
03
Test the evidence file
- Can you trace the highest-exposure product to raw material, with translated sub-tier records and proof of payment, within thirty working days?
- What workers at each tier would say, and whether you could show it
- Whether your own purchasing practices would survive the review customs now asks for
04
Sequence the build
- What must exist before 14 December 2027 and what can wait
- Which suppliers should run their own verified systems first
- Who owns each piece: legal, procurement, risk, sustainability
Chief risk officers, general counsel and chief procurement officers who need a number before they need a programme; chief sustainability officers who need co-sponsors.
Sic utere tuo ut alienum non laedas
Use what is yours so as to harm no other.
Talk to us about sizing your exposure