Beyond First Tier – The Imperative for International Brands to Engage with Lower Tier Suppliers on Human Rights Due Diligence

“Beyond First Tier – The Imperative for International Brands to Engage with Lower Tier Suppliers on Human Rights Due Diligence” is a new white paper by The Centre for Child Rights and Business that identifies a common yet critical systemic risk in many manufacturing supply chains: the erosion of human rights due diligence (HRDD) beyond first-tier suppliers, which amplifies and conceals child labour risks in high-risk sourcing countries. Focusing on the Bangladesh Ready-Made Garment (RMG) sector, we show that despite a decade of reform driven by international standards and buyer pressure, child labour risks persist in lower-tier suppliers due to a structural lack of visibility, accountability and industry support.

This study draws on extensive supply chain mapping across three multi-tier supply chains (each involving 6,000-10,000 workers) conducted by The Centre for Child Rights and Business (The Centre). The findings demonstrate that while HRDD frameworks are formally embedded at Tier 1, they quickly degrade into paper-based compliance and transactional practices further down the supply chain. As a result, child labour protections become fragmented and ineffective, contributing to a “decent work deficit” for young workers and reinforcing their entrapment in low-skilled, low-paid, and often hazardous jobs.

This breakdown is driven by the erosion of responsible sourcing fundamentals in lower tiers, characterised by six systemic gaps:

1. Child labour policies that are misaligned with legal standards and lack child-centred remediation processes

2. The progressive informality of contractual agreements, especially in Tier 2 and Tier 3

3. A sharp decline in monitoring, visibility and HRDD-based oversight beyond Tier 1

4. An over-reliance on “approved” or “nominated” supplier status as a substitute for ongoing due diligence

5. A critical lack of workplace support, training and awareness that prevents workers and managers from identifying and preventing risks

6. The absence of structured training on child rights and legal standards leads to a fundamental misunderstanding of child labour

These gaps are compounded by a volatile economic climate, where cost pressures cascade downwards to the most vulnerable stakeholders. The research confirms that top-down compliance is insufficient: without equipping lower-tier suppliers and communities with practical knowledge, resources and incentives, the capacity to identify, prevent and remediate child labour remains severely constrained.

This paper argues that the path to ethical resilience and securing future global market access (such as EU GSP+) requires combining top-down accountability with bottom-up engagement. This means brands and local exporters must move beyond passive compliance to actively invest in lower-tier capacity building, support collaborative initiatives like the Child Rights Action Hub, and embed lower-tier visibility into core due diligence. By taking these steps, the sector can transform systemic vulnerability into sustainable leadership – an outcome that is both an ethical imperative and a strategic necessity for its future.

Download the white paper