What is human trafficking and exploitation? 

Human trafficking is the action of recruiting, transporting/transferring, harbouring or receiving, exchanging or transferring control over another person, including children and young people, with a view to that person being exploited.  Exploitaton involves taking advantage of someone, in particular the act of taking unjust advantage of another for one’s own benefit. 

The Human Trafficking and Exploitation (Scotland) Act 2015 sets out the criminal penalties for this behaviour. 

In simple terms, it is when people are exploited for someone else’s gain. This can involve being forced, threatened or deceived into working or providing services, often for little or no pay. 

 

CARES funding 

If you receive CARES funding, you must follow all relevant laws on modern slavery and human trafficking, including: 

 

You are also required to include suitable and proportionate measures within your procurement processes to identify, assess and mitigate the risk of modern slavery and human trafficking within relevant supply chains. This includes seeking information from installers and suppliers about how they identify and manage modern slavery and labour exploitation risks associated with the products and services they provide. This helps improve visibility of supply chains and reduces the likelihood of exploitation. 

 

Where are the risks within the supply chain? 

Solar PV
There are concerns linked to materials such as polysilicon and other critical minerals. There have been credible reports of forced labour, including state-enforced labour in the Xinjiang Uyghur Autonomous Region (XUAR). 

Wind sector
The growing demand for materials like balsa wood, copper and manganese has raised concerns about how and where these are sourced. In some regions, workers may face unsafe conditions and poor labour standards. 

Batteries
Cobalt, which is used in many lithium-ion batteries, is often sourced from the Democratic Republic of the Congo (DRC). Small-scale mining in these areas has been linked to poor working conditions and labour exploitation. 

 

Reducing human trafficking and exploitation risks 

Supply chains are evolving, and there are positive changes happening: 

  • Alternative materials are being developed (for example, polyethylene terephthalate (PET) replacing balsa wood in some wind turbine blades). 
  • Some battery technologies are reducing or removing the need for cobalt. 
  • Cobalt production is becoming more diversified, with increased supply from countries such as Indonesia and Australia. 

Many manufacturers are also improving transparency. They are: 

  • Mapping their supply chains more clearly 
  • Providing better information to installers 
  • Taking steps to avoid high-risk regions, including seeking alternative suppy chains that avoid or provide alternative sources to the XUAR where sufficient mitigation measures cannot be undertaken 

 

How to assess suppliers 

https://www.solarstewardshipinitiative.org/https://windsustainabilityinitiative.org/ 

When choosing a supplier, you may wish to ask how they manage and reduce human trafficking and exploitation risks in their supply chain for the products that they have quoted to supply.  

Where a real or credible risk of human trafficking and exploitation is identified within a product or supply chain, applicants should seek alternative products or suppliers unless appropriate mitigation measures can be demonstrated and evidenced by the supplier. 

You may want to look for responses that include: 

  • Transparent information on where materials come from 
  • Evidence they avoid products and supply chains where there is a creible risk of production occuring in the XUAR region 

 

Further information 

 

Supply chain risks: 

  • Scottish Government Slavery and human trafficking guidance for businesses (2018) Slavery and human trafficking: guidance for businesses – gov.scot 
  • Home Office, Transparency in Supply Chains (TISC) Statutory Guidance (2025) Transparency in supply chains 

Procurement guidance: 

  • Action Sustainability (2024), Addressing Modern Slavery and Labour Exploitation in Solar PV Supply Chains Procurement Guidance