Fashion supply chains have transformed dramatically over the last two decades. Production has accelerated, order volumes have shrunk, and global manufacturing has shifted toward networks of small, highly flexible factories. This evolution isn’t limited to fast-fashion giants or any single region—it’s visible on the UK high street, across Europe, and even within Italian luxury supply chains. And it has outpaced traditional oversight models.
On February 9, WRAP hosted a panel discussion, “Due Diligence for Fast Fashion & Forced Labor Risks in Migrant Supply Chains” as part of a side session at the 2026 OECD Forum in Paris. Along with WRAP President and CEO Avedis Seferian and Regional Director of Europe and Africa Gerwin Leppink, the panel featured leaders from SHEIN, Medline, and social compliance auditing firm ALGI, who explored how wage assessments, worker voice, and independent verification can strengthen due diligence in complex manufacturing networks. The conversation spotlighted the on-demand model used by SHEIN, the auditing perspective of ALGI, and key themes around migrant labor risk and verification from WRAP and Medline.
Below are the major takeaways.
The Reality of On‑Demand Supply Chains
SHEIN operates at the most extreme end of the small‑batch, technology‑coordinated model that now shapes much of the global apparel industry. With more than 7,000 small and medium-sized suppliers across China, Türkiye, Brazil, and other markets, its system prioritizes responsiveness. Each style begins with a tiny production run—often just 100–200 pieces—followed by real-time restocking only when demand is proven.
The model lowers waste, reduces unsold inventory, and allows rapid trend responsiveness. But it also demands tight supplier management.
SHEIN described three pillars that support this:
- Fast, reliable payments to stabilize supplier cash flow.
- Cost stability through pre-negotiated fabric pricing and shared digital resources.
- Capability building, including access to over 170 performance-improving tools and extensive supplier training.
Despite the scale, the system is not remote. SHEIN conducts more than 4,000 on-site audits annually—covering 95% of procurement value—and maintains regular in-person engagement with nearly 2,000 suppliers.
Why Wage Assessments Go Further Than Traditional Audits
While SHEIN’s audit program is extensive, the company acknowledged that audits alone cannot paint a complete picture of working conditions. That gap led to its collaboration with WRAP on a detailed wage assessment and worker survey initiative.
According to ALGI, this approach adds something essential: worker voice at scale.
Traditional audits rely heavily on documentation—payroll, attendance, and structured interviews. Wage assessments, however, combine these records with anonymous surveys completed independently by workers. In this project, over 80% of workers participated, with some factories reaching full participation.
The result is more candid responses and a more complete view of wage sufficiency, overtime practices, and lived experience—not just compliance metrics.
Key Findings: Strengths and Areas for Improvement
Across participating factories, baseline compliance was strong:
- 99%+ compliance with minimum wage requirements
- 97% compliance with overtime premium regulations
- Most workers meeting hourly living wage benchmarks
But the worker survey added nuance. About 30% of workers still felt wages were insufficient for their cost of living despite meeting legal thresholds. This highlights the difference between compliance on paper and workers’ perceptions of adequacy—an insight only possible through direct worker feedback.
Preferences around hours were mixed too, reflecting diverse worker needs across a fragmented supply base.
ALGI noted clear improvements across the five rounds of wage assessments. Early on, many facilities struggled with incomplete or inconsistent records. Over time, these were replaced with well-structured payroll and attendance systems. Management became better able to explain wage calculations, and the focus shifted from data cleanup to worker engagement.
Practical, achievable assessment tools create buy-in—and ultimately, lasting improvement.
Migrant Labor: Where Vulnerabilities Are Highest
The panel then shifted to a related but distinct topic: forced labor risks in migrant‑dependent supply chains. WRAP emphasized that migrant workers often face the highest vulnerability—recruitment fees, debt bondage, document retention, and restricted mobility remain persistent risks across many markets.
Regulatory frameworks are tightening quickly:
- In the Hoa Kỳ, forced labor enforcement is already shaping import decisions.
- In the European Union, a forthcoming regulation will prohibit products made with forced labor from entering the market.
- Public procurement—especially in healthcare—is increasingly requiring proof of due diligence.
How Medline Uses Independent Verification to Meet Rising Expectations
As explained by Medline, many of its suppliers rely on migrant labor, making ethical sourcing an operational necessity rather than a branding exercise. Medline embedded ILO-aligned expectations directly into its Supplier Code of Conduct and integrated human rights due diligence into core procurement processes.
Crucially, third-party verification through WRAP certification became essential—not only to identify and address risks, but also to meet procurement requirements. In many tenders today, Medline would be disqualified if Tier 1 suppliers lacked WRAP certification.
Independent verification provides:
- Credible, comparable evidence of compliance
- Reduced audit fatigue for suppliers
- Alignment with global buyer expectations
- A stronger position in public procurement bids
Looking Ahead: Worker Voice, Due Diligence, and Market Access
Whether discussing fast-fashion supply chains or migrant labor risk, the themes converged:
- Transparency and speed must evolve together.
- Worker voice is indispensable.
- Independent verification is increasingly tied to market access.
- Regulators and buyers expect proof—not promises.
As SHEIN launches its ESCP Worker Helpline pilot and Medline expands its verification program, the goal remains the same: mechanisms that workers trust, that generate meaningful insights, and that lead to safer, more equitable workplaces.
WRAP closed the session with a reminder that protecting the most vulnerable workers—especially migrants—is central to responsible sourcing in 2026 and beyond.
