Focus on Labour Exploitation (FLEX) has been developing the FLEX Worker-Centred Model, an innovative Human Rights Due Diligence (HRDD) programme for outsourced service supply chains, co-created with workers and grounded in their lived experience. 

The Worker-Centred Model, first piloted in the UK cleaning sector and now expanding to logistics and security, combines two key tools: the Worker Engagement and Safeguarding Framework (WESF), which captures workers’ lived experience, and the Human Rights Assessment (HRA), which evaluates supplier practices. Together, they help businesses spot risks early, meet regulatory requirements, make smarter sourcing decisions, and improve supplier performance. 

Outsourced service supply chains are often treated as peripheral to core business operations. Yet the workers delivering cleaning, security and logistics services are present on sites every day, and their labour is essential to effective operations. Offices do not function, goods do not get delivered and premises do not remain secure without them. They represent brands in practice whether companies directly see them or not.The question is not whether these workers sit within a company’s sphere of responsibility — they already do. The question is whether due diligence systems are designed to meaningfully account for how their work is experienced on the ground. 

Outsourced service models often limit brands’ direct oversight of working conditions. Questions such as: 

• “How many workers are delivering services on our sites?” 
• “How do we know our policies are being implemented in practice?”
• “Are workers absorbing unpaid time to meet service expectations?” 
• “Are workloads and staffing levels aligned with what is contractually agreed?” 

are often left without answers.  

Traditional audits and supplier reporting rarely capture how risks play out in practice, particularly where workers feel unable to raise concerns.  

Without reliable worker input, companies risk basing decisions on incomplete or misleading information, leaving them exposed to labour risks in their own backyard.  

At the same time, outsourced service supply chains are complex, with responsibilities spanning procurement, operations and suppliers. Regardless of intent, governance conversations do not always align in a coordinated way.  

That’s why, in the pilot for our Worker-Centred Model, we worked with partners willing to engage openly with this complexity. We created space to test assumptions, identify blind spots and develop practical solutions grounded in worker insight. 

By co-developing our approach with workers from the outset, we ensure that risk identification, action plans and any interventions implemented by companies reflect workers lived experience, and result in measurable improvements. 

Building feedback channels workers can trust 

As part of this pilot version of the model, we developed a Worker Engagement and Safeguarding Framework, directly from what workers shared about the risks and barriers they face when raising concerns. It guides how we design engagement and ensures workers feel safe and supported in sharing their experiences. 

Brands can often assume that if reporting tools exist, workers will use them. But the reality is more complex. Many workers weigh the risks of speaking up against the consequences they may face. 

To give an example, FLEX ran workshops with more than 60 Latin American and Afro-Caribbean cleaners in the UK, in collaboration with the grassroots union Independent Workers of Great Britain (IWGB). Latin American and Afro-Caribbean communities that are notably overrepresented in the cleaning sector. When asked why the workers don’t use reporting mechanisms, despite having issues at work, they described indirect forms of pressure: 

“They don’t always punish you directly. They change your hours, move you to a worse site, or make the job impossible so you end up leaving.”  

For companies, this presents a clear oversight risk. If workers perceive sharing their day-to-day experiences or raising concerns as unsafe, emerging or even long-standing issues remain invisible, leaving companies unable to act before they escalate.  

Clear non-retaliation commitments, alongside independent channels and practical safeguards, are essential if risk identification systems are to function effectively. 

While developing our Worker Engagement and Safeguarding Framework, workers also emphasised the importance of follow-up: 

“I want to know what happens after the meeting. Follow-up matters, so we’re not left wondering if anything changed.” 

This insight exposed a common weakness in due diligence processes: issues may be identified, but without visible action and effective communication (and this includes a format and language that workers can understand!), trust erodes and future engagement with the brand declines. FLEX’s Worker-Centred Model embeds clear communication across all stakeholders, with workers recognised as central participants, alongside structured action-tracking mechanisms that improve the reliability of worker-informed insights over time. 

Applying the model in practice 

To test the Worker-Centred model in practice, FLEX piloted it in partnership with businesses operating in the UK. 

From the outset, the process brought together procurement, legal, operations, sustainability and human rights teams. Rather than sitting within a sustainability silo, the findings were integrated into governance, supplier oversight and operational decision-making processes. Teams recognised that understanding how conditions were experienced on the ground strengthened not only human rights due diligence, but also stability of vital services, brand reputation and long-term operational resilience. 

At times, this required navigating different internal priorities. Operational efficiency and cost control can appear to sit in tension with enhanced worker protections. In practice, the assessments helped demonstrate that these objectives are complementary: Stronger safeguards and clearer responses can result in:  

• Reduced staff turnover and more stable service delivery 
• Mitigated risk of disruption to vital services such as cleaning and security 
• Provide defensible due diligence evidence to investors and regulators 

The HRA examined participating brands’ cleaning supply chains through structured engagement with service suppliers, policy and document review, workforce data analysis, and periodic engagement with the brands and suppliers to maintain alignment throughout the process. Rather than focusing solely on policy compliance, it assessed how risk was managed in practice.  

As the assessments progressed, five areas kept coming up all highlighting the gap between formal standards and lived conditions: 

• Living Wage implementation: Annual rate increases are often implemented at the formal deadline rather than when new rates are announced, meaning workers can remain below the updated benchmark for several months (over £500 impact at 30 hours/week). This means companies can be technically compliant, but this last-minute implementation weakens the credibility of Living Wage commitments and creates reputational risk. 
• Overtime and unsocial hours: Early morning, late evening and late-notice additional hours are typically paid at standard rates, with no premiums for unsocial scheduling. This contributes to fatigue and high turnover in operationally critical roles. 
• Lone working: Cleaners frequently start and finish shifts without a colleague or supervisor present, yet lone working is not always formally recognised. As a result, appropriate protocols are often absent, creating avoidable safeguarding and liability risks. 
• Disability inclusion gaps: Without structured disclosure, monitoring or adjustment tracking, disability risks remain invisible. This increases legal and discrimination risk, particularly in sickness absence and capability processes.  
• Subcontracted labour: Specialist subcontracted workers, like those carrying out window cleaning or deep-hygiene tasks, are not always integrated into the same reporting and grievance systems, creating compliance and brand risk through fragmented oversight.

By uncovering these gaps, the assessment meant that concrete improvements could be identified. These included strengthening wage implementation practices, enhancing recognition for unsocial hours, formalising lone working safeguards, building structured disability protections, and tightening oversight of subcontracted labour.

Participating businesses engaged constructively with these findings, including where they challenged established practices. Power dynamics in outsourced service supply chains are not straightforward, and aligning procurement, operations and supplier oversight requires coordination across multiple functions. The willingness of partners to interrogate their own systems and implement changes with clear ownership and timelines was critical to translating worker insight into practical reform. 

Ultimately, verifying the success of the model is down to the workers, by definition of the model itself. To that end, we are engaged with workers on this at the moment, and look forward to showing the findings of their feedback.

Looking Ahead 

As scrutiny of service supply chains increases, due diligence that relies on policies and audits alone will not be enough; without trusted worker engagement, companies are operating with only a partial view of risk. 

Our Worker-Centred Model pilot revealed how outsourced service models can appear compliant on paper while key risks remain out of view. Even with policies and contractual standards in place, blind spots and limited brand visibility remain- which is exactly where safeguarded worker input becomes essential. 

Our experience reinforced something fundamental: staying engaged matters. Outsourced service workers are an essential part of these supply chains, keeping sites operations every day. Workers remain inside these supply chains whether or not brands have visibility of their day-to-day realities. When companies open space for scrutiny, even partially, it creates an opportunity to surface risks, strengthen systems and embed more responsible practices. When that space narrows, the risks do not disappear, they simply become harder to see. 

FLEX is now applying and refining this model across other outsourced service industries. Our aim is not simply to assess risk, but to build durable, scalable systems that improve visibility and accountability over time.