Looking beyond direct suppliers

By the Generate Zero Team  |  Published October 2026  |  Modern Slavery

What a laptop can tell you about modern slavery risk beyond Tier 1

You buy a laptop from a local technology supplier. You know the company, have its contact details and may have reviewed its policies. But what do you know about the factories and raw materials behind the laptop?

That is the visibility gap beyond Tier 1, the suppliers you buy from directly. Their own practices matter, but assessing them alone may miss risks in the production of the goods they sell. [LINK: Article 4 for the proposed regulatory changes in Australia and New Zealand]

A laptop is a good example

A New Zealand reseller may have few obvious risk indicators in its own operations. That does not establish the risk profile of the laptop’s wider supply chain.

An illustrative supply chain could include:

1. The reseller that supplies your organisation.

2. Assembly and electronics manufacturing.

3. Component production, including semiconductors, batteries and circuit boards.

4. The mining and processing of materials such as cobalt, tin and tantalum.

These activities can involve different countries and working conditions. The chain also branches: a battery and a circuit board will not necessarily pass through the same companies or the same number of tiers. This example illustrates possible exposure, not a verified route for a particular laptop.

What supplier questionnaires can miss

You buy a laptop from a local technology supplier. You know the company, have its contact details and may have reviewed its policies. But what do you know about the factories and raw materials behind the laptop?

That is the visibility gap beyond Tier 1, the suppliers you buy from directly. Their own practices matter, but assessing them alone may miss risks in the production of the goods they sell. [LINK: Article 4 for the proposed regulatory changes in Australia and New Zealand]

Questionnaires can help you understand a supplier’s practices and request evidence. They are less useful when they become the whole assessment:

• The answers depend on what the supplier knows. A reseller may have limited information about mines or component factories further upstream.

• Answers can go out of date. An assessment needs revisiting when new information becomes available.

• Follow-up can be difficult to track. If responses, evidence and actions sit in separate spreadsheets and inboxes, it is easy to lose the connection between them.

• Response rates can distract from risk. The suppliers who answer fastest are not necessarily the ones that need the most attention.

How upstream modelling helps

You may not have a complete list of the businesses behind every purchase. Modelling can help you decide where to investigate while those gaps remain.

Upstream modelling starts with purchasing data: what you buy, from whom and how much you spend. It uses economic supply chain models to estimate which sectors and countries may be involved in producing those goods and services. Risk indicators are then applied to those estimated pathways.

For a laptop purchase, that may point towards component manufacturing or raw material extraction as areas to investigate. It does not prove which factory or mine supplied your laptop, or that exploitation occurred there. It gives the team a more informed place to start asking questions.

From hotspots to action

You may not have a complete list of the businesses behind every purchase. Modelling can help you decide where to investigate while those gaps remain.

Upstream modelling starts with purchasing data: what you buy, from whom and how much you spend. It uses economic supply chain models to estimate which sectors and countries may be involved in producing those goods and services. Risk indicators are then applied to those estimated pathways.

For a laptop purchase, that may point towards component manufacturing or raw material extraction as areas to investigate. It does not prove which factory or mine supplied your laptop, or that exploitation occurred there. It gives the team a more informed place to start asking questions.

A potential hotspot is a reason to investigate. The next steps might be:

• Prioritise the purchasing categories with higher modelled exposure, alongside any direct evidence you already hold.

• Ask relevant direct suppliers what they know about sourcing in those categories and request supporting evidence.

• Consider how sourcing requirements, supplier engagement or contract terms could address the risks identified.

• Record the questions asked, evidence received and action taken. Keep unresolved gaps visible too.

The useful outcome is a clearer decision about where to spend due diligence effort. A risk score alone does not make that decision for you.

How Generate Zero can help

Generate Zero’s Modern Slavery Risk Intelligence uses supplier and general ledger data to assess risk by country, sector, commodity and company. Local and global intelligence helps teams prioritise suppliers for further investigation and monitor changes in the information behind their assessments.

The platform distinguishes risk indicators from confirmed evidence and shows the information supporting an assessment. That helps teams understand why a supplier needs attention and what they still need to find out.

To explore how this could work with your supplier and spend data, get in touch.