Mosaic’s Salient Risk Country Reference is a country-by-country reference to the labour risks most likely to be actually occurring in apparel and footwear production, NOT what is being reported in standard social compliance audits such as SMETA, BSCI, WRAP, SLCP, etc. which routinely fail to identify known country risks due to their lack of independence, over scoped nature, lack of onsite time, and restricted reporting protocols. 

Purpose: use the resources regulators use to identify country labour and human rights which stands in contrast with most social audit trends. Consistent with how regulators prioritize issues, this resource only covers Zero Tolerance and Critical as defined by the ILO and directly or indirectly linked to Force Labour indicators.

The European Commission’s June 2026 guidance on the EU Forced Labour Regulation names sectoral risk assessments among the documents an authority may request. This is built to be one. Every row maps to the ILO Compliance Assessment Tool category and sub-category, to the ILO’s eleven forced-labour indicators where they apply, and to the mHRDD instrument it falls under — EU CSDDD, German LkSG, French Duty of Vigilance, Norwegian Transparency Act and others. If you are asked how a sourcing decision or a prioritisation judgment was reached, this is the answer.

Vietnam

For Vietnam, the Salient Risk Reference flags twelve distinct labor issues – seven rated Zero Tolerance and five rated Critical. While the focus of the tool is the apparel and footwear industries, regional field input confirms that many of the noted issues are driven by fundamentals (e.g., migrant labor management, recruitment practices, wage/hours systems) common across manufacturing sectors generally. Another key driver for compliance trends relates to factory ownership and management team profiles. A large number of Vietnamese factories are owned and operated by Chinese nationals. As a result, similarities, including bad habits, seen in Chinese factories are also common in Vietnamese factories such as record falsification. Furthermore, critical communication gaps can exist between management and workers, and ownership and management that create a much higher risk environment for disciplinary, harassment and abuse issues.   Here are some of the issues identified: 

Record Falsification and Worker Coaching

Undocumented or edited time records and coached workers are common in Tier One factories. Such practices which are the norm in mainland Chinese factories are often carried over to Vietnamese factories owned and managed by Chinese nationals. It is estimated that more than 75% of Northern Vietnam’s garment factories are Chinese owned. Catching this issue during normal audits requires both focus, training, and tenacity by auditors. Working hours that consistently meet the exact maximum legal hours and/or a typical brand maximum of 60 hours/week are red flags that this issue exists, but not found during an audit due to weak auditing or bribery issues. 

Poor Communication and Industrial Relations 

Workers frequently face severe retaliation for voicing complaints, deterring them from asserting their rights or raising internal concerns. These risks are heightened by language barriers and cultural communication gaps between Chinese ownership and management and Vietnamese staff, which exacerbate misunderstandings and friction on the factory floor. Furthermore, grievance mechanisms are often weak or non-functional due to low worker trust or awareness, leading employees to bypass internal channels entirely by quitting or escalating issues externally to trade unions, labor authorities, or social media

Sexual Harassment

Vietnam’s labor law explicitly prohibits sexual harassment, but Fair Wear Foundation, Better Work Vietnam, the Fair Labor Association, Worker Rights Consortium and Human Rights Watch report it remains common in Tier 1 and sub-tier factories. 

Sub-contracting & Temporary Labour

Non-compliance on dispatched labour has increased significantly in recent years putting people on a factory floor without putting them in its personnel system. In addition, unauthorized subcontracting can occur related to labour-intensive steps that sit either side of sewing, which are the easiest to move and the least likely to be listed: hand embroidery, beading and trims, printing and washing, and final packing. These leave the declared site during peak and return as finished components.

Indirectly Coerced Overtime

These days, overt forced overtime, and direct retaliation for refusing it, are less widespread. Especially in Tier One factories. However, this issue still exists in small and sub-contracted sites. However, piece-rate quotas, low base wages and monthly bonuses are often tied to the number of overtime hours pushing workers toward more and more overtime. 

Fire, Chemical, and Machinery Safety Failures 

Critical fire and chemical safety issues are commonly found, but in particular with new and/or less sophisticated sub-tier or sub-contracted sites that are less exposed to social auditing. 

Full detail on each issue – audit blind spots, legal basis, and Salient Risk Supplier Assessment (SRSA) probes – can be found in the tool itself. Click here if you’d like to learn more.