By Antonio Carlos Rosa, Program Director, Brazil
More than two decades after its creation, Brazil’s Lista Suja—the “Dirty List” of employers found to have subjected workers to conditions analogous to slavery—remains one of the most influential forced labor accountability tools in the world. Few countries have taken such a direct and public approach to confronting modern slavery. Yet its continued relevance also reflects a sobering reality: transparency alone, while powerful, is not enough to eradicate forced labor.
Understanding what the Dirty List has achieved, and where its limits lie, offers important lessons for policymakers and companies navigating labor risk in Brazil and beyond.
A Pioneering Approach to Forced Labor Enforcement
Launched in the early 2000s, Brazil’s Dirty List was an innovative policy response that relied on public disclosure rather than criminal sanctions alone. Employers placed on the list have been found, through formal labor inspections and due process, to have subjected workers to conditions analogous to slavery under Brazilian law.
By making verified cases of forced labor publicly visible, the Brazilian government intentionally shifted accountability beyond the state. The list enabled banks, companies, investors, and civil society to factor labor rights violations into economic and commercial decisions—embedding human rights considerations into the functioning of markets.
Why the Dirty List Has Had Real Impact
At its core, the Dirty List is “just a list.” Yet its impact has been substantial precisely because of how it is used.
Financial institutions and companies across Brazil incorporated the list into lending, procurement, and risk-management decisions. One of the clearest examples is Brazil’s development bank (BNDES), which is legally prohibited from financing companies linked to slave labor. Similar restrictions have shaped broader financial and commercial behavior, increasing the economic consequences of labor exploitation.
Perhaps the strongest evidence of the Dirty List’s effectiveness lies in the repeated efforts to suppress it. Publication was suspended between 2014 and 2016, and later attempts were made to weaken its governance and credibility. These challenges underscore how disruptive transparency can be when it threatens entrenched interests—and why the list continues to matter.
A Persistent Paradox: Transparency and Ongoing Forced Labor
Twenty-three years after its first publication, two realities coexist.
On one hand, Brazil stands out globally for the transparency and credibility of its forced labor enforcement. On the other, forced labor remains a serious human rights challenge. In 2023 alone, more than 3,190 workers were rescued from conditions analogous to slavery. Many more cases likely remain hidden.
This paradox does not reflect a failure of the Dirty List. Rather, it highlights the limits of any tool designed primarily to act after severe violations have already occurred.
The Limits of Exposure and the Need for Prevention
The Dirty List is inherently reactive. It exposes abuse after workers have already been harmed. While the risk of public listing can deter some violations, rescue figures make clear that deterrence alone is insufficient.
Reducing forced labor at scale requires shifting from exposure to prevention. This means strengthening strategies that identify and address risk earlier—before exploitation occurs, and that reach across supply chains and labor markets. Prevention depends on sustained collaboration among government, companies, workers, and civil society, grounded in shared responsibility and practical action.
It also requires addressing the structural drivers of exploitation. Inequality, informality, and limited access to decent work increase workers’ vulnerability to coercion. Public policies that strengthen social protection, labor governance, and rural livelihoods remain essential complements to enforcement mechanisms like the Dirty List.
What the Dirty List Means for Companies Operating in Brazil
For companies sourcing from Brazil, the Dirty List should be treated as a critical risk signal, but not as a standalone compliance solution.
Responsible companies use the list to inform risk assessments, identify high-risk sectors and regions, and trigger deeper engagement with suppliers. However, absence from the list does not mean absence of risk. Many supply chains operate in contexts where inspections are infrequent and abuses go undocumented.
Using the Dirty List effectively means:
- Integrating it into broader human rights risk assessments
- Looking beyond exclusion toward prevention and remediation
- Engaging suppliers and workers to address root causes
- Recognizing that public enforcement data captures only part of the risk landscape
Companies that rely solely on the list to screen suppliers risk overlooking severe but hidden forms of exploitation.
From Listing to Due Diligence: Strengthening HRDD in Brazil
This is where human rights due diligence (HRDD) becomes indispensable. When designed collaboratively and implemented in practice, HRDD enables companies to move beyond reactive risk avoidance toward proactive prevention.
In Brazil, effective HRDD requires acknowledging that forced labor risks exist across sectors and supply chains—and committing to systematic approaches that identify, prevent, and mitigate harm. This includes aligning company systems with public enforcement data, engaging workers meaningfully, and investing in tools that support early risk identification.
Verité is part of this effort, working alongside Brazilian stakeholders to translate global HRDD standards into practical, field-informed tools. Through initiatives such as the Farm Labor Due Diligence Initiative, Verité supports companies in strengthening prevention-focused approaches that complement—and extend beyond—the Dirty List.
Brazil’s Global Relevance in a Changing Regulatory Landscape
As forced labor regulations, import bans, and mandatory due diligence laws expand worldwide, Brazil’s experience offers critical lessons. Few major commodity-producing countries have demonstrated the same level of transparency or institutional commitment to confronting modern slavery.
The path forward is not about replacing the Dirty List, but about embedding it within a broader preventive system. A structured, collaborative approach—bringing together policymakers, companies, workers, and civil society to design and implement effective HRDD, supported by credible enforcement and public policy—offers the strongest foundation for lasting change.
Transparency made forced labor visible. The next chapter must ensure that visibility leads to prevention, accountability, and, ultimately, the eradication of slave labor across Brazil’s economy.
About the Author
Antonio Rosa is Verité’s Brazil Country Lead and Co-Leader of the Stakeholder Engagement and Technical Assistance Practice Group. Since 2022, he has led Verité’s work in Brazil, including directing the Cooperation on Fair, Free, Equitable Employment (COFFEE) Project. In this role, he oversaw the development and implementation of the COFFEE Toolkit and led pilot initiatives in Brazil, Colombia, and Mexico. His research and HRDD system implementation experience spans multiple Latin American production chains, including cocoa, coffee, palm oil, carnauba, and sugarcane.
Human trafficking, Brazil
