Services/Service 03
Support Your Claims With Strong Supply Chain Evidence.
When a brand says that its products are responsibly sourced, sustainably processed, or ethically produced, it is making a statement about its supply chain. It has nothing to do with intentions, supplier contracts, or procurement policy.
Its supply chain as it actually operates.
Regulators care deeply about that distinction, and it is here where a large number of well-intentioned sustainability claims begin to falter.
Where the problem starts
Most supply chain claims do not start as intentional misrepresentations. They start as reasonable summaries of the procurement policy, a supplier questionnaire, or a certification held by someone else.
Then, someone in marketing writes 'responsibly sourced' because that is what the brief says. It goes to ESG, where it is signed off as reflecting the company's stated commitments.
In this chain, no one checks whether the underlying evidence would withstand a simple question from the regulator: "How do you know?"
The CMA Green Claims Code is clear that businesses bear the responsibility for the accuracy of their statements, including claims that depend on supplier information. Responsibility does not transfer upstream just because they hold the evidence. If you have incomplete, outdated, or unverified data, the claim built on it can't stand, regardless of who provided the information.
Regulatory triggers
Supply chain claims attract scrutiny when they are:
Terms like "ethically made," "responsibly sourced," and "sustainably produced" are so broad that they can be interpreted to mean anything. That is the problem. ASA/CAP guidelines need clarity on environmental claims. If consumers can't understand what the claim implies, it may be considered misleading.
A claim needs documentation to back it up at the time it is made. Supplier self-declarations, unaudited questionnaires, and internal assumptions do not count.
Highlighting one positive aspect of a supply chain while omitting significant environmental or social concerns elsewhere can be classed as 'misleading by omission'. For example, if your shipping methods offset gains in your production process, that reality has to be reflected in the final claim.
For businesses subject to the Modern Slavery Act reporting requirement, the expectation is that a brand's sustainability aligns with what annual transparency statements say. Inconsistencies between public claims and supply chain realities invite regulatory and reputational risk.
What's included
We work with clients to close the gap between what is being communicated and what can be proved.
We review public-facing language related to sourcing, origins, supplier standards, and ethics, across websites, packaging, campaigns, and other communications. These claims are assessed against what your procurement team can gather evidence for.
We map the gap between your published claims and available documentation. The exercise identifies missing, partial, or unverified evidence to determine what needs to be audited, obtained, or qualified before the claim can be made safely.
We assess the supplier information underpinning your claims for currency and quality. Self-declarations, audit reports, certifications, and third-party verifications are not the same. We help you understand which claims have strong support and which are made on weak grounds.
If we cannot fully substantiate a claim across an entire supply chain, we provide alternative language that is honest about the scope, clear about limitations, and defensible to regulators. A more limited claim with proper evidence is stronger than a broad claim that won't stand up to scrutiny.
For clients whose obligations include Modern Slavery Act reporting, we review how closely the supply chain disclosures and marketing claims align. Any discrepancies present a compounding risk that could damage your reputation and invite regulatory and legal issues.
Who this is for
Our supply chain review is particularly relevant for:
Brands selling fashion, consumer goods, food, etc., or manufacturing where sourcing claims are included.
Businesses whose claims rely on certifications held by upstream or third-party verifiers to support marketing claims.
Companies whose ESG or sustainability communications reference the supply chain.
Organisations preparing for public reporting, investor due diligence, tender submissions, or supply chain integrity checks.
Businesses that have received communications from retail partners or institutional buyers who demand evidence of sustainability claims.
Supply chain claims are some of the riskiest categories when making environmental statements. Often, this is because the evidence to support them sits, at least in part, outside your direct control. That makes it worth looking into the strength of your current claims.
We help you make those claims without exposing yourself to regulatory liability.
