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| Untranslated strings | 49% | 113 | 49% | 277,850 | 49% | 1,996,918 |
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Navigating Sensitive Stories: A Guide to Ethical Engagement with Vulnerable Sources
=============================== By Stavros Malichudis  ```cik-in-short ``` **In short:** Drawing on over a decade of investigative reporting experience, this practical guide by Stavros Malichudis in collaboration with Tactical Tech offers concrete steps in working with vulnerable sources. --- ## Introduction How should journalists and researchers approach sources who have experienced trauma? How can they do so in a way that avoids unintentionally re-traumatising them? And how can we build trust, and make sure that individuals willing to share important information with us will not be targeted or face other negative consequences? As an investigative reporter and editor for over a decade, I have worked closely with vulnerable sources in the field. I have spoken to [shipwreck survivors](https://exposingtheinvisible.org/en/films/pylos-shipwreck/); victims of violent state collective expulsions known as ‘pushbacks’; exploited [land workers](https://wearesolomon.com/mag/focus-area/migration/greek-strawberries-made-in-bangladesh/) and [call center agents](https://insidestory.gr/article/teleperformance-part2); unaccompanied minors who lived on the street or had been detained for up to 48 hours in secret ‘prisons,’ which were passenger ferries running between Italy and Greece; residents who lost their neighbors and their houses in a massive fire outside of Athens in the summer of 2018; locals whose loved ones were among [the 64 people who died in 2020 in a care home in Crete, Greece](https://www.investigate-europe.eu/en/posts/death-in-paradise-how-64-care-home-residents-died-in-crete); mothers in Greece and Germany whose sons [were killed by neo-Nazis](https://wearesolomon.com/mag/format/interview/their-sons-were-murdered-by-neo-nazis-now-they-vow-to-keep-their-memory-alive/); and administration and industry insiders who became whistleblowers. This guide draws on these experiences to address ethical concerns that span the entire investigative project lifestyle, from initial design, to implementation, and finally to engaging audiences in the post-publication phase. ## Pre-reporting phase ### 1. Understand which sources are vulnerable First, we need to have a clear understanding of the many diverse roles and identities that a ‘vulnerable source’ can belong to. A ‘vulnerable source’ could be, but is not limited to: * An undocumented worker or a person on the move (migrant); * A person who lost a loved one in an accident; * A person who lost their property in a natural disaster; and * A whistleblower on the brink of exposing misconduct or mistreatment within a company, a state agency, or an international organisation Focusing on vulnerable voices should be the standard practice for *any* story striving to illuminate underreported issues and hold power accountable. Vulnerable sources can enlighten perspectives, for both the researcher and the reader, by offering the opportunity to perceive a situation as thoroughly and holistically as possible. Including vulnerable sources in your research isn't just about doing the right thing; it's also about better research. While many stories highlight the usual prominent voices, tapping into those often overlooked can uncover fresh, underexplored perspectives. It's a powerful way to make your work more inclusive and insightful. But for these individuals, speaking to a researcher carries significant risk. Depending on their status, they could face job loss, retaliation or community rejection, risk of arrest, and more. Given the stakes, researchers serving the public interest with their investigations have an ethical duty to protect the sources of their work. The rest of this guide presents a curated list of best practices to help researchers incorporate the voices of vulnerable sources while minimising potential harm. ### 2. Do your research before approaching vulnerable sources Before establishing contact with an individual or a community, it’s vital that some time is dedicated to pre-reporting. Ask yourself: What do you know about the person you are willing to approach or the community they are part of? Do you have a basic understanding of the community’s manners or customs? A basic overview of the individual’s story? Dedicate some time to answer these questions and gather some basic, initial information. This can be done through searching online, making phone calls to experts, and asking colleagues. A good first impression can save both parties from awkward situations. It can also help create a first layer of trust; people appreciate it when others have made the effort to learn things about them. #### For communities: Research the communities you are approaching, and treat them with respect by adhering to their customs. Demonstrate that you have done your due diligence and establish that this is a source-researcher relationship you are interested in building. For instance, in some cultures men do not greet women with a handshake. In other cultures, for example, refusing to accept a drink that someone offers can be seen as lack of respect. These cultural circumstances can be difficult to navigate at times, as you balance your specific risk assessment and safety concerns with cultural practices in certain contexts (such as the fear of being poisoned by a potential adversary). Above all, try not to take cultural differences for granted — it’s vital to adapt to and enter each context with as much care and awareness as possible. #### For individuals: Again, research as much as possible beforehand. Demonstrate that you took the time to learn about whoever you are approaching. If that person carries with them a traumatic experience, thorough research before meeting them can help avoid re-traumatisation. A journalist's due diligence involves gathering as much context as possible to understand what is at stake for the source. When I first worked on the [story of the care home](https://www.investigate-europe.eu/en/posts/death-in-paradise-how-64-care-home-residents-died-in-crete) in Crete, Greece, where 64 people died in a single year, some of the relatives who lost loved ones had already talked to the media. Having read their interviews, when I met with them I was able to ask more targeted questions to get the most insightful information. Having an idea of the chain of events, I also had the opportunity to treat traumatic memories with more care. Doing as much research as possible can help you show sources that you took the time to learn them, stick to the facts when it comes to traumatic experiences, and respectfully acknowledge the pain people share. While a long-standing saying in journalism says that there are no stupid questions, perhaps the only stupid question that could be posed to a vulnerable source is one that will unnecessarily make them re-experience their trauma. ### 3. Plan your initial approach Often, the best way to approach sources who might be hesitant to talk to you is through people who can vouch for your integrity, your credibility, and your ethical standards. These could be mutual acquaintances, like an NGO that you have worked with before. Or, perhaps you know members of the same community who can introduce you to your potential source. If the individual has a public social media profile, you can search for possible common connections. This allows for a smoother approach, as well as a better informed pre-reporting phase. ### 4. Recognise the power balance between you and your sources Researchers should clearly understand the power dynamics at play when working with vulnerable sources. A vulnerable source inherently holds less power than a reporter. This imbalance can stem from a source's level of wealth or income, legal status, social standing, age, race, ethnicity, nationality, religion, or other factors. Researchers need to take power imbalances in mind when designing an investigation. They must have in mind the insecure position of their source, their ethical duty to protect them and treat them with care, and the possible challenges that may arise during the research phase, and beyond. ## Research phase ### 1. Explain yourself The success of a research project involving vulnerable sources often comes down to how you explain yourself, the process you follow, the outcomes of the research project, and any possible implications such as short or long-term risks posed to your sources in this case. Vulnerable sources are entitled to clear explanations of the above, as early on as possible in the process. Researchers should keep in mind that their sources may not be familiar with their research or its possible implications. Researchers need to provide this context themselves and explain each aspect of a research project as needed. As early as possible in the process, researchers must seek agreement with sources on these major aspects: #### The nature and level of involvement: What is it exactly that you want to gain from your sources? Will this require a single interview or a series of meetings? Should they also expect phone calls from you? Do you expect them to be available for a set period of time, e.g., for the duration of a trial? Is your editor, a photographer, or a fact-checker going to call them later on? #### The duration and timing of the engagement: Very often, vulnerable sources contribute to time-sensitive research projects. For instance, when investigating how governments and organisations used funds provided by the EU for the accommodation of asylum seekers, I met a family who stayed in one of these housing units in Athens. The NGO responsible for them was receiving millions of euros from the EU, but photos the family captured showed that conditions inside their apartment were horrific. They wanted to expose the conditions, but it was best for them to do so after they had left the apartment, due to a fear of being identified. Similar conditions may occur when a company whistleblower wishes to denounce internal processes. It may be better to publish any material only *after vulnerable sources* have left these environments. Time of publication should be agreed upon early on to avoid frustration on both sides. No surprises! #### The format: When you interview a vulnerable source, will you quote them in full, or will you rephrase or paraphrase their words? Before recording a source’s voice or likeness through photos or videos, always obtain informed consent, taking care to explain how this material will be used. When recording their voice, for example, state from the outset whether it is strictly for your own note-taking or for inclusion in the publication of the story. #### Publication details: Where will the story be published, and in what context? In what languages and formats will the outcome be available? #### Fact-checking: Information provided by vulnerable sources, in fact by *any* sources, must be corroborated independently. This can be tiring or disappointing for people who share their trauma with you. Consider the [Pylos shipwreck](https://exposingtheinvisible.org/en/films/pylos-shipwreck/), the largest in the Mediterranean in recent years, which claimed the lives of over 600 men, women, and children. Some survivors said they had stayed in the water for an hour before a Greek Coast Guard vessel came to their rescue. Others said it was closer to half an hour. While probing such details can feel insensitive given the immense suffering, these discrepancies still require meticulous fact-checking. For sources unfamiliar with journalistic processes, it's crucial to explain that independent verification is paramount to upholding the integrity and validity of any investigation. This transparent communication also means being clear that some information, no matter how personally significant, may not be included in the final report if it cannot be independently verified. Clarifying these aspects in advance can help you manage expectations, maintain trust, and mitigate frustrations. ### 2. Let sources know they are also in control All human relations come with power dynamics. Usually, journalists have power over sources, as they ultimately decide what to include in a piece or not. But with sources, especially vulnerable sources, it’s important to know that they are also in control of their own story. One of the first steps I follow when working with vulnerable sources is to make clear to them that they have the option to decide if specific information shared with me is on the record, off the record, or on background. In other words, if they don’t want to answer a specific question, they don’t have to. They should also have the opportunity to pause an interview, if at any time they feel the need to do so. As researchers, we should show patience. Give them the time and space they need, and don’t pressure them. Resist the urge to fill pauses, or periods of silence. If a discussion touches on tragic events, don’t just keep pushing for answers. Take a break when the person seems distressed or simply wants to stop. ```cik-note ``` >**Some terms to explain to your sources:** > >* **On the record:** Unless explicitly agreed otherwise, any conversation with a journalist is considered ‘on the record’. This means everything a source says can be quoted directly, attributed by name, and published. It's the highest level of transparency and accountability, allowing readers to see precisely who said what. > >* **Off the record:** When something is ‘off the record,’ the journalist agrees that the information provided cannot be published or attributed to the source. Journalists and sources must mutually agree that a conversation is ‘off the record’ before any information is shared. > >* **On background:** When a conversation is ‘on background,’ journalists can publish and quote the information provided by a source, but cannot identify the source by name or otherwise attribute that information to the source using other identifiable information. Researchers can describe the source as accurately as possible, for example as ‘a source familiar with the incident’ or ‘an employee on the field’, without revealing the source’s identity. > ### 3. Give it time In 2019, during a months-long investigative project, I was tracking unaccompanied migrant children in Greece. These kids faced unimaginable challenges; some had experienced homelessness, others had been detained in police stations for months. As I worked to build trust and gather information, my editor offered a brilliant piece of advice: “just hang out with them.” No recording, no note-taking, just hanging out. Do what they do. Spend an afternoon with them, then another, without the pressure of collecting material for the written piece I had in mind. This approach was illuminating. It allowed me to visualise and truly understand the humanity of my potential sources first. It fostered a more natural, less rushed relationship, letting things unfold organically. Investigations, especially with vulnerable sources, demand time. That fellowship taught me a crucial lesson about building trust. When sources sense genuine care for their story, they often become your strongest advocates, introducing you to others and vouching for your credibility. It's a powerful ripple effect that extends far beyond any single interview. ### 4. Explain the possible implications Letting vulnerable sources know they’re also in control is related to your responsibility to inform them about the possible implications that may arise for them by speaking to you. For instance, a few years back I worked on an investigation exposing labor exploitation and racism in a call-center giant in Greece. One of the main sources, an ex-employee of the company, insisted on speaking on the record. Although it’s always better for the validity of an investigation that sources speak on the record, it was my duty back then to inform the person that, given the practices in that specific sector, speaking publicly against the industry’s major company could mean that employers in his sector would no longer want him at their company. The source took a few days to think on this. He decided to still do it, as he saw his professional future in an entirely unrelated field. It was his choice in the end, but it was my responsibility to provide context that he wasn’t necessarily aware of. In other cases, when a source shares potentially identifying or incriminating information, it is imperative that a researcher might ask: “Are you sure you want to share this?” - This reminds the source of the risks and empowers them to decide what to share and withhold. ### 5. Don’t create expectations “Why should I speak to you?” - This is a question I often get from residents of refugee camps across Greece. - “You do your story, what will I get?” Vulnerable sources might be in dire need of financial aid or of state documents that could make their life move forward, to name just two examples. You might be asking them to talk to you at a time when they feel their life is falling apart. Researchers should make sure not to exploit the hopes of vulnerable sources. Simply put, don’t offer things in return for information, and don’t promise what you cannot deliver. It is imperative to explain that the actual impact of your story, especially for the individual’s own story, might be limited. But you should also explain that your research will contribute to holding power to account, and may contribute to a wider impact beyond this one story. While you may not be in a position to help them get certain documents, you can help them in other ways, like to let them know which NGOs offer legal support or to tell them what you know about labor inspections. ### 6. Ensure physical safety when meeting in person Are sources talking to you at risk if someone sees them with a reporter or a researcher? Would source protection be compromised? Physical safety during meetings demands careful planning. Be sure to consider: * **Awareness of Surroundings:** Ensure you are not being followed. Have a good understanding of the area you are in. * **Discreet Meeting Locations:** Avoid places where you could be easily seen. If meeting at a café, choose a seat with a direct view of the entrance. Avoid outdoor seating where you might be visible to individuals you cannot see. * **Location Privacy:** If using taxis or ride-sharing apps to meet a vulnerable source, avoid mentioning or inputting the exact meeting address directly into the app. You can ride to a walking distance address, and get on foot from there. * **Mobile Device Protocols:** When meeting sensitive sources, consider not carrying your mobile phone or disabling GPS to protect their safety, even if you perceive no personal risk. * **Inform your source:** Share with your source the different steps you take to ensure their protection. This can help build trust among the two parties, but it can also lead to valuable feedback on the specifics. ### 7. Ensure digital safety In-person meetings are not the only form of communication in need of security. Securing digital communication is also paramount. This includes: * **Password Protection:** Keep your phone password-protected. * **Auto-Delete Messages:** Utilise features that automatically delete messages. Most applications (like Signal, WhatsApp) have this feature. * **Encrypted Communication:** Avoid standard phone lines and SMS. Prioritise encrypted messaging apps like Signal, which is favored by researchers and academics due to its strong security. * **End-to-End Encryption:** Opt for services designed with privacy, where end-to-end encryption is standard, ensuring only you and your source can read messages. ```cik-note ``` >**Digital Security Resources** > >For fundamentals on digital security, physical security and wellbeing as well as risk assessment, you can start with articles and guides such as: > >* Security in a Box guides and tutorials: [https://securityinabox.org/](https://securityinabox.org/) >* Safety First guide: [https://kit.exposingtheinvisible.org/en/safety.html](https://kit.exposingtheinvisible.org/en/safety.html) >* Risk Assessment guide: [https://exposingtheinvisible.org/en/articles/risk-assessment-mindset](https://exposingtheinvisible.org/en/articles/risk-assessment-mindset) >* Holistic Security manual: [https://holistic-security.tacticaltech.org/](https://holistic-security.tacticaltech.org/) > ### 8. Handle documents securely For sensitive investigations, physical transfer of documents can sometimes be the safest method, such as through mail or direct delivery. Physical transfer doesn’t leave metadata. Edits can’t be tracked. This was reportedly how Edward Snowden provided documents to reporters, according to ["Snowden's Box: Trust in the Age of Surveillance"](https://www.versobooks.com/products/852-snowden-s-box?srsltid=AfmBOop4rkUd1yEAj2yNWs2yL5PTqlrs3MMKtHk7bmUuARbO0H0-Ckhi) by Jessica Bruder and Dale Maharidge, two experienced journalists who worked behind the scenes of the Snowden story. As the summary of the book notes, "The biggest national security leak of the digital era was launched via a remarkably analog network, the US Postal Service." If a source provides you with a document, you have to make sure that you properly anonymise it in case you wish to publish it together with your investigation or share it with others outside your fully trusted team. Make sure you really anonymise it. Don’t just cover content with blacked out text boxes that can be removed from the file! Image edits with specific tools can be tracked, as can metadata of the files, so one needs to very carefully work on this to ensure full source protection. ```cik-note ``` >**Metadata** refers to information that describes the properties of a file, be it an image, a document, a sound recording, a map, etc. For example the contents of an image are the visible elements in it, while the date when the image was taken, the location and device information constitute its metadata. In communications – when sending a message or a file - metadata includes details about who sent it, when, where from, and to whom, among others. See more here: [https://ssd.eff.org/module/why-metadata-matters](https://ssd.eff.org/module/why-metadata-matters "https\://ssd.eff.org/module/why-metadata-matters"). > Of course, file and data anonymisation has its drawbacks. Often it means altering evidence, so you will need to make sure you safely preserve original, unaltered versions of files for any possible situations that might arise, including, for example, court procedures. In 2022, after months of investigation, Greece's National Transparency Authority (NTA) released a redacted report addressing allegations of illegal pushbacks of asylum seekers. The report's conclusion: no such pushbacks had occurred. However, researchers quickly discovered a critical flaw: basic digital design tools were all that was needed to remove the blacked-out sections intended to protect the anonymity of the report's sources, thereby compromising the identities of the individuals who had informed the research. ```cik-tip ``` > See more tips and examples about data anonymisation in these articles: > >* “How Data Journalists Can Use Anonymization to Protect Privacy”, GIJN: [https://gijn.org/stories/how-data-journalists-can-use-anonymization-to-protect-privacy/](https://gijn.org/stories/how-data-journalists-can-use-anonymization-to-protect-privacy/) > >* “Privacy and data leaks: How to decide what to report”: [https://datajournalism.com/read/longreads/privacy-and-data-leaks](https://datajournalism.com/read/longreads/privacy-and-data-leaks) > >* “Why does The New York Times use anonymous sources?”, The New York Times, [https://www.nytimes.com/article/why-new-york-times-anonymous-sources.html](https://www.nytimes.com/article/why-new-york-times-anonymous-sources.html) > >* “Here are 12 principles journalists should follow to make sure they’re protecting their sources”, NiemanLab: [https://www.niemanlab.org/2019/01/here-are-12-principles-journalists-should-follow-to-make-sure-theyre-protecting-their-sources/](https://www.niemanlab.org/2019/01/here-are-12-principles-journalists-should-follow-to-make-sure-theyre-protecting-their-sources/) > >* “Investigative Journalism: How to Develop and Manage your Sources”, Al Jazeera Journalism Review: [https://institute.aljazeera.net/en/ajr/article/investigative-journalism-how-develop-and-manage-your-sources](https://institute.aljazeera.net/en/ajr/article/investigative-journalism-how-develop-and-manage-your-sources) > >* “Media Defense Guide for Investigative Journalists”, Media Defence: [https://gijn.org/stories/legal-help-for-journalists/](https://gijn.org/stories/legal-help-for-journalists/) (see more resources from Media Defense here: [https://www.mediadefence.org/resource-hub/](https://www.mediadefence.org/resource-hub/) > >* “The Perugia Principles for Journalists Working with Whistleblowers in the Digital Age”: [https://whistleblowingnetwork.org/WIN/media/pdfs/Journalism-Sources-INT-Blueprint-2018-Perugia-Principles-for-Journalists.pdf](https://whistleblowingnetwork.org/WIN/media/pdfs/Journalism-Sources-INT-Blueprint-2018-Perugia-Principles-for-Journalists.pdf) > ### 9. Show empathy in interviews When interviewing vulnerable sources, traditional journalistic approaches — like quickly shifting between topics — can inadvertently inflict further harm. Instead, a more deliberate and structured interview approach is crucial. Before a sensitive interview, it's vital to carefully plan the progression of your questions. The goal is to guide the source through difficult topics efficiently, ensuring they only have to recount painful experiences a single time. For example, a parent discussing the loss of a child should ideally only need to recall the specifics of their child's death once during the conversation. ### 10. Keep showing up Vulnerable sources often go to extraordinary lengths to provide information for investigative projects. Yet, once the research phase concludes, contact frequently ceases. This abrupt disengagement can leave sources feeling exploited, deepening a sense that they were merely a means to an end for a story, especially when their personal realities remain unchanged. Imagine a journalist who maintains daily contact with a source for weeks, only to vanish once the story is filed. This sudden absence can breed resentment and a profound sense of betrayal. Consider the devastating [Mati fire](https://greekcitytimes.com/2025/03/13/mati-fire-guilty/), which claimed 104 lives in the outskirts of Athens in the summer of 2018. Both national and international media swarmed the area. Some reporters and crews stayed and covered the tragedy for up to three months. However, as new events unfolded in Greece and elsewhere, the journalistic gaze shifted, and many moved on, never to return. My former colleague, Tasos Telloglou of Inside Story, chose a different path. He continued to visit Mati long after the initial media frenzy subsided. A year later, when we began working together on follow-up stories about the fire's aftermath, I - despite being new to the community - was granted immediate access and full trust. They didn’t know me; this was solely because I was collaborating with him. Tasos had earned that trust by consistently making the drive to Mati when no one else did. His dedication was an illuminating example of how genuine care for a community's story and its ongoing realities, in stark contrast to extractive "parachute journalism," can build enduring trust and the whole different set of investigative possibilities this can bring. ## Post-publication phase Researchers and investigative reporters tend to jump from project to project. But for the vulnerable sources that contributed to an investigation, their everyday lives continue. Even reporters who carefully follow specific steps during the pre-reporting and the reporting phase of investigative projects may overlook the importance of the post-publication phase. It is also worth keeping in mind that while veteran researchers might not feel like the days following publication are special, sources who are unfamiliar with the investigative process may feel differently. They can feel pressure, might think they have been exposed, or even regret having talked to someone. After publishing a story, keep the following steps in mind. ### 1. Share the story Is the story finally out? Send it to your sources. Don’t let them find it via social media, or hear about it from other acquaintances. Even worse, don’t let them find out the story has been published only days later. Thank them once more for their contribution to the investigation and explain to them the story’s significance. ### 2. Ask for feedback Don’t just send your sources the story and leave it at that. Ask them what they think of it. While you may not be in a position to make major changes after publication, it’s important to learn how they viewed their contribution to the story. Are their concerns properly framed in it? Do they feel that your portrayal of their reality was just? ### 3. Remain accessible Journalists and researchers often disappear after publication, which can make vulnerable sources hesitant to trust not just them, but all journalists in the future. Be reachable to your sources, follow up on their wellbeing, and do not vanish. Working with people on the move in Greece for several years now, I often have sources of stories asking me why other journalists stopped replying to messages after they had opened their houses to them, had coffee with them, or shared childhood photos with them. Sources who have experienced these ‘parachute journalists’, will find it more difficult to trust researchers in the future and will feel that they were taken advantage of or used. <hr class="thick"> #### About the author **Stavros Malichudis** is a reporter and editor. He has worked for the Agence France-Presse and inside story, and has participated in cross-border investigations with Lighthouse Reports and Investigate Europe. He’s member of Reporters United. His reports have been published in European media. He was shortlisted for the European Press Prize ‘21 and won the IJ4EU Impact Award ‘22. In 2019 he was selected as a fellow for BIRN's Balkan Fellowship for Journalistic Excellence (BFJE). He has been trained in data journalism at Columbia University in New York on a fellowship. <hr class="thick"> *Published in June 2025* |
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# Supply Chain and Product Investigations
By Mario Rautner  ```cik-in-short ``` **In Short:** An introduction to supply chain investigations including an overview of the main tools, techniques, data resources and essential precautions to take. It focuses on the main actors, stages and processes of a supply chain and includes a hypothetical step-by-step investigation. --- A supply chain is a set of steps that commodities (goods or raw materials) undergo on their way to becoming products used by consumers or industry. Stages of a supply chain can include places where products are transformed – for instance, an electronics company where circuit boards are made from transistors and copper lines – and where products change hands through transport, such as the loading of circuit boards onto a truck and their shipment to a computer manufacturing company. Supply chain investigations focus on collecting evidence to link each stage of a product’s journey, from the origin of the commodity (for example, the _**[conflict metal Cassiterite](https://en.wikipedia.org/wiki/Conflict_resource)**_ used in the solder of laptops) to the final product (the laptop itself), which can contain hundreds of different components. Supply chain investigations can be particularly impactful because they have the potential to change the behaviours of entire industries when done effectively, with thorough and reliable evidence. A _**[recent supply chain investigation](https://www.cips.org/en/supply-management/news/2018/may/unilever-suspends-palm-oil-suppliers-over-deforestation-claims/)**_, for example, alleged that a large palm oil supplier to major food companies such as Unilever, Nestle and Mars, was conducting massive deforestation and not complying with sustainable palm oil policies. As a direct result, Unilever stalled collaboration with the supplier pending further verification. In another case, in 2018, the British supermarket chain Iceland (Iceland Foods Ltd) _**[committed to removing palm oil](https://www.theguardian.com/environment/2018/apr/10/iceland-to-be-first-uk-supermarket-to-cut-palm-oil-from-own-brand-products)**_ from the manufacturing process of its own-brand products by the end of 2018. Such investigations and findings can have an impact not only on the reputation but also the financial status of the companies involved, in particular when they reveal illegal or controversial activities. Remember, something doesn’t have to be illegal for it to be considered controversial. Even the use of rabbit fur, while legal, can be problematic for a fashion brand these days. In the most successful cases, this change impacts the supply chain all the way back to the origin of the product, where it may prevent social injustice, from poor working conditions and human rights abuses to land grabbing and environmental destruction. Most supply chain investigations are carried out by journalists or NGOs, but they can also be carried out by determined independent investigators or people and communities directly affected by an issue. ## Shining a light on where our products really come from Everything around us is part of a supply chain: from the food we eat to the clothes we wear and the devices we use. But the nature of supply chains means we rarely know how commodities are produced or even where they originate. We might not always consider where our items come from, who harvested their source materials and under what conditions, whether there was exploitation or abuse at any point in the production process, or if illicit acts were carried out along the way. However, these questions might be brought to light when public controversies emerge about certain products or brands. Perhaps you live in an area where important materials are extracted or produced. These materials may then enter the supply chain of a final product through countless contracts, companies and manufacturing processes, which are often opaque or not immediately visible or accessible. Or, you might live near a forest that is being cleared and want to know whether the companies carrying out the clearing are using legal and ethical practices. The impact of such findings can be crucial in saving the forest. Of course, it is not always an investigator living in that area who will expose the truth, but having someone familiar or close by to observe or launch the quest for more information is a good start. Often a few initial questions and some raw evidence can lead to wider investigations by another group or organsation. Equipped with awareness of the risks and safety considerations, and a good assessment of what is at stake, you can also start this way. Even if you are not physically present at a location where commodities are produced or extracted, many supply chain investigations can be carried out remotely. Indeed, in most cases, elements of a supply chain are located far from the source - for example, wood processing and furniture manufacturing can take place continents away from where the forest was originally cleared. ```cik-tip ``` >**Tip: Helpful tools anyone can use to track products** > >**Barcodes:** Barcodes on consumer products can be used to identify the manufacturer, as well as additional >information about them. Though barcodes are most familiar to us from a retail environment, they are also >used in many other areas of business. In retail, the most commonly used barcodes are the _**[European >Article Numbers / EAN](https://www.gs1.org/standards/barcodes/ean-upc)**_, which are usually 13 digits and >used both >within and outside of Europe; and the 12-digit Universal Product Code (UPC), which is very similar to the >EAN, but contains a zero at the beginning to signify registration in the USA or Canada. The first three >digits of an EAN indicates the name of the company that accepted the registration of the code (note that >the location of the company may be, but not necessarily, the same as the location the product was >manufactured). Companies that accept registration are members of the GS1 non-profit organisation, which >maintains the global standard of barcodes. The [GS1 website](https://www.gs1.org/) has a _**[searchable database](http://gepir.gs1.org/index.php/search-by-gtin)**_ of many (but not all) barcodes. In some cases >this is useful for obtaining information on who registered the product, and can also reveal details about >a company's ownership structure. > >**Food hygiene labels:** >EU rules regarding _**[food hygiene](https://ec.europa.eu/food/safety/biosafety/food_hygiene_en)**_ cover >all stages of the production, processing, >distribution and sale of animal products intended for human consumption. This includes, for example, fish, >meat and dairy products, but also non-food animal byproducts such as pet food. Every individual >establishment or outlet (rather than the parent company) that puts such products on the market has to have >a registration number that uniquely identifies it. The codes can be found on the product label and consist >of a combination of letters and numbers within an oval. Have a look at a product at home to see how easy it >is to spot the label. The EU has an online database of the codes, making it possible to identify the name >of the company that put the product on the market. Since the regulation covers imports and any processes >that take place in the EU, the database includes details of companies from over 80 countries. This comes in >very useful if you’re investigating the chain of custody of a food product manufactured by a large consumer >company on a contract, or a brand owned by a supermarket. In such cases, you can identify the actual >producer rather than the brand owner. ## What makes a supply chain investigation  As you prepare for your investigation it’s important to have an informed idea of what is possible to achieve, what is relevant and what may be out of reach. Supply chains are not always simple; they are often complicated networks or webs of actors, processes and movements. While it takes thousands of links in multiple supply chains to manufacture one laptop, investigations usually focus on very specific components of a supply chain, such as the source of one single element used in the manufacture of one part of the laptop, or a single factory where one stage of the production takes place. Maintaining such a focus makes the research more effective. Supply chain research can be instrumental in linking a company to ethical issues that taint their products, even though the physical components of the product itself may not be controversial – for example, the violation of indigenous land rights that often occurs when producing rubber for car tires. A key concept to remember about supply chains is **traceability:** the passing of information from one stage in the supply chain to the next. This can relate to the initial source of the ingredients or raw material of a product, the alterations it incurred along the way, or other relevant details that may help trace an entire history of transportation and production. Some companies have systems for this but many supply chains are so long and complicated that it can be difficult even for the companies directly involved to achieve a fully traceable supply chain. Sometimes, **certification schemes** are used to ensure that products are manufactured, produced and traded following specific standards. For instance, they can indicate that the human rights and traditional land rights of local and indigenous people are observed or that no tropical forests are cleared to make a specific product. Well known certification schemes include those for organic and fair trade produce or for sustainable timber, palm oil or coffee.  *Fairtrade certificate logos. Image from Pinterest: https://www.pinterest.com/pin/110619734567839836/* In order to carry out supply chain research, it is necessary to get a good understanding not only of the product you are trying to track and its production prices, but also about **company finances** and **trading** and **transport processes** in different countries. **Re-evaluate** your assumptions and **verify** your data at every step. As with any investigation, you should always question your initial assumptions and results in order to make sure that the information you collect is relevant to what you intended to prove. What at first appears likely may in fact have another explanation. For instance, you might have linked a company illegally clearing forests to a timber mill that sells to a furniture company, only to find out that the furniture company does not actually use the timber species harvested from the forest in question. You therefore cannot make a direct connection between the company and the illegal deforestation activity. The **flexible** and **unpredictable** nature of supply chain research also means that it is not always possible to anticipate how long your research will take. Sometimes linking two processes can take a day of online database work; sometimes it can take months and dozens of research strategies and tools, including online and field research. Due to the complexities of supply chain research and the legal, ethical and safety risks involved in accusing large corporations of wrongdoing, if you decide to conduct this kind of investigation, it’s best to take your time to slowly expand your skills and understanding of supply chains. Starting with basic searches and testing some of the tools and techniques we present here would be an easy way to introduce yourself to the field. How and where do I start? ------------------------- You can start your investigation at any point along the supply chain where you suspect unethical or illegal behaviour might be taking place. In most cases, investigators follow the trail downstream along the supply chain from this entry point. For instance, if an investigation starts at a mobile phone assembly plant suspected of using child labour, it will most likely continue downstream to the brand that sells the mobile phones, rather than upstream to the origin of the plastics and metals used in the phones’ manufacturing process. The focus here will be to expose illegal and unethical practices of exploiting children to produce that phone. In some cases, however, research can occur upstream. An example might be the case of an ill-famed company establishing a manufacturing plant in a town whose residents want to find out if the products and commodities entering the plant are of controversial origin. Once you identify an entry point, you can follow a sequential path along the supply chain to collect evidence connecting each step, be it along a production process or a product’s transport path. That said, your research will most likely be nonlinear, and you will have to use multiple tools. Depending on what you are investigating, your work will involve extensive online research, and sometimes field research. You might need to use anything from maps to identify the source locations of raw materials or interactive transport tracking services to follow commodity shipments, to online customs and product databases or corporate records and stock exchange websites to learn more about the products and companies you are focusing on. You might also sometimes undertake field research and collaborate with others to collect evidence and witness accounts about what happens on the ground. Remember that companies tend to tightly guard information about their suppliers and customers to avoid exposing their internal mechanisms and advantages to their competitors. Companies also sometimes hire investigators to research the supply chains of competing products and of other companies. Good supply chain investigators look for evidence that links the chain, and this often requires a lot of creativity since no two supply chains are the same and access to information can vary vastly depending on the data sources available or the geographies where research is being conducted. The ability to ‘look sideways’ by making previously unseen connections is a critical skill, as is being able to come up with innovative solutions to research problems. ## Mapping and profiling actors When thinking about supply chains, a useful first step is to understand the various actors – the participating companies or individuals – that operate along the way. While the actual chains are usually unique combinations, some of the actors can be categorised into groups, which are often connected by shipping or transport providers. Most often, along a supply chain you will encounter the following: ```cik-definition ``` > **Producer:** company, person or group of persons > that takes, grows, mines or otherwise produces the raw materials (such > as the owner of a timber plantation). > > **Initial processor:** company that carries out the first > transformation of the product (for instance, a timber mill turning a log > into planks). > > **Further processors:** companies that carry out additional > transformations of the product (wood can ultimately even turn into fiber > for textiles). In many supply chains there are multiple further > processors, while other supply chains may not have any. > > **Importers, exporters, distributors:** companies responsible > for getting the products into different countries, by operating or > hiring shipping or trucking services to carry the products (for > example, shipping the wood planks to a deposit in country X, from where > it can be sold to furniture manufacturers and others). > > **Manufacturers:** companies that carry out the last > transformation before the product is sold to consumers or industrial > users (such as the company making furniture or toothpicks). > > **Retailers:** companies and individuals responsible for > selling the products to consumers or industrial users (like a hardware > shop or furniture store).  *Simplified example of supply chain actors and their connections* Let’s assume you’ve chosen your entry point in the supply chain: for example, a local fabrics manufacturer where you suspect that workers are mistreated and underpaid, and you want to find out what fashion brands buy these fabrics and where they are sold. You’ve also mapped the actors you will focus on: the manufacturer and the retailer (plus, potentially, the final consumers), so you can raise public awareness about your investigation findings. Now you know what and whom you are investigating. The next step is to establish a list of companies and people of interest – your actual actors. Before you move any further, begin by researching their company ownerships, business models, networks of collaborators, places where they are registered and/or operate, products they manufacture or sell, and possible controversies surrounding them already. By doing this background research you create a profile of your main actors and their connections, build your foundation for further investigation, prepare yourself for interviews with relevant people (sources, witnesses, specialists etc.), establish connections and assess your potential risks. Internet research is a good place to start looking for basic information about businesses and people associated with the companies in the supply chain you're investigating. Try to find out as much as possible from companies’ websites and activity reports, supply chain due diligence reports (if available), stock exchanges (if the company is listed), media articles or social media profiles of the company, its board and staff. At the same time, look for official documents that include the companies’ registration data, shareholders, subsidiaries, members of the board, directors, annual financial reports and other relevant details. If you already know in which countries to look for official documents, you can start by checking available online corporate registries and other official databases, such as land records, court records, patent registries etc. There are a number of platforms to help you start this research. Some corporate registry websites may seem intimidating at first, but don’t be daunted: there are more user-friendly, convenient and extremely helpful ways to get introduced to the company research field. _**[The Investigative Dashboard](https://id.occrp.org/)**_ (ID) is a resource built by the [Organized Crime and Corruption Reporting Project](https://www.occrp.org/en), providing a global index of public registries for companies, land and courts. From this platform you can go to the country and type of records you want, but note that while some corporate records provide free access to basic or more advanced information, many will require registration and fee payments in order to provide detailed company records. ID often marks the resources as free or paid for, so you know what to expect. In addition, the platform allows investigators to freely search and use its _**[database](https://data.occrp.org/)**_ of millions of documents and datasets from public sources, leaks and investigations it has conducted in the past. Chances are that you might find good leads in there too.  *Investigative Dashboard database: https://id.occrp.org/. Screenshot by Tactical Tech.* There are other similar resources where you can continue and expand your research. _**[Open Corporates](https://opencorporates.com/)**_ is a platform that lets you search freely for company records and related data it collects from all over the world. [The International Consortium for Investigative Journalism (ICIJ)](https://www.icij.org/) runs the _**[Offshore Leaks Database](https://offshoreleaks.icij.org/)**_ a massive resource of company records and other useful documents that have been revealed by large leaks and projects the group has been working on, including the Paradise Papers, Panama Papers, Offshore Leaks and Bahamas Leaks. Do not forget about the power of social media, and especially professional networks such as LinkedIn, where you can search for people and companies as well as identify possible connections among your subjects of interest. Elsewhere in this kit, you can learn how to build a strong body of evidence, how to investigate companies and people, how to do online and offline research and how to use various tools and techniques such as maps, social media, interviews etc. You can combine resources and develop new skills with each issue you investigate, based on the demands of your particular context, while also making sure to remember the safety and ethical considerations that go hand in hand with your plans. ## Inspiration and guidance: a sample investigation This section uses a fictitious example to show you the kinds of tools and approaches you might use to carry out a supply chain investigation. While the example is relatively realistic, the [chain of custody](#term-chain-of-custody) has been simplified and shortened for the sake of illustration. Unlike the product itself, chain of custody research cannot follow a simple research recipe, so the goal of this example is to demonstrate the need to think creatively and adjust to each specific case. ```cik-note ``` >**Note:** all the names of the entities involved are fictional, and >any relation to real companies or products is coincidental. ### Sparked by a story of injustice You read a news report that details how villagers in a South American country have been rounded up at gunpoint and forced to work in a bauxite mine run by a company named Brown Gold. You want to find out if the minerals from the mine are being used in well known consumer products. You start your investigation by focusing on the supply chain at the point where the mineral leaves the mine or company warehouse. This is your entry point. Initially, you might begin with simple online research. Keep in mind that this case could be sensitive, so it’s useful to familiarise yourself with and start using some digital security tools, such as the [Tor Browser](https://www.torproject.org/projects/torbrowser.html.en), [DuckDuckGo](https://duckduckgo.com/) search engine or a [VPN](#term-vpn) (Virtual Private Network), to avoid being tracked. Your search does not yield much more than the name of the company itself, but in the process you gather additional information, such as the company’s registration number and the names of the founders and key people in the company. You also carry out online research and ask some specialists you trust on related subjects such as: - The uses of bauxite (as a main source of aluminium). - Detailed information about the aluminium production process and its impacts. - The largest companies involved in global bauxite and aluminium production. - The main uses for aluminium in industry. ```cik-example ``` >**Example of online research entry points:** > >In many instances, [Wikipedia](https://www.wikipedia.org/) provides useful entry-level information and links to external sources that you can check for more in-depth knowledge. Specialised websites that focus on the particular minerals are helpful for understanding the field and its main players. >In this case, for example, a DuckDuckGo (or a Firefox, Google etc.) search for “aluminium and bauxite” leads you to pages like that of [Geology.com](https://geology.com/minerals/bauxite.shtml), >[Aluminum.com](https://www.aluminum.org/industries/production/bauxite) (Aluminum Association in the US), [Australia’s Aluminum Council](https://aluminium.org.au/interactive-flowchart/bauxite-mining-chart/) and many others, where you read about the production process and uses of this resource. > >Searching for “bauxite producers world 2019,” for instance, takes you to information on the current _**[top bauxite producer countries and companies](http://www.thedailyrecords.com/2018-2019-2020-2021/world-famous-top-10-list/world/largest-bauxite-producing-countries-world/6882/)**_. > >Searching for “aluminium producers world 2019” leads you to other resources such as a [map and downloadable database](http://www.world-aluminium.org/statistics/) of top aluminium producers from international institute [World Aluminium](http://www.world-aluminium.org/) and additional data from statistics aggregator [Statista.](https://www.statista.com/statistics/280920/largest-aluminum-companies-worldwide/) ### Investigating the key players Your preliminary online research provided key information about the products and actors at the centre of your investigation; enough to build some background knowledge and basic details about your topic and main subjects (producers, buyers etc.). You then continue by mapping your actors and the connections between them – who is the producer, who delivers the commodity to whom, by what means etc. – and following the supply chain downstream from your entry point. #### The Producer: MINING COMPANY Since the company – Brown Gold – is mining the resource, it is considered the producer of the commodity. By using the resources mentioned above, you can gather various types of information to get a better understanding of who Brown Gold is: - Physical company operations and locations – source: maps and satellite images (potential transport routes). - Type of company (private, public and, if so, shareholders, etc.) – source: company registries, stock exchange, website information. - Financial information – source: company filings, annual reports on company’s website, stock exchange (if the company is listed on any stock exchange). - Registered office addresses (used for formal purposes, e.g. where mail can be received) and trading or operational addresses (where actual activities occur) – source: online and offline corporate records, company’s website. - Board members and directors (and any other businesses they might be involved in) – source: company registries, company website, company and people databases (see above for Investigative Dashboard and other resources) - Bank connections, loans, mortgages – source: corporate records, court records, annual financial reports. - Employee feedback, reviews and grievances on sites like [glassdoor.com](https://www.glassdoor.com/Reviews/index.htm), [comparably.com](https://www.comparably.com/), [careerbliss.com](https://www.careerbliss.com/), sometimes yield information about the company. - The current careers or job opportunity page and archives of job postings from _**[archive.org](https://archive.org/web/)**_ may yield information about projects, locations, and future plans of the company. ```cik-note ``` >**Note:** > >Carefully searching through company reports and other documents can lead to very useful findings. >Annual reports, corporate sustainability reports, company presentations and shareholder filings can all be useful not only for basic information on a company and its finances, but also, in some cases, about its customers (photos within these reports can be especially useful for this). > In this case, you find the location of the company on satellite images and identify its board members and directors, but cannot find any further information about them. Nor have you found detailed financial data or names of any customers of the company. Searching through company records and annual reports, you do, however, manage to find a subsidiary (a company owned and controlled by another company) of Brown Gold, by the name of BG Shipping. #### The Initial Processor: ALUMINIUM SMELTER From your initial online research you found out that bauxite is used to manufacture aluminium, which in turn is produced in large smelters (facilities where the metal is extracted by heating and melting the ore). You also discovered that smelters are massive investments – to the extent that there are fewer than 150 of them globally. This information will help you in your investigation, because it offers a relatively narrow field of inquiry. In order to find one of the smelters that is supplied by Brown Gold, you use a process of elimination to rule out certain routes, while looking for likely connections between the mining company and certain smelters. Examples of investigation activities to do this include: - Finding out if there are any smelters located in the country the mine operates in – there are none. - Identifying other bauxite mines in the country – you find three more. - Analysing whether this country exports any bauxite overseas using the UN Trade database [Comtrade](https://comtrade.un.org/) -- you find that six countries received bauxite. So far you know of four mines in total; this means you can’t yet determine which country is supplied by Brown Gold.  *Sample comtrade.org search. Screenshot by Tactical Tech.* In order to identify the smelter, you need to first determine the country that receives the bauxite. With a relatively simple online search (e.g. "how is bauxite transported") you learn that bauxite is most commonly transported by ships or trains. You carry out further online research, and check transport routes and map locations (using Google Maps or Google Earth) to map out deepwater seaports. Then, by looking at the train lines between the four mines and the location of the mines to each other, you conclude that Brown Gold is most likely exporting its bauxite using ships. Moreover, you previously identified the BG Shipping subsidiary and were able to locate its warehouses on the map at a port that is connected to Brown Gold via train track. You can therefore conclude with even higher certainty that the company exports its bauxite from this port. #### The Trader: SHIPPING COMPANY Today, the majority of commodity-carrying ships are fitted with live tracking devices, which employ what’s called an Automatic Identification System (AIS). All vessels over 300 tonnes (gross) are required by law to emit radio signals with their speed, direction and exact location. This data is also captured by receivers on other vessels and by stationary receivers in ports and on coastlines. Services such as _**[Marine Traffic](https://www.marinetraffic.com/)**_, _**[Vesseltracker](https://www.vesseltracker.com/)**_, and others use AIS information to produce live maps showing the movement of ships across the globe. To search the map, you need to know the name or registration number of the vessel you are tracking. For additional resources and depending on your needs, other tracking services may be of further help, so reviews like this from [Marine Insight](https://www.marineinsight.com/) - _**["Top Eight Websites to Track Your Ship"](https://www.marineinsight.com/know-more/top-8-websites-to-track-your-ship/)**_ - may help when looking for alternatives. Most of the ship tracking services either have a free version or offer a free trial, which can be used to track these vessels. They also tend to employ their own network of receiver stations and have maps on their websites that indicate the network coverage. MarineTraffic, for instance, provides near real-time information about vessels’ positions and voyage-related information. In addition to the AIS receivers, which are ground-based, Marine Traffic (and other such platforms) also collects vessel data from satellite receivers. Obtaining this data often requires paying a one-off fee or signing up for yearly subscription, which is usually cheaper if you plan to use it longer.  *Sample MarineTraffic.org search. Screenshot by Tactical Tech.* ```cik-Tip ``` >**Tip:** > >Always search more than one vessel-tracking website to trace the same ship, as some platforms may provide >you with more free information than others, and some may have the data you need while others may not. If there is an area of particular importance to your investigation that is not covered by these services, it’s even possible to buy your own receiver online, from places like Amazon or specialised websites such as _**[Milltech Marine](https://www.milltechmarine.com/)**_. If this is the case, do some serious research first: check what range you need to cover, what other users recommend, verify equipment reviews, consult forums like _**[ShipSpotting](http://www.shipspotting.com/)**_ and maybe even check with some vessel tracking enthusiasts for advice and recommendations. ```cik-note ``` >**Note:** > >Taking this route requires some financial cost, a stable Internet connection and power supply in the place where you are installing the receiver, knowledge of how to use the equipment and some extra effort to maintain it. However, if it helps to advance your investigation and you have no other options, it’s well worth the relatively short time it takes to learn and experiment. Marine Traffic provides useful advice for such situations in its [FAQ section](https://help.marinetraffic.com/hc/en-us/articles/205326387-What-is-the-cost-of-an-AIS-Receiving-Station-). >The website also offers free receivers to those who want to contribute to its [live map](https://www.marinetraffic.com/en/p/expand-coverage), but that requires you to share your receiver’s data >with the platform, something you might or might not want to do, depending on how sensitive your >investigation is. If you decide to go ahead and operate a receiver, you also get a free subscription plan, or an upgrade to your existing account. After deciding which tracking site(s) to use, you spend several weeks mapping out the journeys of vessels that appear to have been loading materials at BG Shipping. Ships that spend several hours berthed right next to the BG Shipping facility in the port are more than likely loading or unloading. You can track journeys of vessels by saving their movements on some of the above mentioned online platforms. In Marine Traffic, for example, you can create your own "fleet" of vessels to monitor and get updates on, or set up notifications when a vessel reaches a port. You can also access past travel information in the database - a service that is sometimes free, other times for a fee. Eventually, by tracking these ships, you identify three ports in three different countries across Asia that received exports from BG Shipping. This means that, at the very least, three separate smelters bought bauxite from the Brown Gold mine. Using Marine Traffic you manage to show that a vessel that left BG Shipping went directly to the port facility of a company called Caliper Alumina. You conclude that Caliper Alumina is one of the smelters receiving bauxite from Brown Gold mine. Think back to your earlier research, when you identified and mapped smelters, their transport routes, subsidiaries, key personnel, addresses and finances. You can now apply the same techniques and resources to find out more about Caliper Alumina and its activities. ```cik-tip ``` >**Tip:** > >Vessels sometimes make multiple stopovers. It’s also not always clear from sites like Marine >Traffic whether a vessel is loading or unloading. Look for additional information about the vessel’s draught (the depth its hull is submerged into the water), which provides another indicator of whether it has been loading or unloading (the higher the draught, the heavier the ship). > #### The Further Processor: CAN PRODUCER In this example, you can use another resource, namely *customs data*, to try to identify one of the customers of Caliper Alumina. Customs data consists of shipping manifests, which every shipment vessel is legally required to carry while it travels around the world. Governments collect this data in order to produce their trade data statistics. It’s possible to purchase this data, but doing so is expensive and only available for a limited number of countries. Generally it provides the name of the importer and exporter – so if one country in the trade does not make customs data available for purchase, you may be able to get the same information from the other country involved in the transaction. The cost of purchasing customs data has decreased lately, in line with a growing number of companies offering it for sale. Examples of such services include [Trade Atlas](https://www.tradeatlas.com/en), [Export Genius](https://www.exportgenius.in/export-import-trade-data/), [Xportmine](https://www.xportmine.com/), [ListThe](https://www.listthe.com/), [Panjiva](https://panjiva.com/) etc. The first step in this process is knowing which data to buy, and to do that, you need some context and background information. Products are usually organised by HS (harmonised system) codes, a nomenclature developed and maintained by the _**[World Customs Organization](http://www.wcoomd.org/)**_(WCO). The codes are organised into 21 sections, which are subdivided into 97 chapters, in turn further subdivided into several thousand headings and subheadings. The most recent HS codes edition, which we use in this section as of 2019, is [the 2017 HS Nomenclature](http://www.wcoomd.org/en/topics/nomenclature/instrument-and-tools/hs-nomenclature-2017-edition/hs-nomenclature-2017-edition.aspx) (note that a new one will come into place in [2022](http://www.wcoomd.org/en/topics/nomenclature/instrument-and-tools/hs-nomenclature-2022-edition.aspx)). **Here is how it works:** Usually each subdivision comes in a two-digit increment. The case in our example: Section XV "Base Metals and Articles of Base Metal" lists a series of chapters numbered from 72 to 83. - Chapter 76 is Aliminium and articles thereof. This is followed by 16 headings, for example: - Heading 7606: Aluminium plates, sheets and strips... - Heading 7612: Aluminium casks, drums, cans, boxes and similar containers (including rigid or collapsible tubular containers), for any material (other than compressed or liquefied gas), of a capacity not exceeding 300l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment. - Subheading 7612.10: Collapsible Tubular containers.  *Base metals codes from World Customs Organization wcoomd.org. Screenshot by Tactical Tech.* When buying customs data, most of the time it is necessary to know the HS codes of the products in question. Often HS codes are defined down to eight or 10 digits, but at these levels the classification is usually set by the countries rather than the WCO. In addition, codes are reviewed and sometimes adjusted every few years, including those of the World Customs Organization above, so make sure you stay updated. ```cik-note ``` >**Note:** > >Each product and shipment that enters a country has an HS code attached >to it, so both domestic and international trade statistics are usually >based on those HS codes. For instance, the United Nations maintains the >_**[Comtrade database](https://comtrade.un.org/)**_, which contains such statistics - >[comtrade.un.org/data](https://comtrade.un.org/data) - that can also >prove useful for chain of custody investigations. In many cases, customs data comes in spreadsheets and often contains false positives or multiple spellings for the same company name. Depending on the purpose of your investigation, you might need to clean the data, especially for statistical analysis. The details of the data vary depending on the country that supplies it, but it usually includes: - the names of the exporter and importer, - the date of the shipment (at least the month), - the weight of the shipment, - the HS codes, - the port of loading, - the port of discharge. Additional data fields can include addresses, phone numbers, detailed product descriptions, the value of the shipments, the name of the vessel and shipping company, as well as the names and addresses of notifying parties (the buyer or importer who receives notice of the shipment’s arrival). In this case, the data shows that a US company by the name of Beverages Inc. purchased aluminium sheets from Caliper Alumina. You also find a number of older shipments made by that company, which you are able to verify with historical Marine Traffic data, by tracking the vessel’s past movement as detailed above. You also notice that the Beverages Inc. website features photos that show cans of soft drinks produced by prominent brands. #### The Manufacturer: SOFT DRINK COMPANY One of the companies whose cans are displayed on the website of Beverages Inc. is called Spark Drinks. While you might be tempted to link this well known brand to the controversial bauxite producer, more research is necessary to ensure that this supply chain is indeed linked. There are various reasons why they may not be connected. There could, for instance, be different grades (strength, concentration) of aluminium in different lines of cans used for different brands. So, there is a chance that Sparks Drinks may not be using the aluminium made from the bauxite sourced from Brown Gold’s mine. This is where the problem of *traceability* emerges. ```cik-note ``` >**Note:** > >Supply chain *traceability* is a process and technique that ensures the >integrity and transparency of a company’s supply chain, by tracking >products from origin to consumer. This reduces the risk of mislabelling >commodities that have been mixed from different suppliers and regions, >allows products to be tracked back to their source and helps identify >particular batches of the product if something goes wrong and products >need to be tested or recalled, etc. Traceability is a key challenge in >supply chains. > >In certain cases, however, commodities and products are *segregated* >(they have their *identity preserved*), which means that companies can >trace the product and its components all the way back to the origin and >the producer. This segregation is often required for certified products >(e.g. those who must meet strict quality standards) and animal products >(for instance, to identify farms in case food safety issues arise). > >In most instances, though, raw materials or components from different >sources (e.g. from different mines and suppliers) are mixed together at >various points in the supply chain. The result is that, due to a lack of >segregation and traceability, most companies do not know for sure >whether they are connected to actors involved in illegal, unethical or >controversial activity. From an investigator’s point of view, this means >that all actors downstream of where the mixing occurs are part of the >supply chain in question. > >For companies, traceability is important for a number of reasons. These >include compliance with policies of sustainable sourcing (for example, >making sure they do not contribute to famine, drought or environmental >damage) or with conflict minerals regulations implemented by various countries, which impose strict rules >on the purchase and use of commodities obtained from areas controlled by >armed groups or where abuses take place. Such aspects are important for a company’s accountability >to regulatory authorities and to their consumers. There are a number of research techniques you can use to find out if mixing occurs along the supply chain. Sometimes the *company information* (websites, public filings) includes details about where the company purchases commodities from and if it keeps a detailed log of its own supply chain from the sourcing of materials until the point these reach its ‘hands’. In other situations, searching online for *scientific articles* or other investigations on your topic or commodity of interest, as well as more general magazines such as _**[Supply Chain Quarterly](https://www.supplychainquarterly.com/)**_, and available *industry* *research* might shed light on how the sector operates in general. In addition, NGOs like [Greenpeace](https://www.greenpeace.org/international/), [Rainforest Action Network](https://www.ran.org/), [Rainforest Alliance](https://www.rainforest-alliance.org/), [Mining Watch](https://www.miningwatch.ca/) and many others already conduct research on various supply chains and their impact on human rights, the environment, and the wellbeing of communities living and working along the chain. Contact them for advice if you find their knowledge useful. ```cik-tip ``` >**Tip: using NGO reports** > >The techniques and resources outlined here are often used by >NGOs working to pressure companies into changing their ways of >production or cleaning up their supply chains. NGO reports can offer >insightful and inspiring examples of how such tools have been used in >conjunction with other supply chain research techniques. When reading reports, keep in mind the >mission of the NGO. Some of the language >may not be appropriate for investigators or journalists and some texts are >designed for advocacy and policy purposes. However, it’s an interesting >exercise to try and figure out how the research was carried out and what >investigation tools and strategies were applied. Also look out for *trade and industry magazines* and websites that profile the way your company of interest operates (see [supplychain247.com](https://www.supplychain247.com/), for example). However, keep an eye out for articles and research that appear one-sided or solely focused on positive angles – this is a strong clue that they may be sponsored by the very companies you are investigating, and thus not always reliable or complete. Search multiple sources and read as much as possible to create a complete picture. You might also consider *talking to industry experts* or even to the company itself. ```cik-warning ``` >**Warning:** > >Before talking directly to the company of interest, you should conduct >thorough background research on their operations, and be prepared to ask >highly relevant questions rather than details you might already find >elsewhere. If you plan on accusing the company of something, it makes >sense to avoid telling them so, or even closely hinting at that, before >you’ve gathered solid proof. Powerful companies will go a long way to >make you stop your research, try to discredit you or sometimes even >threaten you with legal action or other types of >pressure. Now, back to our scenario. You find out from industry magazines that mixing occurs at the aluminium smelter and that all products leaving the smelter contain bauxite from various sources. Since this question is crucial, you also confirm it by carrying out interviews with industry experts and eventually also with representatives of the smelter itself. This means that any product containing aluminium that originates from the smelter, including the products of Spark Drinks, is potentially contaminated with bauxite of controversial origin. #### The Retailer: SUPERMARKET In this supply chain, the last step of identifying retailers that sell the products to consumers is relatively simple, since most retailers in your country have online stores and stocked products can be found via the retailer websites – as well, of course, as in person by visiting the stores. This allows you to complete the supply chain and link the bauxite to a number of major supermarket chains. ### Loose ends and further questions Even though the case study ends here, there are many potential questions still to be answered to increase your certainty in the information. These include: - Are the customers listed by Beverages Inc. still up to date? - Is it possible that the bauxite and aluminium are of grades that rule out the smelter you identified, and thus render the particular chain impossible (and therefore another smelter would have to be identified)? - Does Beverages Inc. export to other countries? - Are there ways to confirm the supply chain links using other research techniques or further verify the results you obtained so far? You can employ numerous different research techniques to identify customers of the aluminium smelter and, depending on how many more transformations take place, there may still be more chains to uncover before you reach the final consumer product. For electronic products, it is likely that the aluminium will change hands many times before it can be found (unrecognisable in shape and form) in a store. In some cases, due to the nature and complexity of supply chains, you’ll have to invent or significantly adapt the research techniques as you go. ## Risks and considerations Supply chain research often comes with significant risks, many of which depend on both the research strategies employed and the geographies in which they take place. Because this type of research is often connected to and can effect the profits, loss, and earnings of companies it makes sense to have an understanding of how to secure your research and work pseudonymously. If you decide go public with your findings timed release of key research (instead of releasing everything at one) is a method of dealing with crisis management and public relations teams. Developing a methodical and meta data preserving way to catalog data, notes, research and files is key. Developing a workflow that involves having an encrypted backup is recommended. If you are technical, look for ways to split decryption keys into _**[(Shamir Secret) Shards](https://en.wikipedia.org/wiki/Shamir%27s_Secret_Sharing)**_. This allows you to split the key into several pieces, and only if a certain number of pieces come together does the key reform. Look at projects like [ssss](http://point-at-infinity.org/ssss/) and [storaj](https://storj.io) for examples. Hashes of these shards can be used to create so-called "insurance files" which may be of use to the investigator, however is out of scope of this section. ### Safety concerns Successful supply chain research often requires field research in addition to online data collection and shipments tracking. Field research can be high-risk, especially in some areas where corruption is rife, where investigators and journalists have little protection, or where violence occurs frequently. This kind of work is usually carried out in teams and under detailed plans for physical and digital security. High-risk work should only be undertaken by experienced investigators. ### Data access Companies usually have multiple customers and suppliers, often hundreds. There are, therefore, many forks in the road when it comes to following the trail of the products you are investigating. Make such choices carefully and base them on knowledge, facts and information rather than on gut feelings. An assessment of the difficulty of research and operating in specific jurisdictions for instance is a rational way of making such decisions. It is important to give special consideration to supply chain bottlenecks (for example, a blockage in the chain caused by shortage of a commodity or increased demand), where only a small number of companies may have overwhelming market shares. For instance, a handful of traders now dominates the global trade of agricultural commodities. In most cases it is not possible to prove the supply chain for a specific product all the way to the end product. This diluting of the chain is common and is not necessarily a concern. For example, it would be very difficult to show that one harvest of coffee beans from a smallholder (a non-industrial farmer harvesting a small area) who has illegally cleared forested land, ends up in instant coffee products of a large consumer brand company. However, it might be possible to prove that the smallholder sells to a specific agent, who sells the coffee to a company where the beans are collected and washed. This company in turn sells to a processing and packaging company that ships the coffee overseas to an importer, who passes it on to the coffee roasting and grinding company, which in turn sells it to a large consumer brand that packages the instant coffee products, which are sold in supermarkets around the world. In this scenario, the coffee coming from the illegal plants can never be traced directly and has been mixed with coffee from many other plantations, yet the consumer brand is still exposed to the problem because it is part of the supply chain. ### Legal issues Supply chain research requires a very high standard of proof. If the evidence at any point of the chain is not strong enough, additional investigations are required to corroborate your theory or conclusion. This type of investigation often ultimately exposes very large corporations for whom reputation is as valuable as the products themselves, and they often respond strongly when their reputation is under threat. Be aware that it is not uncommon for lawsuits to ensue from investigations on supply chains, and there are significant risks for investigators even when the information they provide is accurate. Supply chain investigators frequently obtain legal advice before publishing the results of their work, which often exposes powerful companies and shady practices. Investigators may find themselves accused of libel or slander; countries have different laws and potentials for legal issues so asking for legal opinions is useful even if only as a precaution. Organisations and individuals engaged in this research can also face SLAPP (Strategic Lawsuit Against Public Participation) suits. These are designed to use the companies’ large funds to engage investigators in lawsuits in order to intimidate them and delay or stop them from carrying out their work, even if the lawsuit has very little or no legal merit and chance of success. ### Collaboration In order to avoid or mitigate many of the risks above, investigators often collaborate with others doing similar work, including asking for advice and best practices on physical and digital security. Collaboration is particularly advisable when investigating certain topics for the first time, and additional knowledge and expertise is required. Don’t shy away from asking questions to trustworthy organisations and people, and avoid the temptation of trying to take down a company with your very first investigation. Collaboration also help share the workload, so you don’t have to follow the entire supply chain by yourself, but instead work with local communities, experts, NGOs and others to collect stronger evidence and reach a more impactful result. Some countries may have freedom of information laws which allow citizens of that country access to information not available to the investigator. It may make sense to collaborate with a citizen who can access other information and at lower risks. When collaborating it makes sense to take extra care to encrypt files/folders and get hashes (fingerprints) of files to look for changes. The kind of "source control" software a developer uses ([github](https://github.com/), [bitbucket](https://bitbucket.org/product), etc.) may aid you in doing this and keeping track of files, edits, and ownership. When working in a team be sure to have a secure and encrypted way to communicate. Messenger apps like [Signal](https://signal.org/en/) or [Wire](https://wire.com/) are recommended. <hr class="thick"> _Published April 2019_ ## Resources ### Articles and Guides - *[Supply Studies Research Guide: A Research Guide for Investigations in the Critical Study of Logistics](https://supplystudies.com/research-guide/)*, by Matthew Hockenberry, Ingrid Burrington, Karina Garcia, and Colette Perold, 2025. - *[Destroying elephant habitat while breaching the Indonesian Government moratorium on forest clearance for palm oil](https://www.ran.org/wp-content/uploads/2018/06/RAN_Leuser_Watch_PT_Agra_Bumi_Niaga.pdf)*, from Rainforest Action Network. A supply chain investigation report. - *[Eating up the Amazon](https://www.greenpeace.org/usa/wp-content/uploads/legacy/Global/usa/report/2010/2/eating-up-the-amazon.pdf)*, from Greenpeace. An investigation report on tracking soy from the Amazon. - *[Investigating supply chains](https://gijn.org/investigating-supply-chains/)*, from the Global Investigative Journalist Network (GIJN). A short guide including tips, resources and techniques. - *[Investigating illegal timber](https://www.earthsight.org.uk/tic/guidebook)*, from the Timber Investigations Center. A guidebook to researching timber supply chains. - *[Top eight websites to track your ship accurately](https://www.marineinsight.com/know-more/top-8-websites-to-track-your-ship/)*, from Marine Insight. A brief review including tools comparisons and tips. - *[Who's Got the Power: Tackling imbalances in agricultural supply chain](https://web.archive.org/web/20151117052506/http://www.fairtrade-advocacy.org/power/183-projects/psc-main-page/870-the-report-on-imbalances-of-power-in-agricultural-supply-chains)*, from the Fair Trade Advocacy Office (FTAO). A study about power concentration and unfair trading practices in agricultural supply chains. ### Tools and Databases - *[EAN/UPC barcodes overview](https://www.gs1.org/standards/barcodes/ean-upc)*, from GS1 non-profit organisation. A list of global standards of barcodes. - *[EU rules regarding food hygiene](https://ec.europa.eu/food/safety/biosafety/food_hygiene_en)*, from the European Commission. - *[GS1 searchable database of barcodes](http://gepir.gs1.org/index.php/search-by-gtin)*, from GS1 non-profit organisation. ## Glossary ### term-certified-product **Certified product** – a product that receives approvals and certifications confirming it abides by a set of quality and performance standards and regulations. For instance, certified organic foods are expected to be produced without the use of chemicals but also abide by specific conditions in terms of storage, packaging and transport, among others. ### term-chain-of-custody **Chain of custody** – a process that seeks to demonstrate that physical and other sorts of evidence is protected from tampering during the course of an investigation, from the point of collection to the point of publication or use in other circumstances, such as in court. ### term-commodities **Commodities** – traded goods or raw material. ### term-distributor **Distributor** – company responsible for getting the products into different countries, by operating or hiring shipping or trucking companies to carry the products. ### term-exporter **Exporter** – an actor (company, organisation, person) sending goods and materials across the border to a foreign country for trade purposes. ### term-further-processor **Further processor** – company that carries out additional transformations of a product (such as wood turning into fiber for textiles). In many supply chains there are multiple further processors, while other supply chains may not have any. ### term-hs-codes **HS (harmonised system) codes** – a nomenclature established to organise and list products for easier classification and labelling across borders. It is developed and maintained by the World Customs Organisation (WCO). ### term-importer **Importer** – an actor (company, organisation, person) bringing in goods and materials across the border from a foreign country for trade purposes. ### term-initial-processor **Initial processor** – company that carries out the first transformation of the product (for instance, a timber mill turning a log into planks). ### term-manufacturer **Manufacturer** – company that carries out the last transformation before the product is sold to consumers or industrial users (such as the company making furniture or toothpicks). ### term-producer **Producer** – the actor, be it a company or person/group of persons, that takes, grows, mines or otherwise produces the raw materials (such as the owner of a timber plantation). ### term-product-certification **Product certification** – a process of verification and approvals confirming that certain standards and regulations are met by products and services. ### term-retailer **Retailer** – company or individual responsible for selling the products to consumers or industrial users (like a hardware shop or furniture store). ### term-supply-chain **Supply chain** – a set of steps that commodities undergo on their way to becoming products used by consumers or industry. ### term-supply-chain-bottleneck **Supply chain bottleneck** – an impediment or blockage along the supply chain caused by shortage of a commodity or increased demand, and where only a small number of companies may have overwhelming market shares. ### term-vpn **Virtual Private Network (VPN)** - software that creates an encrypted "tunnel" from your device to a server run by your VPN service provider. Websites and other online services will receive your requests from - and return their responses to - the IP address of that server rather than your actual IP address. |
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