customer asks about migrant workers in the supply chain, how do I approach this

Migrant workers fall under the VSME labour module

The question about migrant workers in the supply chain is usually a more specific version of the standard question on working conditions and human rights in the supply chain. Customers ask it separately because migrant workers are considered a vulnerable group in risk analyses: higher risk of underpayment, dependence on the employer for housing and residence status, and less access to a complaints channel. So do not expect a single simple yes/no question, but a set: whether there is a policy, whether that policy specifically mentions migrant workers, and how violations can be reported.

If you do not employ migrant workers yourself and do not work with employment agencies that do, you can simply indicate that — that is a factual answer, not a policy choice. If you do work with employment agencies or subcontractors that deploy migrant workers, this falls under the broader policy on human rights in the supply chain: have you documented it, and does it specifically cover this group, or is it formulated more generally? If a specific migrant worker policy is missing, then "no, no specific policy, but general labour policy" is a more honest answer than a "yes" that does not cover the file. Also check whether your customer is actually asking for a code of conduct for your own suppliers — these two questions are often combined in the same list but require different evidence.

Basis: social sub-module of VSME

The VSME basic module asks companies to report on their own employees, working conditions and risks in the labour chain, without "migrant workers" being a separate mandatory data point — it is an interpretation that customers themselves add within the broader social reporting that the CSRD (Directive (EU) 2022/2464) expects for the supply chain. If you have no documented answer, leave the field blank or give the honest "no" — not a "yes" that you cannot substantiate.