Sarah A. Altschuller

Sarah A. Altschuller

Foley Hoag LLP

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U.K. Modern Slavery Act: New Disclosure Requirements for Companies Operating in the United Kingdom

Companies that do business in the United Kingdom should assess their exposure to the U.K. Modern Slavery Act, which goes into effect this October. The transparency provisions of the Act are applicable to companies that do any...more

8/25/2015 - Audit Policies Board of Directors Corporate Entities Disclosure Requirements Due Diligence Enforcement Human Rights Human Trafficking Injunctive Relief Modern Slavery Act Partnerships Policies and Procedures Public Disclosure Supply Chain Training Transparency Transparency in Supply Chains Act UK

H.R. 3226: New Bill Calls for Transparency on Trafficking and Slavery in Corporate Supply Chains

In late July, Representative Carolyn Maloney (D-NY) introduced H.R. 3226, the Business Supply Chain Transparency on Trafficking and Slavery Act of 2015. The bill, if passed, would require companies to file annual reports with...more

8/5/2015 - Child Labor Forced Labor Human Rights Human Trafficking Privately Held Corporations Proposed Legislation Publicly-Traded Companies SEC Slavery Supply Chain Transparency in Supply Chains Act

Alien Tort Case Development: Plaintiffs in Exxon Mobil Case Survive “Touch and Concern” Review

Earlier this month, the District Court for the District of Columbia denied Exxon Mobil’s motion to dismiss plaintiffs’ claims in Doe I v. Exxon Mobil, a case brought pursuant to the Alien Tort Statute (“ATS”). Plaintiffs...more

8/3/2015 - Aiding and Abetting Alien Tort Statute Corporate Counsel Extraterritoriality Rules Exxon Mobil Human Rights Jurisdiction Mens Rea Motion to Dismiss

Alien Tort Case Development: Second Circuit Affirms Dismissal of Claims Against Ford and IBM

Earlier this week, the Second Circuit Court of Appeals affirmed a decision in In re: South African Apartheid Litigation dismissing claims brought pursuant to the Alien Tort Statute (“ATS”) against Ford and IBM. Plaintiffs had...more

8/3/2015 - Aiding and Abetting Alien Tort Statute Appeals Ford Motor Human Rights IBM Race Race Discrimination South Africa

G7 Leaders Issue Declaration Supporting Private Sector Implementation of Human Rights Due Diligence

At the conclusion of the G7 Summit held on June 7 and 8, the assembled leaders released a declaration endorsing the U.N. Guiding Principles on Business and Human Rights. Specifically, leaders of the United States, the United...more

6/16/2015 - Human Rights Supply Chain Transparency in Supply Chains Act UN Guiding Principles United Nations

Shareholder Proposals Regarding Corporate Respect for Human Rights

Shareholder proposals filed during this year’s proxy season reflect investors’ continued concerns about the social and environmental impacts of corporate operations. The Proxy Preview published by As You Sow, the Sustainable...more

5/18/2015 - Human Rights Proxy Season Shareholder Activism Shareholders UN Guiding Principles

U.N. Guiding Principles Reporting Framework Released by the Human Rights Reporting and Assurance Frameworks Initiative

In late February, after 18 months of research and consultation, a new Reporting Framework has been released to help companies report on their human rights performance in a manner aligned with the expectations set forth in the...more

3/11/2015 - Corporate Social Responsibility Human Rights New Guidance United Nations

Alien Tort Case Development: Ninth Circuit Affirms Dismissal of Claims Against Occidental Petroleum

In mid-December, the Ninth Circuit Court of Appeals affirmed the dismissal of claims filed pursuant to the Alien Tort Statute (“ATS”) against Occidental Petroleum. Plaintiffs in the case argued that Occidental should be held...more

1/26/2015 - Appeals Columbia Department of State Dismissals Hiring & Firing Human Rights Negligence Occidental Petroleum Oil & Gas Pipelines Wrongful Death

Alien Tort Case Development: The Second Circuit Assesses the Appropriate Focus of Jurisdictional Inquiries

On October 23, the Second Circuit Court of Appeals issued a decision in Mastafa v. Chevron Corp., a case filed against Chevron Corp. and BNP Paribas pursuant to the Alien Tort Statute (“ATS”). The court upheld the District...more

10/28/2014 - Alien Tort Statute Appeals BNP Paribas Chevron Dismissals Human Rights Iraq Jurisdiction

Alien Tort Case Development: Litigation Against Exxon Mobil Corporation May Proceed

In late September, the District Court for the District of Columbia ruled that two closely related cases filed against Exxon Mobil Corporation, and several of the company’s subsidiaries, could proceed. Plaintiffs in both...more

10/1/2014 - Alien Tort Statute Corporate Counsel Exxon Mobil Human Rights Oil & Gas Popular Vicarious Liability

H.R. 4842: New Bill Calls for Transparency on Trafficking and Slavery in Corporate Supply Chains

On June 11, Representative Carolyn Maloney (D-NY) introduced H.R. 4842, the Business Supply Chain Transparency on Trafficking and Slavery Act of 2014. The bill, if passed, would require companies to file annual reports with...more

6/23/2014 - Disclosure Requirements Human Rights Human Trafficking Proposed Legislation SEC Secretary of Labor Sex Trafficking Slavery Supply Chain Trafficking Transparency

“Hardening” Soft Law and Human Rights Expectations for Financial Institutions

Earlier this month, a group of global banks known as the Thun Group released a discussion paper exploring the ways in which financial institutions might seek to integrate the U.N. Guiding Principles on Business and Human...more

11/1/2013 - Banks Corporate Social Responsibility EU Human Rights OECD United Nations

Responding to Investor Concerns Regarding Human Rights Impacts

Increasingly, companies will face explicit demands from investors, especially members of the socially responsible investor community, that they provide detailed disclosures regarding internal processes and procedures to...more

5/21/2013 - Corporate Social Responsibility Human Rights Investors

Reflections on the Evolving Business and Human Rights Agenda

As mentioned in last week’s post, participants in the Voluntary Principles Initiative recently held their Annual Plenary Meeting. The discussions began with opening addresses from Professor John Ruggie, the former U.N....more

4/5/2013 - Corporate Social Responsibility Due Diligence Human Rights United Nations

Telecommunications Companies Release Guiding Principles on Freedom of Expression and Privacy

The Telecommunications Industry Dialogue, a group of eight telecommunications companies, recently published a set of Guiding Principles on freedom of expression and privacy. Originally formed in 2011, the Industry Dialogue...more

3/26/2013 - Data Protection Due Diligence Freedom of Expression Human Rights Safety Precautions Telecommunications Training

Due Diligence on Human Rights? Consider Consulting Your FPCA Counsel.

Human rights due diligence requires many of the hallmarks of existing corporate compliance programs: clear policies; assessments of risk; and the integration of strong standards into corporate management systems. This...more

2/8/2013 - Compliance Due Diligence FCPA Human Rights

Looking Ahead: Five Developments We’ll be Watching in 2013

As memories of New Year’s Eve fade, and another Inauguration Day winds down in Washington, D.C., it’s time to look ahead and identify key events and emerging trends that we think will help shape the business and human rights...more

1/22/2013 - Alien Tort Statute Corporate Social Responsibility Due Diligence Human Rights Human Trafficking Supply Chain

John Ruggie Gives Opening Address at U.N. Forum on Business and Human Rights

On December 4 and 5, more than 1,000 participants from 85 countries gathered for the first U.N. Forum on Business and Human Rights in Geneva, Switzerland. The Forum focused on “trends and challenges” in the implementation of...more

12/11/2012 - Conflict Mineral Rules Dodd-Frank Due Diligence Human Rights United Nations

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