Corporate Responsibility for Human Trafficking & Five Steps that Your Company Can Take Right Now

by Foley Hoag LLP - Corporate Social Responsibility

In a landmark speech to the Clinton Global Initiative in September 2012, President Barack Obama declared that the “fight against human trafficking is one of the great human rights causes of our time” and that “our global economy companies have a responsibility to make sure that their supply chains, stretching into the far corners of the globe, are free of forced labor.”

The President’s speech is reflective of the fact that human trafficking and forced labor have become key priorities for those seeking to hold companies accountable for the human rights impacts of their operations. Companies that fail to address these concern face both legal and reputational risks.

Why has human trafficking emerged as a major focus area for companies?  New statutes, including the California Transparency in Supply Chains Act and the proposed Business Transparency on Trafficking and Slavery Act have focused attention on corporate efforts to address human trafficking risks. The California statute, which went into effect on January 1, 2012, requires companies to make public disclosures of their efforts, if any, to ensure that their supply chains are free from forced labor and human trafficking.

At the same time, educational and media efforts like the CNN Freedom Project have helped to raise awareness of the scourge of modern day slavery. Notably, in the past year, the American Bar Association has made human trafficking a major focus area, and has launched a Task Force on Human Trafficking. One project of the Task Force is to develop guidance materials for companies seeking to comply with state, federal, and national legal requirements on human trafficking as well as to eradicate human trafficking in their supply chains.

Many companies have been proactive in taking efforts to address trafficking concerns in the context of their operations. President Obama’s speech highlighted the launch of the Global Business Coalition Against Trafficking (“gBCAT”), a new initiative that intends to serves as a “thought leaders’ forum to develop and share best practices for addressing the vulnerability of businesses to human trafficking in their operations.” Companies that are members of gBCAT include ManpowerGroup, Microsoft, Carlson, and the Coca-Cola Company.

Earlier this month, a New York Times article, The Travel Industry Takes On Human Trafficking, focused on travel and tourism industry efforts to combat human trafficking, and noted that an increasing number of companies are signing the Tourism Child-Protection Code of Conduct. Companies that have signed the Code include Carlson, Delta Air Lines, Hilton Worldwide, and Sabre Holdings.

In this context, what are immediate steps that your company can take to address human trafficking concerns?

  1. Conduct a risk assessment to evaluate the risks of human trafficking in the context of your company’s operations, including its supply chain.
  2. Develop policies and standards on human trafficking, or ensure that prohibitions on human trafficking are incorporated into existing human rights policies and standards.
  3. Ensure that prohibitions on human trafficking and forced labor are included in contractual requirements for contractors and suppliers.
  4. Provide training to managers and employees on how to identify and report indicators of human trafficking and forced labor.
  5. Identify and engage with relevant industry initiatives and other potential partners that can provide critical support for company training and risk assessment efforts.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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