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