Hidden Traffic with Gwen Hassan: Recent Episodes
Gwen Hassan
What is human trafficking? What is modern slavery? Where does it show up in the daily life of an organization? Human trafficking doesn't always take the form we first imagine - it can be found at almost any level of an organization's supply chain. What can compliance professionals do to assess human trafficking risk and how can they leverage the resources of the organizations they work for to help root out this tragic problem? Gwen Hassan is here to help - this is Hidden Traffic.
The global landscape of human trafficking and forced labor is evolving, and no country is immune. In this episode of Hidden Traffic, Gwen Hassan sits down with Sean Stephenson, an accomplished attorney based in Toronto. Sean works for the multinational law firm Dentons and has extensive experience in trade and investment. The growing concern for supply chain integrity forms a significant part of his work, with particular emphasis on human trafficking, forced labor, and child labor. Together, he and Gwen delve into the new Canadian law aimed at preventing human trafficking, forced labor, and child labor within supply chains. Their conversation also provides insights into the practices of various multinational companies and explores the need for coherence in the anti-slavery reporting and measures across different jurisdictions.
The new Canadian legislation is known as the Modern Slavery Act, but is officially titled "Fighting Against Forced Labor and Child Labor in Supply Chains Act." This law is set to come into effect on January 1, 2024. Sean underscores the legislation's scope, noting that it will apply to a wide range of entities and industries that produce, sell, or distribute goods in or import goods into Canada. Sean clarifies, "The legislation is roughly based on another piece of legislation we have in Canada that was adopted a few years ago called the Extractive Sector Transparency Act, that's focused specifically on the extractive sector, …But it's much broader in nature. It's not specific to the extractive sector. It applies to essentially any business formation."
Despite the legislation's primarily reporting nature, Sean distinguishes it from an actual diligence standard. He emphasizes the need for convergence in anti-slavery laws globally, which calls for a balance between compliance and alignment in disclosure across jurisdictions. However, he points out some unique features of the Canadian Act, such as its focus on child labor and specific liabilities for companies and directors for false and misleading statements.
Both Gwen and Sean believe in the Act’s potential to drive meaningful change in business practices related to human trafficking, forced labor, and child labor.
Sean sheds light on the operations and mandate of the Canadian Ombudsperson for Responsible Enterprise (CORE). CORE is an arm of the Canadian federal government, focusing on promoting the implementation of the UN and the OECD guidelines on multinational enterprises. The organization targets three specific areas: garment business, mining, and oil and gas. "Anyone can submit complaints to the CORE about business activities of Canadian businesses, either inside Canada or abroad", Sean explains. He distinguishes CORE's investigative powers, which are funded by the Canadian government, from those of a non-governmental organization. Gwen likens its investigative powers to those of a regulatory authority.
Sean points out that CORE cannot force document production but can accept and facilitate discussions around complaints. While CORE can't directly impose penalties, they can recommend fines and referrals to law enforcement. Gwen highlights the potential reputational damage these investigations can pose for companies, and they both agree on the importance of proactive measures in mitigating these risks.
Resources Sean Stephenson on LinkedIn | Twitter Dentons Canada’s Forced Labour and Child Labour Reporting Legislation: What You Need to Know The CORE of the matter: An overview of the Canadian Ombudsperson for Responsible Enterprise (CORE) and its relevance to Canadian businesses operating abroad
Noel Thomas is CEO of Zero Trafficking, a data company bringing innovative data, analysis, and training solutions to the frontlines of anti-trafficking. He joins host Gwen Hassan to discuss how Zero Trafficking is using technology in the fight against human trafficking. Prior to founding his company, Noel toured the world as the bass guitarist of a rock band. It was during one of these tours in 2007 that he first got exposed to the issue of human trafficking through a flyer aiming to raise awareness. It inspired him to learn more about human trafficking and join the efforts to eradicate it.Rather than manually looking for human trafficking online, Noel and the task forces he worked with thought of a better way to bring technology into the space. They quickly realized that corporations like social media platforms, banks, and even real estate developers could also benefit from this data; they could use it to up their compliance and mitigate the risks involved with human trafficking. ResourcesNoel Thomas on LinkedInZero Trafficking
Kody Kumfer is Associate Executive Director of Forgotten Children Worldwide. Forgotten Children is an organization dedicated to helping children in vulnerable situations across the world. Kody joins host Gwen Hassan to discuss how Forgotten Children is funding education and working with indigenous leaders to create positive change.
Forgotten Children partners with native leaders, most often religious and business leaders, who are passionate about orphan care. They have built homes and farming operations in various countries to support vulnerable children. The organization is focused on preventing children from falling prey to human trafficking, as well as improving their conditions.
Currently, Forgotten Children is working in India to bring young girls out of the Devadasi system, which is a practice that, in modern times, pushes them into prostitution. It’s a hereditary role that is often passed on from grandmother, to mother, to daughter.
Resources Kody Kumfer on LinkedIn Forgotten Children
Aditi Wanchoo is Senior Manager of Human Rights at Novartis, based in Basel, Switzerland. Novartis is a leading global medicines company using innovative science and digital technologies to create transformative treatments in areas of great medical need. Aditi joins host Gwen Hassan to discuss Germany’s recent Supply Chain Due Diligence Act (SCDDA) and how it’s going to help with human trafficking prevention. In order to tackle any change, whether it’s better labor and human rights protection for supply chain workers or addressing human trafficking, there needs to be an ecosystem response. Governments, businesses, and civil society must consistently work together to address and overcome these challenges. Having had the opportunity to work with three multinational companies in diverse sectors, Aditi believes companies can be and are a force for good to bring about social and environmental change.
Though human trafficking prevention, in particular, has improved in the last few decades, there is still much left to be done. Germany’s Supply Chain Due Diligence Act (SCDDA), which was passed in 2021 and will enter into force on January 1st, 2023, is an important step forward in this regard. The act’s core expectation is to develop a corporate risk management system to identify and address human rights and environmental risks. Companies that fail to do this will be subject to substantial administrative fines.
Resources Aditi Wanchoo on LinkedIn
How do you create a system where you are continuously and effectively listening to your key stakeholders in an inclusive manner? Vera Belazelkoska is Director of Programs at Ulula, a social enterprise startup that provides organizations with digital tools and expertise to monitor the human rights impacts in their global supply chains. She joins host Gwen Hassan to discuss how Ulula is helping companies amplify the voices of people who don’t always get to talk to the social auditors.
Ulula designs technology solutions to help companies do better in many areas. They are dedicated to building, configuring, and successfully implementing different innovative tools to help organizations monitor human rights issues, labor rights impacts, and community rights in global supply chains. Supply chain transparency is part of it, but they also focus on the accountability aspects.
Corporations are being held to increasingly high standards across different jurisdictions to ensure that they do everything in their power to identify human rights violations they may be complicit in along their supply chain, and then remediate them.
Resources Vera Belazelkoska on LinkedIn Ulula
Rebekah Enoch is Program Director at Human Trafficking Search, an organization aiming to raise awareness and contribute to preventing and eliminating human trafficking worldwide. She joins host Gwen Hassan to share how Human Trafficking Search is fighting human trafficking through education.
Human Trafficking Search is an electronic clearinghouse of information about the many faces of human trafficking, including sex trafficking, labor trafficking, child labor, and labor exploitation. “We really try to encompass every level of that conversation so that if you are someone who works in the field or an aspect of the field, you can find materials for any research you're doing to inform what you're working on,” Rebekah explains. Even laymen who just want to be informed can access easily digestible information from their website.
They also conduct their own investigations, she adds. Recently, HTS published a report about how the green revolution in the Democratic Republic of Congo may be linked to cobalt mining. While this may not sound like a problem initially, cobalt mining in the DRC is driven by a host of issues around child labor and labor exploitation.
Resources Rebekah Enoch on the Web | LinkedIn | Twitter
In this solo episode of the Hidden Traffic Podcast, host Gwen Hassan discusses recent developments in human trafficking and forced labor prevention. She shares with listeners a snapshot of where Hidden Traffic is headed over the next few months as 2022 draws to a close.
There has been a flurry of activity around the Uyghur Forced Labor Prevention Act, Gwen claims. It has been driving broader conversations among companies about their supply chains, serving as an impetus to examine where they source their products from and if they have been enabling entities that violate human rights. Even companies that are truly domestic have now started full-scale risk assessment processes for forced labor risk within their supply chain.
It really has stemmed from UFLPA work, because many of them are concerned they may have private label goods that are manufactured for them under a contract manufacturing arrangement overseas. They've become aware of the fact that they may be caught up in a forced labor situation, even if it's not their own labor or their own manufacturing.
Resources Gwen Hassan on LinkedIn
Virginia Newman is a trade and white collar compliance attorney, and counsel in the international department at Miller & Chevalier. She advises on Foreign Corrupt Practices Act (FCPA), anti-money laundering (AML), securities laws, anti-forced labor laws and other human rights-related issues. Virginia also specializes in investigations and litigation. She joins host Gwen Hassan to explore key points in the Uyghur Forced Labor Prevention Act.
There has been a debate around which comes first: mapping your supply chain, or doing a risk assessment. Rather than making it a chicken or the egg scenario, Virginia believes mapping your supply chain is a part of a risk assessment and due diligence. The first step in performing a risk assessment is discussing your products with your product team, she shares: figuring out which products have high risk inputs, and which ones you should focus on mapping first.
This is especially important for large companies who import and distribute countless products. There may be too many products to have a fully mapped and detailed supply chain for every one of them. Taking it one input at a time breaks down the line item list to a more manageable level.
Resources Virginia Newman on LinkedIn
Mollie Sitkowski is Trade Compliance Counsel at Faegre Drinker, where she handles import and export control and compliance work on behalf of the firm's clients. She has assisted numerous clients in developing and implementing import and export compliance programs, and offers continued training to the business areas that touch on import and export compliance. She returns in this episode to discuss key points about the Uyghur Forced Labor Prevention Act.
Customs has been advocating forced labor risk assessments since the consumptive demand loophole that allowed companies to import goods made by forced labor was taken out. However, aside from companies in very high risk industries such as textiles, most companies weren’t conducting these risk assessments. Mollie advises listeners to start mapping out supply chains and identifying ones with the highest risk - you can’t assess your risk without knowing your supply chain.
Every company should have a supplier code of conduct, Mollie adds. The best practice would be flowing down the requirements from your first tier suppliers to their suppliers, because the manufacturers also need to be on board and held responsible.
Resources Mollie Sitkowski on LinkedIn
Matthew Frank is Chief Legal Officer at PeopleConnect. He is an experienced legal and compliance executive in many industries including e-commerce, technology, hospitality, and manufacturing. Matthew joins host Gwen Hassan to discuss human trafficking in the hospitality industry.
Matthew previously served as Senior Vice President and Global Chief Compliance Officer at Las Vegas Sands Corps, where he was involved in the trafficking focus. They did extensive training with the front desk staff, teaching them to spot red flags at the check-in process, and with the housekeeping staff.
Staffing shortages can lead to human trafficking risks, Matthew claims. In a place like Singapore, where the majority of housekeeping staff are guest workers from other places in Southeast Asia, the big risk is the presence of labor brokers. They would recruit locals, mostly low-income young women, and essentially force them into indentured servitude.
Resources Matthew Frank on LinkedIn
Duncan Jepson is Managing Director of Liberty Shared. Starting as a documentary filmmaker, he saw the stark contrast between the ones being filmed and the excited executives. He joins host Gwen Hassan to discuss how Liberty Shared is helping organizations take action against human rights violations.
Liberty Shared’s main focus is data gathering and research and intelligence sharing - gathering information about what happens on the ground then communicating that to individuals, groups, and organizations that can do something in response. “We’re not interested in statistics [or] estimations,” Duncan shares, “we’re interested in data as it is accurate and can produce actionable information and evidence.”
The system is flawed and incomplete, he adds. The global economy is profit-oriented, so much so that it operates at the expense of other people, and the chance of anyone being held accountable for their part in it is very limited. Liberty Shared is working to identify those gaps of accountability and close them as much as possible.
Resources Duncan Jepson on LinkedIn
Sarah Dadush is a business and human rights law practitioner with a background in international development. She also teaches Contracts, Business & Human Rights, and Consumer Law at Rutgers Law School. Susan Maslow is an experienced business attorney with a focus on transactional corporate law, and a co-founder and partner at Antheil Maslow & MacMinn. They join host Gwen Hassan to discuss how contracts can be used as preventative measures against human rights violations.
Upon coming across the Model Contract clause 1.0 (also called standard contractual clauses), Sarah was taken by the idea of using contracts as a tool for improving the human rights performance of international supply chains. As contracts are well within the dominion of firms, there was something promising about using these legal links in the supply chain to serve a new purpose. Unfortunately, the 1.0 had a significant pain point, but the updated 2.0 intends to solve it.
This pain point, Susan shares, is that model clauses’ definition of non-conforming goods did not address the buyer’s desire to call them non-conforming or even use traditional contract remedies. Soccer balls that are black and white and perfectly stitched look like conforming goods, even if they were made with forced labor. “The first step in [our process] was to define goods that were tainted by forced labor, child labor, or other human rights abuses as defective,” she adds.
Resources Sarah Dadush on LinkedIn Susan Maslow on LinkedIn AMM Law - Susan Maslow
Richard Mojica is Practice Lead of Customs and Import Trade at Miller & Chevalier. He helps companies comply with the legal requirements associated with importing products into the United States. He also specializes in business and human rights. Richard joins host Gwen Hassan to discuss the overlap between customs and human trafficking prevention, and how they came to intersect.
Though the importation of goods made with forced labor is prohibited by law, there was a loophole that allowed it for decades. The loophole was that if a good was not sufficiently produced in the US to meet consumptive demand, it could be imported, which permitted the importation of goods made with forced labor that fulfilled those requirements. This was made worse by the lack of oversight from customs, which was likely driven by a focus on acquiring necessary goods.
The loophole of consumptive demand was plugged in 2016 by the passing of a new law, and the US Customs and Border Protection was charged with its enforcement. The CBP’s tool for that is the withhold-release order - an instruction that detains merchandise that is suspected of being made with forced labor at the ports of entry.
Resources Richard Mojica on LinkedIn | Twitter MillerChevalier.com
Nate Lankford is the Practice Lead for Business and Human Rights at Miller and Chevalier, and co-chair of the International Bar Association’s Business and Human Rights Committee. He is an anti-corruption expert whose practice focuses on matters involving the Foreign Corrupt Practices Act (FCPA) and other areas of international corporate compliance. Nate joins host Gwen Hassan to discuss the UNGP on Business and Human Rights and its role in ending forced labor.
The UN’s Guiding Principles on Business and Human Rights is a framework unanimously endorsed by the UN Human Rights Council in 2011. The framework is a broad consensus about a company’s responsibility to respect human rights - essentially, a company’s responsibility to ensure their actions aren’t interfering with someone’s ability to enjoy their rights. It also requires companies to do due diligence in identifying their human rights risks and facilitate effective remediation when they’ve identified that they’ve had adverse impacts.
“[The company must] evaluate the risks and severity from the lens of vulnerable stakeholders like a worker or community member,” Nate shares. The potential liability and economic consequences shouldn’t be the priorities when faced with a potential breach of human rights. It’s important to have meaningful stakeholder engagement in all stages of risk evaluation, and transparency is key to that process.
Resources Nate Lankford on LinkedIn
Mike McDonnell is an IT Consultant and a CSR. He was also a founding member of the Responsible Business Alliance's Responsible Labor Initiative. Mike and host Gwen Hassan discuss the impact of fast fashion on workers, forced labor, and the responsibility of companies to ensure that they don’t use vendors and suppliers who engage in unethical and harmful practices.
Many workers who end up in the grips of human trafficking are oftentimes fleeing hardship and poverty. This makes them targets for exploitation by agencies and facilities. Mike explains that some workers have to pay fees to be able to be hired, and, because of these fees, they are put under tremendous pressure by the employers. The workers feel indebted to the ones exploiting them, allowing their superiors to maintain a sense of control over them. Companies may also be receiving free hiring services and benefits by way of human trafficking, sometimes without their knowledge.
The workers pay fees in two ways: above board by way of charging limits, or in rougher aspects by extraction of cash. These fees are ongoing and so that workers can keep their heads down and out of the line of fire, so to speak. There are digital programs put in place to audit this. Surveys are given out to workers with questions on whether they've been asked by anyone for money. One of the positives about this type of technology is that companies are able to monitor in real time when these situations arise.
It's not enough to not do harm as a company. It's not enough to just say that you're following your code of ethics. You have to show it in your actions, and you have to break it down to its elements. Rethink your tools, assess your suppliers and their business practices, and these can become your rail factors on whether or not to engage in business with them. If they present too much of a risk, or you cannot prove that they aren't engaging in unethical behavior, you will have to rethink your outsourcing.
Resources Mike McDonnell on LinkedIn Responsible Labor Initiative
Lisa Thee is the Data for Good Practice Lead at Launch Consulting Group. She is CEO at AMP Solutions, where she provides advising, consulting, and strategy services for businesses. She also serves on the board of directors and as an advisory board member for several organizations, and is a TEDx Speaker. Lisa joins host Gwen Hassan to discuss the evolution of digital safety, and the role of digital platforms in both the persistence and end of human trafficking.
Digital platforms have been used as a vehicle for recruiting victims of human trafficking and/or child sexual exploitation, in part due to the absence of standards and regulations for digital safety. There isn’t a strong business incentive to do the right thing in terms of trust and safety, Lisa claims, because it opposes shareholder value and growing your audience. “I think we're finally at a place as a society where we're ready to [abandon leveraging] our next generation’s mental and physical health to maintain the status quo,” she says.
However, a delicate balance must be struck; making adjustments to trust and safety will directly impact privacy, and vice versa. There is no one-and-done method to solving this problem, as it has never been about technology, but instead, ethics. On a related note, advocating for compliance and ethics from a financial standpoint promotes a win-win scenario for business and for the greater good.
Resources Lisa Thee on LinkedIn | Twitter LisaThee.com
Leo Bonanni is founder and CEO of Sourcemap, the social network for supply chains. Sourcemap provides supply chain mapping software for companies, that traces products, evaluates social, environmental and financial risks, and monitors improvements over time. Leo is also a board member at Bluenumber Foundation, a former faculty member at NYU and Columbia University, and a former visiting scientist at MIT Media Lab. He joins host Gwen Hassan to explore how Sourcemap is maintaining supply chain integrity and transparency with social networks.
The impetus behind Sourcemap was transparency in a world of greenwashing, Leo shares. He observed the emergence of user-generated content and the convergence of the democratization and open dissemination of ideas, and connected the two to make it easier to maintain supply chain integrity. When Sourcemap launched in 2011, there were numerous companies interested in mapping their supply chains to gain a competitive edge.
Audits were the predominant technique used to manage social and environmental performance in extended supply chains. Sourcemap is expanding the power of audits by collecting data from all of the actors in a high-risk region.
Resources Leo Bonanni on LinkedIn | Twitter Sourcemap.com | Sourcemap on Twitter
Laura Gauer Bermudez is Director of Evidence and Learning at the Global Fund to End Modern Slavery. She is also a psychotherapist at Gold Therapy NYC and Westchester Psychotherapy. With over 15 years of experience in leadership, business operations, and grant-making, Laura is a social impact professional dedicated to making the clinical setting more human. She joins host Gwen Hassan to define and differentiate between human trafficking and modern slavery, and discuss GFEMS’ data-based approach to ending both.
Fundamentally, modern slavery and human trafficking are about people with more power taking advantage of those with less for profit. Often, the victims have a minority status, usually ethnic, religious, or gender-based. Though modern slavery and human trafficking often intersect, they aren’t the same thing. Human trafficking is the recruitment, transfer, transportation, harboring or receipt of persons using force, fraud, or coercion for the purposes of exploitation. Modern slavery is an umbrella term that covers multiple forms of exploitation, including human trafficking, forced labor, commercial sexual exploitation, and forced marriage.
Whether the term ‘modern slavery’ is appropriate is a point of contention within the US. The reason it’s up for debate is due to the US’ own history of the transatlantic slave trade; for some, it’s an insult to equate recent forms of exploitation to the purchasing and ownership of African people as property.
Resources Laura Gauer Bermudez on LinkedIn | Twitter Global Fund To End Modern Slavery
Jeff Bond is the Director of Strategy and Design for the Global Fund To End Modern Slavery, an international fund that mobilizes resources, evidence and partnerships to end modern slavery. He is passionate about making a positive social and business impact, and has spent a great deal of time in other countries broadening his perspective. Jeff returns to Hidden Traffic to discuss how modern slavery drives climate change.
If modern slavery were a country, it would be the third biggest source of carbon emissions in the world, after China and the US. This is because the industries and geographies that contribute the most to climate change use forced labor extensively, due to the increased vulnerability discussed in the last episode. Simply deciding to pull support from these industries will not be enough to end the issue of modern slavery, as it leaves behind more vulnerable people; people who can be easily manipulated by others seeking to make money off of them.
GFEMS is trying to strike the right balance of policies and enforcement to eradicate the conditions that power modern slavery, while still encouraging local growth and empowerment. To achieve this, however, many industries in particular need to undergo a complete overhaul of the way they do business.
Resources Jeff Bond on LinkedIn Global Fund To End Modern Slavery
Jeff Bond is the Director of Strategy and Design for the Global Fund To End Modern Slavery, an international fund that mobilizes resources, evidence and partnerships to end modern slavery. He is passionate about making a positive social and business impact, and has spent a great deal of time in other countries broadening his perspective. Jeff and host Gwen Hassan discuss how the effects of climate change impact modern slavery around the world.
There are two broad ways in which climate change drives modern slavery: increased vulnerability and forced labor. Populations that are disproportionately affected by climate change in the way of floods, landslips, and a lack of water become more vulnerable to modern slavery. As for forced labor, this primarily occurs in the realm of clean energy supply chains. The technological solutions that will be critical in addressing climate change have issues related to exploitation. Cobalt mining in the Democratic Republic of Congo, nickel mining in Guatemala, and solar panels in China are just a few examples. Legislation such as Germany's Supply Chain Due Diligence Act and the Forced Labor Prevention Act in the US are coming into effect to challenge this.
Climate change, human trafficking, and modern slavery are intricately connected, and they cannot be separated from each other. They are connected to various corporate relationships, and so it's very important for companies to remember the moral obligations they have to their workers. Companies have to make sure that they're operating ethically and not facilitating modern slavery.
Resources Jeff Bond on LinkedIn Global Fund To End Modern Slavery
Jean Bruggeman is Executive Director at Freedom Network USA, an organization with over a decade of leadership in supporting providers of direct services to survivors of human trafficking in the United States. She is a highly effective leader with 20 years of management experience in the non-profit legal and social services sector. She discusses the shortcomings of the immigration system and how it affects human trafficking, and what human trafficking looks like in the US.
In the case of domestic violence against an immigrant spouse, the traditional system is biased towards the abuser if they are a US citizen. They are essentially “handed another weapon in their arsenal to abuse and exploit their spouse,” as they can use their partner’s immigration status as a tool of power over them. There is now a law under the Violence Against Women Act that allows immigrant women to apply for their own visas, therefore taking the control away from their spouses.
Human trafficking is not about a few bad apples, Jean shares. Freedom Network is pulling out all the stops to get at the systemic issues of policy choices and immigrations systems that don’t protect or empower workers, and the racist, misogynistic history in US laws that put people at risk of being victimized.
Resources Jean Bruggeman on LinkedIn
Irene Kaushansky is Associate Director for Compliance and Operational Integrity at Global Fund to End Modern Slavery (GFEMS). She has over 15 years of international experience developing and implementing programs for compliance and ethics, risk mitigation, and crisis management and investigations. She discusses GFEMS’ contribution to the fight against modern slavery and human trafficking.
GFEMS' mission is to bring donors together and coordinate globally to eradicate modern slavery and human trafficking. Most anti-slavery work is narrowly focused on interventions that are tied to the purpose of the organizations, and these entities do not collaborate effectively. GFEMS was conceived by leaders who recognized that greater resources and coordinated global action was necessary to make real progress in ending modern slavery.
One of the ways that GFEMS is addressing forced labor and exploitation along supply chains is through private sector engagement. They are developing innovative tools to help private sector businesses build and maintain supply chains that are free from exploitation. These tools also support the private sector to comply with regulations to meet rising consumer demand for ethically sourced products, and ultimately to protect workers from being exploited.
Resources Irene Kaushansky on LinkedIn
Andrew Wallis is CEO at Unseen UK, a charity dedicated to eradicating modern slavery wherever it is found, and bringing safety, hope, and choice to the survivors of human trafficking and modern slavery. Andrew is a member of several boards for organizations that seek to end labor abuse, advocate for human rights and social justice, and enforce ESG. He discusses how Unseen is fighting modern slavery, and how leaders can do their part.
Unseen works with all the major statutory agencies to assist victims of human trafficking and slavery that are identified within the UK. They help paramedics and local government develop a more victim-based approach, tackle forced labor within business’ supply chains, and run the UK’s modern slavery helpline, which is a fully manned, 24/7 operation. The helpline receives calls from victims, concerned members of the public, police officers, and businesses. It’s critical that the call handlers understand the need for the victims’ confidentiality, as well as the legislation necessary to extricate them from their circumstances.
“There isn’t an industry sector or country that isn’t impacted by the issue of human trafficking,” Andrew claims. “I’ve stood in many conferences and told them that I wasn’t there to make them feel guilty; we’re all guilty. [We need to] get over [the guilt], and start thinking about how we’re going to get out of the mess we’ve built.”
Resources Andrew Wallis on LinkedIn | Twitter UnseenUK.org ModernSlaveryHelpline.org
Mollie Sitkowski is Trade Compliance Counsel at Faegre Drinker, where she handles import and export control and compliance work on behalf of the firm's clients. She has assisted numerous clients in developing and implementing import and export compliance programs, and offers continued training to the business areas that touch on import and export compliance. She discusses how import and export compliance intersects with human trafficking.
Customs has the authority to issue a WRO (withhold-release-order) if they have information that reasonably indicates that goods were made, either in part or in full, with forced labor. The goods are detained until you can prove otherwise. The vast majority of forced labor detentions are done under WROs, Mollie says. You have to provide two things required by the regulations within 90 days or you can choose to export. However, customs has escalated so much that it is difficult to acquire all the necessary data within 90 days, unless you already have a good compliance program and good auditing in place.
“To require you to have mapped out your entire trade flow and be able to provide that kind of detail all the way through the chain; I think that's something that hopefully will really be an impediment to trafficking over the long run,” Gwen shares.
Resources Mollie Sitkowski on LinkedIn | Twitter
Aaron Kahler is founder and Chief Executive of The Anti-Human-Trafficking Intelligence Initiative, a non-profit organization dedicated to the worldwide fight to abolish modern slavery related to labor and sex trafficking. He is also a contributing member of Cryptocurrency Compliance Cooperative. He discusses how ATII works and gives insights about incorporating their programs into a company’s CSR and ESG.
The Anti-Human-Trafficking Intelligence Initiative (ATII) is focused on bringing anti-human trafficking programs to organizations such as financial institutions, commercial organizations, other NGOs, and businesses. ATII encourages these organizations to practice corporate social responsibility and think about environmental and social governance. They also have a unique focus on compliance and financial crimes due to Aaron’s background.
Standards are being set higher not just on the financial and regulation level, but also from new generations of society and young individuals with influence. They want to know before investments are made that companies are standing for something or meeting certain requirements.
Resources Aaron Kahler on LinkedIn | Twitter FollowMoneyFightSlavery.org
Human trafficking doesn't always take the form we first imagine - it can be found at almost any level of an organization's supply chain. In the Hidden Traffic podcast, host Gwen Hassan helps compliance professionals assess human trafficking risk and leverage their organization’s resources to root out this tragic problem.
Matt Friedman joins Hidden Traffic as the first guest. He is a global expert on modern slavery and human trafficking, and the founder and CEO of The Mekong Club, where he regularly advises heads of governments and intelligence agencies. Matt is considered by captains of industry to be the leading catalyst of the anti-slavery movement in Asia’s business sector. He shares how The Mekong Club helps companies protect themselves and avoid risk.
Corporate social responsibility (CSR) came about as a form of self-regulation for organizations to contribute positively to their surrounding communities, but the intended overall objective has not yet been achieved, Matt says. Nowadays, organizations often use CSR as a smokescreen to hide questionable and sometimes unethical practices.
Resources Matt Friedman on LinkedIn TheMekongClub.org
In this introductory episode, Gwen Hassan shares how she developed a passion for exposing human trafficking within supply chains. The Hidden Traffic podcast will educate, enlighten, and equip the compliance professional to understand what human trafficking is, the risks your organization will face, where it happens, and what you can do to combat it.