- Professor and Department Chair - Counter Illicit Trafficking - George C. Marshall European Center for Security Studies
- Assistant Special Agent in Charge, Customs and Border Protection, Office of Internal Affairs, Department of Homeland Security
- Assistant Director (Programs), Department of the Treasury, U.S. Customs, Office of Investigations, Smuggling Investigations Division, Washington, DC
- Featured Speaker, 4th International Symposium on Terrorism and Organized Crime, Antalya, Turkey "Illicit Trafficking As A Wicked Problem"
- All 7 Best Practices
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Human Trafficking - Compliance in Business and the Supply Chain
Human trafficking isn't just a threat to victims – it's a threat to any business that knowingly or unknowingly gets involved.
Whether you do business in one country or 50, you need to take precautions against your workforce, your contractors and sub-contractors, or your supply chain being tainted by forced labor, child labor, debt bondage and even 21st-century slavery. No country is immune.
Businesses can no longer make excuses; they cannot say, "We didn't know." These days, you need to find out even if employees working for third parties are victims of human trafficking. Even when you don't have a legal responsibility, you will be judged by the public.
Rather than waiting for a human-rights tragedy or public relations scandal to hit, you can take proactive steps. Companies must do due diligence to ensure they're not inadvertently involved in the recruitment, transportation, provision or obtaining of a person for involuntary servitude through the use of fraud, force, or coercion.
First, you need to be familiar with the growing number of laws, regulations and international initiatives. These include:
- On September 25, 2012, President Obama signed Executive Order 13627 strengthening protections against trafficking related to federal contracts. It effectively takes a “zero tolerance” approach.
- The California legislature passed the California Transparency in Supply Chains Act (SB 657), which took effect in 2012. It requires large businesses to ensure their supply chains are free from human trafficking.
- The U.N. has a number of conventions and protocols that criminalize human trafficking.
After understanding the local and international rules, you need to identify any vulnerabilities in your operations. This involves a risk assessment. At the same time, you need to offer rigorous training: All management, staff, suppliers, contractor personnel and audit teams must be aware of their responsibilities to prevent, identify and report human trafficking.
The following Best Practices are drawn from my experiences in investigation and enforcement from Tucson to Katmandu. They will help prepare your management team to avoid the risks of human trafficking and related crimes so your company can thrive.