- 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
- Pre-Call Discovery Process
- One-on-One Call with Expert
- Session Summary Report
- Post-Session Engagement
Human Trafficking - Compliance in Business and the Supply Chain
- Businesses have not conducted a complete risk assessment of their supply chain for human trafficking.
Conducting a top to bottom review of your entire supply chain as well as all of your business entities will help to identify any problems relating to human trafficking that may be present. You can't conduct a risk assessment without being fully aware of the threat to your operations that would be caused by having victims of human trafficking within your business enterprise.
- Businesses do not understand the entire spectrum of what constitutes human trafficking.
It's difficult for a lot of businesses to understand that even today, human trafficking is pervasive in many countries and in many industries. Slavery, debt bondage, bondage, forced labor and peonage are still used to compel workers to produce commodities or provide services. Children are forced to work in conditions that preclude them from receiving a formal education or that are so hazardous that injuries or death is an anticipated outcome.
- Businesses are unaware of which industries and products tend to be most susceptible to having victims of human trafficking.
Many countries and many specific industries tend to have labor pools that may be comprised of the victims of human trafficking. Commodities in your supply chain, everything from tea, to diamonds, to textiles, to tobacco products may be produced from the labor of trafficking victims. The U.S. Labor Department produces a yearly handbook to identify the countries and commodities most likely to involve human trafficking.
- Discovering a human trafficking problem in your business – what to do next?
A company's plans to deal with the mitigation of a human trafficking problem should be in place well before they are ever needed. Think of these plans as you would contingency plans to deal with any type of problem. Most businesses should simply not release the employee without having measures in place to address their health and well-being. Certain NGOs are well-equipped to deal with the victims of human trafficking. Coordinating with them early on may facilitate obtaining assistance from them, if and when, it's ever necessary. There may also be an obligation to report the discovery to law enforcement entities, contracting officers, or boards.
- Businesses do not have a Human Trafficking Code of Conduct in place.
Every employee, manager, executive, board member, contractor and sub-contractor must be keenly aware of your business Code of Conduct relating to the prevention of human trafficking. The Code of Conduct lets everyone from your suppliers to customers to investors know exactly where your business stands to prevent this heinous conduct within its operations.
- Management and employees have not been trained on indicators of human trafficking.
Training employees and management on how to recognize and prevent trafficking is essential to avoiding the consequences of this type of risk in business. Training on this topic should be at the time of hire, yearly or at least biannually, and should be considered as part of conferences. Consider inclusion of your sub-contractors and contractors in this training. Most importantly, all human resources personnel, both foreign and domestic must be trained on the indicators of trafficking.
- Businesses confuse or conflate human trafficking and human smuggling.
Quite a few businesses, even quite a few law enforcement officers, tend to conflate the terms human smuggling and human trafficking. Human smuggling involves the evasion of a country's immigration laws while human trafficking is about exploitation of the victim. Persons seeking employment without legal authorization to be lawfully present in a country are usually working in violation of that country's immigration laws and are subject to deportation and other measures, Human trafficking victims don't necessarily have to be from another country. People can and often are trafficked in their own countries and communities.
- Businesses believe they aren't susceptible to human trafficking.
Just picking up a newspaper, magazine or reading a news article on the Internet should convince most of us that human trafficking is pervasive in our modern world. Many businesses may believe the problem belongs to their vendors or sub-contractors and therefore would not affect their direct operations. Unfortunately, the stain of human trafficking permeates from the suppliers influencing your customers and your investors.