There's nothing innovative in suggesting modifying value distribution in supply chains; it's just that the imbalance continues to grow and it makes sense that the incidence of exploitation would also grow at the same rate. We can wrestle with issues further down the chain, but immoderation at the top - corporate boards, executives and outsized compensation - will always determine the health of the structure. The fish... more »

A focus on trafficking, forced and child labor in the agricultural and informal sector is needed. With limited number of inspectors, these sectors are often disregarded. While labor inspectors and other government and police agents are well positioned to identify trafficking, with many inspections being complaint driven, victims without access to call or submit any form of complaint means their situations will largely... more »

The United Nations Guiding Principles (UNGPs) make it clear: companies must have robust processes in place to look at the adverse human rights impact their operation (including all their business relationships) can have or can contribute to. They must act on the findings and communicate on the process and its results. Those principles are aligned with the proposed approach by the Department of Labor to mitigate the risks... more »

ILAB can promote higher usage of the Comply Chain app among companies by sponsoring a coalition of interested users and provide them with concreate guidance on how to effectively utilize the app based on different scenarios. This coalition can provide a forum for existing and potential users to exchange ideas, examples and discuss applicability of the app so companies can find ways to make the app most useful to their... more »

The Administration should work with Congress to require DOL/ILAB to include not just commodities and goods but inputs produced with child or forced labor at any point in the production chain on their biennial lists. As mentioned, the Frederick Douglass Trafficking Victims Prevention and Protection Reauthorization Act of 2018 (P.L. 115-425) suggested that DOL/ILAB include inputs made with forced labor "to the extent practicable,"... more »

The only way to adequately and sustainably address the issues of forced and child labor within specific supply chains is through collaboration and coordination of efforts by the many local and global stakeholders. The issues are too large and systemic to be addressed by individual efforts. The challenge therefore remains to connect different stakeholders who can consolidate and complement prevention and remediation efforts.... more »

Comply Chain's emphasis on the unique vulnerabilities of migrant worker recruitment (e.g. "Addressing the Vulnerability of Migrants in Codes of Conduct") is quite useful and practical for businesses. ILAB can further promote supply chain responsibility and social compliance by including specific examples of labour suppliers who follow international best practices in migrant worker recruitment, such as The Ethical Recruitment... more »

ILAB could deliver targeted grants to local civil society organizations in countries and migration corridors where commodities and goods identified to have high incidences of labor trafficking are sourced, as reflected in the App and underlying research. The grants would specifically seek to raise awareness among local workers and worker organizations about the brands and products downstream from their work. Oftentimes... more »

ILAB should update its application to have a part that focuses on US based companies and worker exploitation/human trafficking in the United States. The United States must provide the same tools to workers and companies at home as it does for workers/companies abroad given the abuse that exists in our own backyard.

Diverse agricultural products around the world count on certifications to verify quality standards in issues such as environmental protection, phytosanitary standards, fair commerce, etc. Although certifications are not a full guarantee of labor compliance, they often include certain labor issues that can at least set minimum standards to guarantee acceptable labor conditions. I think it is key to work with certification... more »

It is nearly impossible for most industries to eliminate human trafficking and labor exploitation in their supply chain without vertically integrating. Many products we use, from its raw material form to manufacturing to transportation to retail may at some point have been worked on by slave labor. In most cases, workers employed by contractors or raw material suppliers, occupy the lowest levels of the supply chain pyramid.... more »