Modern Slavery and Your Supply Chain


Modern Slavery and Your Supply Chain

Considerations when Importing Goods and Services

Slavery should have been abolished, right?  However, to this day, many products and services individuals buy every day are sourced by people subject to modern slavery. You may not even be aware of the fact that products and services you are buying or procuring are tainted with it. Modern slavery may occur in any stage of the supply chain, such as extracting raw materials in fields, to manufacturing facilities, to shipping operations. Forced labor and sex trafficking are only some of the types of modern slavery that still exist in the world and you may find it in many industries.

Governments around the world have passed legislation in an effort to eradicate modern slavery and forced labor (e.g., the UK Modern Slavery Act of 2015, the Australian Modern Slavery Act of 2018, the California Transparency in Supply Chains Act which came into effect January 1, 2012, the most recent Uyghur Forced Labor Prevention Act signed into law by President Biden on December 23, 2021, etc.).  If your company operates internationally and is importing goods or services, you may need to review and enhance your compliance program.  Have you stopped and considered whether the goods you are importing are ethically sourced?  Have you performed appropriate due diligence on your suppliers and continue to monitor them?

What is an import?

Imports are goods or services brought into a country when such goods or services are produced in a foreign country.  Depending on the type of good or service, some governmental agencies may require licenses, permits and/or other types of documentation before such imports enter the U.S.  Some goods that are at risk of having modern slavery within their supply chain include, but are not limited to, cotton, bricks, apparel, cattle, sugarcane, gold, carpets, coal, fish, rice, timber, nuts, cocoa, diamonds, electronics, etc.

Supply Chain Due Diligence 

It is important for companies to have effective supply chain due diligence procedures and evaluate their effectiveness in order to mitigate modern slavery and forced labor risks.  At a minimum, companies should implement and enforce a supplier code of conduct and related training that cover topics to prevent and identify signs of modern slavery.  Standard operating procedures that include proper documentation for recordkeeping purposes is also important.  Remember, you should always monitor your supply chain.  Requesting audits may also be an option. 

Please note that this blog should be read for informational purposes only.  If you have any questions or require additional information, please contact our office.

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