Every two years, the U.S. Department of Labor’s Bureau of International Labor Affairs (ILAB) publishes a list of goods made with forced labor or child labor around the world. The latest release of that report is a stark reminder that modern slavery is not only deeply embedded in global supply chains across industries and continents, it is increasing in scope, and it affects nearly every sector you can think of. If you haven’t found any forms of modern slavery in your supply chain, it’s likely you haven’t looked close enough.
The Unseen Depths of Labor Exploitation
The 2024 “List of Goods Produced by Child Labor or Forced Labor” now includes 204 goods from 82 countries, up from 158 goods from 77 countries in the last version. This isn’t just a statistic — it demonstrates the widespread and growing nature of exploitative labor practices and how deeply rooted they are in the global economy.
The complex nature of today’s global supply chains, which stretch across multiple countries and involve millions of suppliers, makes them highly vulnerable to modern slavery. This vulnerability is captured in the 2024 ILAB report, which includes a separate list of goods tainted by forced labor through downstream consumption of goods made with forced labor. In other words, the list includes goods that are not directly made with forced labor but contain parts that may have been. As a result, they remain a target for enforcement action by regulatory bodies.
The Cost of Inaction: Enforcement Is Getting Tougher
And speaking of enforcement action, it’ becoming increasingly clear that governments around the world are no longer turning a blind eye, and they’re no longer satisfied by companies doing the bare minimum.
Looking back at the history of modern slavery legislation, there’s a clear trend toward stricter enforcement. The expectations haven’t necessarily changed, but the level of scrutiny has dramatically increased. They’re introducing stringent regulations with real teeth — enforcement actions that hit companies where it hurts most.
One of the most significant consequences is the inability to move goods across borders, which can cripple a business. Your organization should have always been addressing human rights within your supply chain — that’s a fundamental responsibility that hasn’t changed. What’s different now is the heightened attention from governments, spurred by persistent media coverage and NGO reports highlighting global issues.
Take U.S. Customs and Border Protection (CBP) and their enforcement of the Uyghur Forced Labor Prevention Act (UFLPA). Their website openly displays the staggering number of shipments that have been stopped on suspicion of links to forced labor. Many legal and trade teams have been caught off guard by this robust trade-enforced social accountability legislation.
UFLPA Handbook: How to Prevent Supply Chain Disruption
The Uyghur Forced Labor Prevention Act (UFLPA) places new due diligence requirements on manufacturers. Download our handbook now to learn how to protect your supply chain and stay compliant.
The Pitfalls of a “Check-the-Box” Approach
A common refrain we hear from companies facing enforcement actions is, “We have our suppliers sign our code of conduct stating they won’t engage in modern slavery.” Unfortunately, that’s not enough anymore. Simply taking a supplier’s word at face value doesn’t meet the due diligence requirements of today’s regulations. You need to actively demonstrate that you’ve investigated your supply chain and are aware of where and how your materials are sourced.
That means if you want to avoid stoppages at the border, hefty fines, and reputational damage, you need to be proactive. Authorities now require tangible proof that you’ve conducted thorough due diligence, beyond a code of conduct.
Changing behaviors and ensuring compliance requires more than just a signature. It involves educating your team and your suppliers about what forced labor legislation entails and the importance of adhering to them. Relying on a “scout’s honor” promise isn’t enough to protect your business or, more importantly, the people who may be suffering in your supply chain.
Integrating Human Rights Into Your Business Practices
Addressing modern slavery isn’t just about legal compliance; it’s about embedding respect for human rights into the very core of your business operations. This means implementing strong management procedures that account for both your practices and those of your suppliers:
- Create clear policies that define your company’s stance on human rights and labor practices.
- Invest in training programs for your employees and suppliers to raise awareness about modern slavery risks and compliance requirements.
- Regularly assess your supply chain to identify and mitigate risks.
- Foster open communication with your suppliers and stakeholders to build trust and encourage ethical practices.
- Adopt a holistic due diligence approach by integrating information from other compliance programs like conflict minerals and responsible minerals into your forced labor assessments, noting overlapping risks such as cobalt in the Democratic Republic of the Congo and nickel from Indonesia that are now on the ILAB list.
By taking these steps, you’re not only protecting your business from legal and financial risks but also contributing to a more just and ethical global economy.
How Assent Can Help
Navigating the complexities of global supply chains and staying ahead of evolving regulations can be daunting. That’s where we come in. At Assent, we’ve developed a comprehensive solution to help you meet these challenges head-on:
- We keep you informed about the latest regulations and help you meet all reporting requirements
- Our supplier risk assessments and data analysis provide deeper insights into your supply chain
- Our educational resources, including training modules and awareness programs, ensure everyone understands their role in combating modern slavery
- We ensure you remain compliant with all relevant forced labor regulations, saving you from losing time and resources to a piecemeal approach
By partnering with us, you can demonstrate the due diligence required by today’s stringent regulations and protect your business from the severe consequences of non-compliance.
For more information on modern slavery and your supply chain, check out our eBook, Human Trafficking, Slavery & Your Supply Chain.
Related Solutions
ESG Reporting
See how we build your missing ESG foundation with our complete supply chain sustainability solution.
Human Trafficking & Slavery
Locate and eliminate hidden human trafficking and slavery risks from your supply chain.
