This document discusses efforts to increase transparency and combat forced labor and human trafficking in global supply chains. It outlines initiatives at the governmental, corporate, and NGO levels. At the governmental level, legislation in California and the UK requires companies to disclose efforts to eradicate forced labor in supply chains. Corporations are also developing social responsibility programs and conducting audits of suppliers. NGOs are creating online tools to help consumers identify products that may involve forced labor and evaluate company efforts. However, fully monitoring vast and complex global supply chains remains a significant challenge.

1. 1
By
Jeanne
Crump
HTC
Brief
|
January
2016
Supply Chain Transparency:
New Efforts in Battling Forced Labor and Human Trafficking
Executive Summary
Forced labor and human trafficking within
supply chains is a pervasive problem that is
difficult to remedy. Monitoring a global
corporation’s supply chain is a vast and
complex process that requires considerable
resources. In this brief, I examine the
responses to and efforts in supply chain
compliance from the governmental, corporate,
and NGO sectors. At the governmental level,
legislation in California and the United
Kingdom has been adopted requiring certain
companies to disclose their efforts in
eradicating forced labor in their supply chains.
NGOs are developing online tools
consumers can use to identify products that
may have been produced using forced labor.
Research agencies are conducting
independent assessments by interviewing at-
risk workers on the ground and developing
protocols for Social Responsibility
Programs. But, existing auditing frameworks
in monitoring worker conditions are largely
inefficient and need to be improved.
Corporations need to be held accountable in
conducting assessments on their suppliers at
every tier, not just the top one or two. And
corporations could proactively provide
public supplier lists so that independent
assessments can be conducted more readily
and easily.
This brief does not aim to provide an
exhaustive study of the NGOs or corporate
strategies in battling labor abuses. Rather, it
seeks to serve as an informative guide for
both professionals and consumers on what
is being done in achieving supply chain
compliance and how compliance can be
improved.
Source:
Flickr
Creative
Commons
Seek
Knowledge
|
Secure
Freedom
www.humantraffickingcenter.org

2. 2
The Challenge of Monitoring
Supply Chains
Monitoring a corporation’s supply chain is
no easy task. Major manufacturing
companies and electronics distributors can
have thousands of suppliers that operate
multinational factories, and those suppliers
may have hundreds of subcontractors from
where raw materials are sourced. Tracing
the origin of a product and its materials can
be an enormous undertaking. There is lack
of public data on corporations’ suppliers, so
assessments are difficult to conduct because
this information can be proprietary and
companies are not willing to disclose it.
In addition, the production and
manufacturing process changes rapidly with
improving technology. As explained in an
extensive Huffington Post report, in the last
25 years, as global brands began monitoring
their supply chains more effectively, the
manufacturing and distribution process
completely changed with new technologies.1
These changes have required new methods
of monitoring supply chains.
Workers’ rights also differ from country to
country so enforcing laws on a global level
is not feasible. As explained in Daire (2015),
“The current global supply chain is based on
a dispersed factory model where workers
are spread across the world. Laborers have
less leverage in this type of environment.
Labor rights may be few in some
countries.”2
1
Hobbes, Michael. “The Myth of the Ethical Shopper”,
Huffington Post:
http://highline.huffingtonpost.com/articles/en/the-myth-
of-the-ethical-shopper/
2
Daire, Seth. “Global Supply Chain: Neoliberalism and
Labor,” 2015
Response from Above:
Government and Corporate
Initiatives
Governments are working to provide
consumers with information on the
products they are buying. Most notable is
the California Transparency in Supply
Chains Act of 2012, which requires retail
sellers and manufacturers doing business in
the state with more than $100 million in
annual worldwide gross receipts to disclose
“their efforts to eradicate slavery and
human trafficking from their direct supply
chains for tangible goods offered for sale”.3
According to the US Department of Labor,
it is estimated that the reporting
requirement will impact about 3,200
companies.4 In addition, in 2015, the
United Kingdom also enacted the Modern
Slavery Act, which includes a Transparency
in Supply Chains provision. Under the
provision, commercial organizations
exceeding worldwide gross receipts of $56
million5 who sell goods or services in the
UK must prepare slavery and human
trafficking statements for each financial
year. 6 These statements must include steps
the corporations have taken during the
financial year to ensure that slavery and
human trafficking are absent from their
3
Senate Bill No. 657, Chapter 556, “An act to add Section
1714.43 to the Civil Code, and to add Section 19547.5 to the
Revenue and Taxation Code, relating to human
trafficking.”
4
California Transparency in Supply Chains Act, United
States Department of Labor, accessed Nov 10, 2015:
http://www.dol.gov/ilab/child-forced-labor/California-
Transparency-in-Supply-Chains-Act.htm
5
Global Supply Chain Law Blog, access Nov 10, 2015:
http://www.globalsupplychainlawblog.com/international/
the-uk-modern-slavery-act-or-the-uk-just-got-a-lot-more-
like-california-or-a-domestic-anti-slavery-law-with-
international-implications/
6
Modern Slavery Act 2015, Part 6, Transparency in
Supply Chains. Accessed Nov 10, 2015:
http://www.legislation.gov.uk/ukpga/2015/30/part/6/en
acted#section-54-2

3. 3
supply chains or own business practices.7 It
also requires, much like the California
Transparency Act, that companies publish
the statements on their websites in “a
prominent place.”8
The U.S. Department of Labor has made a
concerted effort to assist businesses in
employing responsible practices. The
Bureau of International Labor Affairs
created a Reducing Child and Forced Labor
Toolkit that can be accessed online and
includes an eight-step process to help
companies develop comprehensive and
transparent social compliance systems.9
Source: www.dol.gov
Some key recommendations include
information on creating a supply chain
map, which encourages businesses to
conduct due diligence on second and third
tier suppliers and identify where those
suppliers are located. It also defines a social
7
Ibid
8
Ibid
9
U.S. Department of Labor:
http://www.dol.gov/ilab/child-forced-labor/
audit and explains how to conduct one
within a company to identify violations of
the code of conduct. It recommends
independent third-party audits and a review
by a certification body. Finally, the toolkit
provides suggestions on developing a
corrective action plan (CAP) when/if abuses
are found.
Corporate Social Responsibility (CSR)
programs within companies have also
grown, with additional resources dedicated
to investigating and disclosing efforts to
eliminate forced and child labor from
supply chains.
Ford Motor Company’s CSR program is
making an effort to document their supply
chain and ensure human rights through the
Code of Human Rights, Basic Working
Conditions and Corporate Responsibility
policy.10 Since 2003, Ford has used a third-
party announced auditing format that
“regularly” audits some of their Tier 1
suppliers.11 Twenty-one at-risk supply
countries were included in the most recent
audit out of 60+ supplying countries. Ford
states it has a goal to audit 25% of their
suppliers. The audits chronicle how well the
suppliers are abiding by laws and “meeting
Ford’s expectations.”12 The independent
assessment uses a detailed questionnaire, a
document review, factory visits, and
management and employee interviews.
Clothing manufacturer and retailer GAP
employs roughly 30 employees in the Gap
Social and Environmental Responsibility
department who collect data through
10
Ford Sustainability Report, 2013-2014:
http://corporate.ford.com/microsites/sustainability-
report-2013-14/supply-materials-trafficking.html
11
Ibid
12
Ibid

4. 4
announced and unannounced visits to
nearly all of the company’s vendor factories
(95-100% depending on year and region).13
The assessment consists of on-site worker
interviews, age-verifying document reviews,
and reports from local NGOs and trade
unions. GAP uses the Code of Vendor
Conduct (COVC) as the backbone for the
assessment that details over 700 potential
violations of Human Rights.14 These 700
markers are lumped into four categories:
Management Systems, Labor, Environment,
and Working Conditions.
Responses from Below: NGO-
Developed Tools to Assess Supply
Chains
The fight to end trafficking and forced labor
has been largely advocated for by NGOs,
independent research organizations, and
academics. Much of the effort in battling
forced labor in supply chains can be seen
through the use of online tools that provide
consumers information on the brands and
products they are buying. For example,
Made In A Free World is an online software
tool that aims to locate and address slavery
and child labor in the supply chain. Used by
buyers and suppliers, the tool identifies
“hotspots of risk” in supply chains and
creates “a customized action plan” for
businesses trying to combat the issue.15
Their method of doing so involves
comparing a company’s purchasing data
against a Global Slavery Database
13
Gap CSR Report 2012:
http://www.gapinc.com/content/csr/html/human-
rights/forced-labor.html
14
Gap Code of Vendor Conduct:
http://www.gapinc.com/content/attachments/sersite/CO
VC_070909.pdf
15
Made In a Free World official website:
https://madeinafreeworld.com/business
comprised of over 54,000 goods, services,
and commodities.16
Products of Slavery, created by Anti-Slavery
International, is an online visualization tool
that shows on an interactive map the
products that are likely to be produced
using child or forced labor. Clicking on a
specific location provides a brief description
of the most prevalent forms of slavery found
in that region, and the products most likely
produced there using forced labor.
Source: Antislavery.org
The site also provides a list of facts for each
product, which includes references to
academic articles and books, government
reports, and other sources from where the
data was collected.
Similarly, Free2Work helps consumers
“learn how your favorite brands are working
to address forced and child labor.”17
Free2Work assigns grades from “A” to “F”
to each brand based on the likelihood that
their products are made with forced or child
labor. They classify company efforts (which
are self-reported in an evaluation tool
created by Free2Work) in four main
categories: policies, monitoring,
16
Ibid
17
Free2work.org

5. 5
transparency, and worker rights.18 In
addition to the evaluation they also assess a
company’s own publications alongside
independent reports and third party data,
such as audit findings and NGO reports.
They grade brands and companies sourcing
from high-risk areas more strictly than
those sourcing from low risk areas.
Free2Work draws risk data primarily from
the U.S. Department of Labor’s List of
Goods Produced With Child Labor or
Forced Labor.19 They then use the U.S.
Department of State Office to Monitor and
Combat Trafficking in Persons ‘Trafficking
in Persons Report’ Tier Placements as a
secondary source of risk information.
Providing tools for businesses to effectively
monitor risk in their supply chains is also a
growing field among NGOs and research
agencies. Know the Chain is an online
source that produces and compiles
resources for businesses and investors who
need to understand and address forced
labor within their supply chains. Know the
Chain serves as a database for briefs,
factsheets, online courses, and learning
modules developed by agencies such as the
United Nations, International Labour
Organization, and US Department of State
to help companies operate responsibly.
Ethical Trading Initiative (ETI) is an
alliance of companies, trade unions, and
NGOs that promote workers’ rights around
the world. They work to bring together
corporate, trade union, and voluntary sector
members in an alliance to adopt the ETI
Base Code of Labor Practice20, which is
18
Ibid
19
Ibid
20
http://www.ethicaltrade.org/about-eti/what-
companies-sign-up-to
based on the standards of the International
Labour Organization (ILO). In addition to
the code, they support initiatives around the
world that raise workers’ awareness of their
rights, and mobilize workers to negotiate
with management. Their alliance of
member companies report annually on their
efforts and results they are achieving.
Verité is a leading research agency that
conducts social and environmental auditing
programs, investigates systems that place
workers in vulnerable positions, provide
training on supply chain compliance, and
consults for companies and governments to
improve working conditions and develop
social responsibility strategies.21
Through Vertité’s supply chain
accountability program, audits are
performed through worker interviews and
surveys “that offer insight into on-the-
ground working conditions.”22
They also conduct Foreign Worker
Assessments that aim to capture conditions
at workplaces that employ foreign contract
or migrant labor. A specific audit conducted
is in the electronics sector against the
Electronics Industry Citizenship Coalition
(EICC) Code of Conduct.23
Assessment
Although recent legislation has been
enacted to address supply chain
transparency, can these efforts make a
difference in battling forced labor? It is too
early to assess whether the UK Modern
Slavery Act has had any influence, but the
21
verite.org/services
22
Ibid
23
http://www.eiccoalition.org/standards/code-of-
conduct/

6. 6
California Transparency Act may have a
peer-pressure effect, causing more
corporations to develop and promote
CSR programs to satisfy both
shareholders and consumers.
According to a 2014 research study
conducted jointly by the American Bar
Association and Arizona State University
that analyzed the supply chain policies of 79
Fortune 100 (U.S. based) companies, 66
percent had publicly available policies
related to human trafficking and 76 percent
had policies related to forced labor.24
According to the study, “the fact that many,
although not all, of the companies
researched have publicly available policies
on these issues is a positive sign.”
Yet, the study also notes that the policies
companies adopt vary widely and may not
all be effective. It was found that 21 percent
of companies were using only internal
monitoring systems, 5 percent using only
external monitoring, and 68 percent using
both internal and external monitoring.25 In
addition, when problems are discovered,
nearly half of the companies provided
general remediation, while only 3 percent
described approaches that provided
remediation to individual victims.
Ethical auditing is described as a thorough
formal examination of the labor practices of
a particular workplace or company. It is a
verifiable process to understand, measure,
report on, and help improve an
24
“How Do Fortune 100 Corporations Address Potential
Links to Human Rights Violations In A Globally Integrated
Economy?”, joint project of American Bar Association,
McMain Institute for International Leadership, Arizona
State University, and School of Politics and Global Studies,
Arizona State University, 2014
25
Ibid, pg 3
organisation’s social and environmental
performance.26
But, auditing and other types of monitoring
pose the risk that they can be manipulated,
which makes it difficult to describe actual
labor conditions.27 In addition, auditing
frameworks may omit the need to inspect
labor issues, and may just pertain to
efficiency and product quality.28 Labor
abuses, specifically those relating to
trafficking or forced labor, may be
overlooked or simply not noticed for a lack
of training and awareness. Furthermore,
the frequency of audits is typically limited
to once a year, with potential of another
unannounced visit. Much can be missed in
one or two visits. Lastly, auditing can be an
expensive process for smaller businesses.
Apple, for example, spent over $250,000
for a Fair Labor Association audit.29
In 2013, The Guardian published “Slaves in
the Supply Chain: 12 ways to clean up the
business.” Genevieve LeBaron at the
University of Sheffield urges for companies
to stop relying on audits.30 She explains,
26
SedexGlobal.com
http://www.sedexglobal.com/ethical-audits/
27
Plambeck, Erica and Terry A. Taylor. “Supplier Evasion
of a Buyer’s Audit: Implications for Motivating Supplier
Social and Environmental Responsibility,” Stanford
University
28
MetricSteam:
http://www.metricstream.com/insights/Supplier_Audits_
Supply_Chain_Governance.htm
29
“A Trip to the iFactory: ‘Nightline’ Gets an
Unprecedented Glimpse Into Apple’s Chinese Core,” ABC
News, Feb 20, 2012
30
Young, Holly. “Slaves in the supply chain: 12 ways to
clean up business,” The Guardian, 2013:
http://www.theguardian.com/global-development-
“The fact that many, although not all, of the
companies researched have publicly available
policies on these issues is a positive sign.” –ABA
and ASU Study.

7. 7
“The pathways of audits are currently built
around products-not-people so they tend to
miss the areas of the labor supply chain that
pose the most risk.”
LeBaron concludes that although the power
of auditing is limited, corporate social
responsibility initiatives and legislation
continue to rely on them as regulatory
instruments. Aidan McQuade, director of
Anti-Slavery International commented in
this discussion that many of the factories
in Bangladesh where workers lost their
lives have been ‘ethically audited’ as have
many of the factories in India where people
are enslaved. He continues, “The purpose
for which ethical auditors are generally
employed is to find nothing,”31 meaning
they are inefficient and faulty.
professionals-network/2013/dec/10/how-to-tackle-
supply-chain-slavery
31
Ibid
This is not to say all audits and auditors are
ineffective or corrupt. As explained by
Kevin Bales, co-founder of Free the Slaves,
those who say audits are misused or
untrustworthy are really referring to a
larger group of companies or institutions
that conduct commercial audits. These
companies might normally conduct
financial audits, and are now offering
ethical audits as well in order to keep their
clients. Bales continued, “Some of these
[companies] are trying to do the right thing,
but have put themselves in the tough
position of wanting to help their clients
avoid problems while being hired to identify
these problems.”
With sparse data on companies’ suppliers,
independent assessments can be difficult to
conduct without the cooperation of the
corporation. First-hand data is also difficult
to acquire. Few research agencies have been
able to employ field staff to interview
workers. Therefore the industry itself is left
with a handful of reports based on the same
data sources, such as the DOL’s List of
Goods Produced With Child Labor or
Forced Labor (cited as a source by many of
the NGOs and research agencies supplying
consumers with information on products).
Organizations creating their own auditing
tools rely on companies to self-report,
which can result in omission of information
and biased or skewed reporting.
NGOs that are working to uncover labor
abuses in the supply chain, such as
“The pathways of audits are currently built
around products-not-people so they tend to miss
the areas of the labor supply chain that pose the
most risk”- Genevieve LeBaron, University of
Sheffield
Kevin
Bales,
shown
above
speaking
at
a
Human
Trafficking
Center
event
on
November
13th,
2015
at
the
University
of
Denver,
says
not
all
audits
and
auditors
are
ineffective
or
corrupt.

8. 8
Free2Work, have a commendable mission,
but according to Claude d’Estrée, Director
of the Human Trafficking Center, there is
serious concern over how they go about the
process of grading companies and products.
Most NGOs do not have the capacity to send
staff to factories to invest these claims first-
hand. Most NGOs rely on secondary data or
self-reporting evaluations by the companies
they are grading.
Finally, there is little data available on
remedial strategies to address labor abuses
when they are found. Further research
could be conducted on industry approaches
to improving workers’ conditions and on
the impact independent auditors are
making with a people-focused framework.
The onset of CSR programs and legislation
demanding transparency is a positive sign.
Leading research agencies such as Verité
are making efforts to collect data directly
from workers. Such data can be powerful
when it reaches consumers or government
bodies. Online tools such as Products of
Slavery are giving consumers easy access to
information on the products they are
buying. Corporations such as Apple are
setting examples by making concerted
efforts to improve workers’ rights and
transparency. Still, more needs to be done
to end abuses and improve auditing tools to
include labor abuse in the framework. Large
corporations need to be held accountable
for putting resources into monitoring their
supply chains and ensuring basic human
rights for all workers they directly or
indirectly employ.
References
“A Trip to the iFactory: ‘Nightline’ Gets an Unprecedented Glimpse Into Apple’s Chinese Core,”
ABC News, Feb 20, 2012
California Transparency in Supply Chains Act, United States Department of Labor, accessed
Nov 10, 2015: http://www.dol.gov/ilab/child-forced-labor/California-Transparency-in-
Supply-Chains-Act.htm
Daire, Seth. “Global Supply Chain: Neoliberalism and Labor,” 2015
Ethical Trade Initiative official website: http://www.ethicaltrade.org/about-eti/what-
companies-sign-up-to
EICC Coalition Code of Conduct: http://www.eiccoalition.org/standards/code-of-conduct/
Hobbes, Michael. “The Myth of the Ethical Shopper,” Huffington Post:
http://highline.huffingtonpost.com/articles/en/the-myth-of-the-ethical-shopper/
Ford Sustainability Report, 2013-2014: http://corporate.ford.com/microsites/sustainability-
report-2013-14/supply-materials-trafficking.html

9. 9
Free2work official website: www.freetowork.org
Gap Code of Vendor Conduct:
http://www.gapinc.com/content/attachments/sersite/COVC_070909.pdf
Gap CSR Report 2012: http://www.gapinc.com/content/csr/html/human-rights/forced-
labor.html
Global Supply Chain Law Blog, access Nov 10, 2015:
http://www.globalsupplychainlawblog.com/international/the-uk-modern-slavery-act-or-the-
uk-just-got-a-lot-more-like-california-or-a-domestic-anti-slavery-law-with-international-
implications/
How Do Fortune 100 Corporations Address Potential Links to Human Rights Violations In A
Globally Integrated Economy?,” joint project of American Bar Association, McMain Institute
for International Leadership, Arizona State University, and School of Politics and Global
Studies, Arizona State University, 2014.
Made In a Free World official website: https://madeinafreeworld.com/business
MetricSteam:
http://www.metricstream.com/insights/Supplier_Audits_Supply_Chain_Governance.htm
Modern Slavery Act 2015, Part 6, Transparency in Supply Chains. Accessed Nov 10, 2015:
http://www.legislation.gov.uk/ukpga/2015/30/part/6/enacted#section-54-2
Plambeck, Erica and Terry A. Taylor. “Supplier Evasion of a Buyer’s Audit: Implications for
Motivating Supplier Social and Environmental Responsibility,” Stanford University:
http://haas.berkeley.edu/faculty/papers/taylor_evasion.pdf, 1
Senate Bill No. 657, Chapter 556, “An act to add Section 1714.43 to the Civil Code, and to add
Section 19547.5 to the Revenue and Taxation Code, relating to human trafficking.”
SedexGlobal.com http://www.sedexglobal.com/ethical-audits/
U.S. Department of Labor: http://www.dol.gov/ilab/child-forced-labor/
Verité offiical website: www.verite.org/services
Young, Holly. “Slaves in the supply chain: 12 ways to clean up business,” The Guardian, 2013,
Accesed Nov 10, 2015: http://www.theguardian.com/global-development-professionals-
network/2013/dec/10/how-to-tackle-supply-chain-slavery

10. 10
About the Human Trafficking Center
The Human Trafficking Center (HTC) is a nonprofit research and advocacy
organization committed to using academic rigor and transparency, sound
methodology, and reliable data to understand forced labor and human trafficking.
Our aim is to provide research that improves inter-organizational cooperation and
accountability, influences anti-trafficking policy, and raises public awareness about
the problem. We also partner with academics, students, legislators, NGOs, and
international organizations to provide the public balanced information about human
trafficking. The HTC is housed within the Josef Korbel School of International Studies at
the University of Denver and is comprised of M.A. candidates and faculty. Visit us
online at humantraffickingcenter.org or on social media:
facebook.com/humantraffickingcenter and Twitter @du_htc
Jeanne Crump is the Research Projects Manager at the Human Trafficking Center and
a M.A. Candidate of International Development at the Josef Korbel School of
International Studies. She can be reached directly at Jeanne.M.Crump@gmail.com.