Human Trafficking and Modern Slavery Part 2: A Discussion with William Shephard [Podcast]

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By Adam Turteltaub
adam.turteltaub@corporatecompliance.org

In Part 1 of this two-part podcast on human trafficking and modern slavery we explored the scope of the issue and the risks to organizations that they may inadvertently have victims within their supply chain, or even working in their facility.

In this podcast, William Shephard, a partner in the Washington and West Palm Beach offices of Holland & Knight, explains that there are specific compliance requirements already on the books that organizations must include in their compliance plans.  He explains that:

  • There are already two types of laws on the books
  • The first set requires reporting efforts by the organization to examine its supply chain for human trafficking and modern slavery
  • California and the UK already have strong disclosure requirements, and the subsequent California regulations goes well beyond simple disclosure
  • The second set of compliance requirement prohibit purchases by US Federal government entities from organizations that do not certify that their supply chain is free of human trafficking and slavery
  • It is essential to look out for warning signs that the workforce may include victims of human trafficking and modern slavery
  • Warning signs include whether there is a written contract in the employee’s native language with the employer and if the employee must surrender his or her passport to the employer
  • Other red flags to look for include recruitment fees that employees must pay to get the job and substandard pay and housing
  • For those in healthcare, there are already requirements to post information