The business community has a significant role to play in advancing progress towards ending human trafficking, including all forms of forced labor and sex trafficking, which are the 21st century’s manifestation of slavery.
"Fully engaging the corporate community is a critical step in the war to end modern day slavery. Human trafficking is a global problem which can only be eradicated by mobilizing global solutions. Corporations need to take action, get involved and become part of the solution."
David Arkless, Founding Counselor and Board Member, gBCAT
gBCAT accomplishes its mission by supporting companies through the following:
• Providing a resource for orientation and operational guidance to companies who desire to understand human trafficking and how it affects business.
• Championing and disseminating best practices in business to end human trafficking, including all forms of forced labor and sex trafficking.
• Driving connections between businesses and governments, international organizations, non-profits and civil society for the purpose of knowledge- and idea-sharing on solutions to address human trafficking.
• Training and Education: Employee, vendor and sub-contractor training programs.
• Supply Chain: Identifying and preventing forced labor in supply chains and operations.
• Sex Trafficking: Raising awareness of company policies to combat sex trafficking notably in travel and tourism.
• Communication and Outreach: Thought leadership and transfer of best practices.
To mobilize the power, resources and thought leadership of the business community to end human trafficking, including all forms of forced labor and sex trafficking
“Trafficking in Persons” and “Human Trafficking” have been used as umbrella terms for the act of recruiting, harboring, transporting, providing, or obtaining a person for compelled labor or commercial sex acts through the use of force, fraud, or coercion. The Trafficking Victims Protection Act (TVPA) of 2000 (Pub. L. 106-386), as amended, and the Palermo Protocol describe this compelled service using a number of different terms, including involuntary servitude, slavery or practices similar to slavery, debt bondage, and forced labor.
Human trafficking can include but does not require movement. People may be considered trafficking victims regardless of whether they were born into a state of servitude, were transported to the exploitative situation, previously consented to work for a trafficker, or participated in a crime as a direct result of being trafficked. At the heart of this phenomenon is the traffickers’ goal of exploiting and enslaving their victims and the myriad coercive and deceptive practices they use to do so.
Training and Education:
Raising awareness of company policies to combat sex trafficking notably in travel and tourism.
Identifying and preventing forced labor in supply chains and operations.
Thought leadership and transfer of best practices.
Robert Rigby-Hall is Executive Vice President & Chief Human Resources Officer for NXP Semiconductors (NASDAQ: NXPI) a global semiconductor company with operations in more than 25 countries, 26,000 employees and revenues in excess of US$4 billion. With over 25 years of global experience as an HR leader for large global corporations; he is unique in his field in that he has run businesses and lived and worked internationally in the UK, Europe, Asia-Pacific, and the United States.
Robert is involved in industry organizations and is a speaker at business conferences around the world, including the Beijing International Publishing Forum, Financial Services Technology Expo, Annual Recruitment Learning Conference, Net Impact Conference, The Human Resource Forum, Global Roundtable on Advanced Management Education Reform, The Vatican / U.S. Department of State – Building Bridges to Freedom, and CEO Connections.
He sits on the Advisory Boards of Kiddy & Partners, Qualigence and The Economist Education. He is the past Chair of Boys Town of New York; past Chair of the Somaly Mam Foundation; and Co-Chair of the Global Business Coalition Against Human Trafficking. In 2010 he was awarded the “Business Leader Award” by the UN Global Initiative to Fight Human Trafficking & UN Global Compact.
He attended Portsmouth University in the United Kingdom and completed the Harvard Executive Development Program and the Kellogg Certificate in Corporate Board Governance at Northwestern University. Robert has three school-age children and lives in Singapore.
Dawn Conway is currently the Chief Operating Officer for Cision US, Inc. Cision is a leading provider of cloud-based PR software, services and tools for the marketing and public relations industry. Marketing and PR professionals use our products to help manage all aspects of their brands – from identifying key media and influencers to connecting with audiences; monitoring traditional and social media; and analyzing outcomes.
Prior to joining Cision in 2012, Conway spent over 20 years at LexisNexis in a number of key leadership positions including serving as Senior Vice President, Corporate Responsibility for LexisNexis. In this role she led a number of initiatives focused on advancing the rule of law and is a founding member of the Global Business Coalition Against Human Trafficking. Conway is the recipient of the 2011 Nomi Network Corporate Social Responsibility Award and a frequent speaker on the role of business in combatting human trafficking.
Her public speaking engagements include Engaging Business: Addressing Human Trafficking in Labor Sourcing sponsored by the U.S. Council International Business, U.S. Chamber of Commerce and International Organization of Employers; Creating the Ripple Effect: the Global Women’s Initiative sponsored by Womenetics; CSR and Human Trafficking What Every Business Needs to Know The Role of Business in Human Trafficking; Social Entrepreneur Conference hosted by the Harvard Business School and Kennedy School of Business and HumanTrafficking and The Rule of Law; the World Justice Forum III.
Conway is the co-author of Doing Well by Doing Good “CSR for Bars” published in the Spring 2012 Bar Leader Magazine, an ABA publication. She has her J.D. and is a member of the District of Columbia Bar, National Association of Women Lawyers and a member of the American Bar Association Anti Human Trafficking Presidential Task Force
David Arkless was until 2013, ManpowerGroup’s Global President of Corporate and Government Affairs. Mr. Arkless is a world-renowned expert on labor market trends and has widespread experience of helping countries to develop their labor market strategies. In 2011, he became Vice President of Ciett, the international confederation of private employment agencies. He is responsible for governmental and international affairs, and as such has been called to advise the governments of China, Mexico, Vietnam, Serbia and Singapore, as well as to the US Department of State, the European Union and the cities of Shanghai, Tianjin, Dalian and El Paso/Juarez regarding skills, talent, employment and social policy. In May 2010, he became Vice President of the China International Council for the Promotion of Multinational Corporations (CICPMC) in Beijing and is an advisor and supporter of the All Party Political Group on East Asia, empowering the Asian diaspora in the UK society and building links between the East Asian and UK business communities. Mr. Arkless also managed ManpowerGroup’s strategic relationships with high-profile organizations such as the World Economic Forum, where he is one of the founding members of the WEF’s Global Agenda Council on the Skills Gap. He also supports partnerships with the European Policy Centre and the Clinton Global Initiative, and is an Ambassador for the Centre For Social Justice, an independent think tank based in the UK.
His global areas of social contribution involve, amongst others, being a highly influential campaigner in the fight to end human trafficking and giving refugees real hope for the future through training and work. Mr. Arkless was President of the Board of End Human Trafficking Now, the leading global organization empowering the business community to eradicate human trafficking and modern day slavery, and co-founder of the Washington Business Ending Slavery and Trafficking organization, launched in the first quarter 2012, a not for profit focusing on mobilizing small to medium sized enterprises against trafficking in the US. He has also been at the forefront of ManpowerGroup’s involvement in www.ninemillion.org, a UN initiative to provide education to the 9 million young refugees all over the world. Mr. Arkless is also a founding member of the Demand Abolition Advisory Council, based in the United States. Additionally, Mr. Arkless serves as an Advisory Board Member of both the International Organization for Migration and the office of the United Nations High Commissioner for Refugees (UNHCR). He also serves as a Board Member of Education For Employment, the pre-eminent US-based foundation that helps unemployed young people and the long-term unemployed in the Middle East and Africa. He is also a board member of the Club of The Hague. In 2011, Mr. Arkless joined the advisory board of PNB-NAPEO a public-private partnership that exists to better link young entrepreneurs and business leaders in the United States and the Maghreb. Earlier this year, he was voted onto the Board of the Arab International Women’s Forum – an organization empowering women and working on inclusion in the Arab world as well as building bi-lateral business links between the Arab world and British business.
He serves as a regular speaker at high profile events including the World Economic Forum Annual Meeting in Davos, the Organisation for Economic Co-operation and Development (OECD), the United Nations, European Parliament, UK Parliament & House of Lords Select Committees, US Congressional and Senate committees, and at various internationally renowned business schools. Mr. Arkless also led ManpowerGroup’s involvement with the United States Council on Competitiveness. Mr. Arkless received his bachelor’s degree from the University of Durham, UK and has completed executive programs at INSEAD, IMD, and the San Jose College of Business. Mr. Arkless is also a Fellow of the Royal Society of Arts in London.
Letty Ashworth is currently the Manager of Global Diversity for Delta Air Lines, Inc., the world’s largest airline. As manager of Global Diversity, Letty has oversight of the strategy and implementation of diversity initiatives for the company. As part of the broader HR group, she works closely with recruiting, marketing and community affairs. She also has oversight of the company’s Employee Network Groups and an external Diversity Alliance comprised of corporate, non-profit and educational representatives from the Atlanta community.
Dan Bross, Microsoft’s Senior Director of Corporate Citizenship, has over twenty-five years of experience in the public, private and nonprofit sectors. With a background in public policy and government and public affairs, Dan has led government affairs and policy teams at both the federal and state levels for two Fortune 100 companies.
He joined Microsoft in 1998 and in 2002 led a cross company virtual team that developed Microsoft’s global Citizenship Program. Today, Dan leads a team with Citizenship responsibilities focused on issues management, reporting, stakeholder engagement and strategic relationship management.
In addition to his corporate experience, Dan has management and program development experience in the nonprofit sector. During his tenure as Executive Director AIDS Council, the nation’s leading AIDS advocacy organization, he chaired a broad national coalition of health and human service organizations and non-governmental organizations and served as an advisor to President Clinton’s Domestic Policy Advisor on the structuring and staffing of the White House Office of National AIDS Policy.
He holds a B.A. in Political Science from Catawba College in Salisbury, NC and a master’s degree in Public Administration from the George Washington University in Washington, DC.
Dan currently is currently a member the Board of Trustees of Catawba College; the Executive Leadership Forum of Boston College’s Center for Corporate Citizenship; Co-Chair of The Conference Board Committee on Corporate Political Spending and Co-Chair of the Board of Directors of Net Impact.
Mark P. Lagon is Professor in the Practice of International Affairs, and Global Politics and Security Chair, at the Master of Science in Foreign Service Program at Georgetown University. He is also Adjunct Senior Fellow for Human Rights at the Council on Foreign Relations. He is Founding Counselor of GBCAT and serves on its Board of Directors.
Lagon was previously Executive Director and CEO of the leading anti-human trafficking nonprofit, Polaris Project, which operates the U.S. Government’s national anti-trafficking hotline (1-888-3737-888).
From 2007 to 2009, with rank of Ambassador, Lagon directed the Office to Monitor and Combat Trafficking in Persons (TIP) at the U.S. Department of State. As such, he chaired by statute the Senior Policy Operating Group coordinating all U.S. agencies efforts to combat human trafficking domestically and internationally.
From 2004 to 2007, Lagon served in the Bureau of International Organization Affairs at the U.S. Department of State as Deputy Assistant Secretary, where he had lead responsibility for United Nations-related human rights and humanitarian issues, UN reform, and outreach.
Lagon previously served as a member of the Secretary of State Colin Powell’s Policy Planning Staff, where he focused on UN, democracy and human rights (2002-2004).
From 1999 to 2002, he was on the senior staff of the Senate Foreign Relations Committee, with responsibility including the United Nations and human rights.
Previously he won a Council on Foreign Relations Fellowship, where he specialized on U.S. policymaking toward in China (1998-1999); served at House Republican Policy Committee (1997-1998); worked for former UN Ambassador Jeane Kirkpatrick as her principal aide at the American Enterprise Institute.
Dr. Lagon is currently a Member of the Leo Nevas Task Force on Human Rights of United Nations Association; the Board of Directors of the Council for a Community of Democracies, as well as the Advisory Boards of ECPAT-USA (End Child Prostitution Child Pornography and Trafficking of Children for Sexual Purposes) and The Stanley Foundation.
He is author of the book, The Reagan Doctrine: Sources of American Conduct in the Cold War’s Last Chapter, and dozens of published essays on human trafficking, human rights, the UN, and U.S. policy making, notably regarding China. He is co-editor with Anthony Arend of the forthcoming book, Human Dignity and the Future of Global Institutions. He has a Ph.D. from Georgetown University and an A.B. magna cum laude from Harvard College.
Thomas Niemann is the Social Sustainability Manager in the Sustainability & Vehicle Environmental Matters department at Ford Motor Company. He has been at Ford since December 1999. Thomas’ previous positions within Ford include Sustainability Reporting Manager; Manager, Executive Chairman’s Office; and Program Manager, Environmental Outreach and Strategy.
Thomas is responsible for the Company’s Policy Letter 24 regarding Code of Human Rights, Basic Working Conditions and Corporate Responsibility, which includes assessment and compliance; identification of emerging issues (e.g., conflict minerals) and stakeholder engagement.
Thomas, a retired U.S. Army Lieutenant Colonel, holds Bachelor and Master’s Degrees in Communications from the University of Michigan (Ann Arbor).
Mr. Pepper spent a 40 year career in various positions at Procter & Gamble, including Chief Executive Officer and Chairman from 1995 – 1999 and Chairman of the Board from 2000 – 2002. He served as Director of Procter & Gamble from 1984 – 2003 and President from 1986 – 1995.
John E. Pepper, Jr. currently serves as Co-Chairman of the Board of the National Underground Railroad Freedom Center and was CEO from January 2006 – May 2007. Mr. Pepper served as Chairman of the Board of the Walt Disney Company from January 2007 through March 2012 and had served as a member of its board since January 2006. He also served as Vice President of Finance and Administration at Yale University from January 2004 to December 2005.
Pepper also serves on the Board of the Stellar Restaurant Group (Boloco) and was a co-founder and currently is a member of the Executive Committee of the Cincinnati Youth Collaborative.
Pepper graduated from Yale in 1960, where he served on the Board of the Yale Daily News. He served as Fellow of the Yale Corporation from 1995 – 2003, including two years as Senior Fellow.
A native of Pottsville, Pennsylvania, Mr. Pepper holds honorary doctorate degrees from Yale University, Xavier University, Mount St. Joseph College, St. Petersburg University (Russia), the Ohio State University, the University of Cincinnati and St. Joseph’s University.
Mr. Pepper and his wife Francie have four children and reside in Wyoming, Ohio.
Ed Potter is currently Director, Global Workplace Rights for The Coca-Cola Company.
He is currently the Chairman of the Labor and Employment Policy Committee, U.S. Council for International Business and a member of President Obama Administration’s Consultative Group focusing on forced and child labor in agriculture.
He is currently a member of the National Advisory Committee on Free Trade Agreements. Since 1997, he has held the role of the U.S. Employer Delegate of the International Labor Organization (ILO).
In 1998, Ed was the employer spokesperson for the negotiation of the ILO Declaration on Fundamental Principles and Rights at Work. Since 2005, he has held the role of the employer spokesperson for the ILO Committee on the Application of Conventions and Recommendations, which holds countries accountable for their obligations resulting from the ratification of ILO conventions.
He has an extensive background in international labor, workplace rights and employment law issues, with 26 years’ experience as attorney.
He holds a BA, Economics, Michigan State University and a Master’s, Labor Economics and Collective Bargaining from Cornell University. He holds a law degree from American University.
Nigel is responsible for managing the LexisNexis relationships with international legal associations and leading industry groups, including the International Bar Association, the Commonwealth Lawyers Association, the Union Internationale des Avocats and Lex Mundi. Nigel has previously managed key industry relationships with state, local and national bar associations across the US.
In recent years, Nigel’s role has included partnering with global associations on various CSR and rule of law projects, including programs and initiatives to help combat human trafficking.
Nigel is a Vice-Chair to the American Bar Association Section of International Law Corporate Social Responsibility Committee and International Corporate Counsel Committee, and liaison to the American Bar Association Center for Human Rights Human Trafficking Project Advisory Committee. Nigel is a Court Appointed Special Advocate (CASA), in New Hampshire.
Nigel joined LexisNexis in 1984. Prior to his relocation to the U.S. in June 1993, Nigel had a successful career as an Area Manager for Butterworths in the U.K. with responsibility for sales of legal and tax information. Nigel holds a BA in Legal Studies and was admitted as a Fellow of the Institute of Legal Executives in the U.K. where he spent ten years working in private practice and with a local government legal department, prior to joining Butterworths.
As Director of Responsible Business at Carlson Rezidor Hotel Group, Ms. Schultz is responsible for all aspects of social, ethical and environmental responsibility for a portfolio of more than 600 hotels in the Americas. Her duties include hotel training, communications, environmental measurements; and support for the International Tourism Partnership, World Childhood Foundation, and The Code of Conduct for the Protection of Children from Sexual Exploitation in Travel and Tourism (The Code); for which she currently serves on the Board of Directors.
Ms. Schultz has championed anti-trafficking initiatives within Carlson, developing and launching robust human trafficking awareness training for employees and sharing that training within the industry.
She has joined with others in law enforcement, government, non-profit and private sectors to bring awareness of human trafficking to Minnesota Congress and Senate members, and participates on the US Department of Transportation’s Transportation Leaders Against Human Trafficking committee. She has spoke on the topic of human trafficking for organizations such as the American Hotel & Lodging Association, Harvard Kennedy School and Georgetown University among others.
A native of Forest Lake, Minnesota, Ms. Schultz holds a bachelors degree from the University of Wisconsin at River Falls.
Dirk Vande Beek is Senior Vice President, Corporate and Government Affairs for Travelport. In this role, Dirk provides strategic direction and manages relationships with governments and international organizations through strategic and tactical global public affairs programs. Dirk also directs Travelport’s Corporate Social Responsibility and philanthropic programs and projects.
Dirk joined Travelport from CA, formerly Computer Associates Inc., where he was instrumental in creating and managing its government relations function. Previously, Dirk served as Vice President of Public Relations for The Coca-Cola Company, where he developed and implemented global public relations strategies. Dirk also served as Global Manager of Public Relations at the Halliburton Company.
Dirk’s experience in Washington D.C. includes serving as the Director of Communications and Press Secretary for Vice President Dick Cheney in the 2000 Presidential Campaign, as well as Deputy Director of Communications for the 2001 Presidential Inaugural Committee. From 1988-1993, he was Senior Assistant to the Director of the Federal Emergency Management Agency (FEMA). He also served in the Communications Department in the U.S. Department of Labor.
In 1993, Dirk was awarded the Distinguished Civilian Service Medal for his service to the U.S. Federal Government.
Dirk holds a bachelor’s degree in History from Westmont College in Santa Barbara, California
Microsoft’s firm commitment to fighting human trafficking has been demonstrated by a number of corporate initiatives in collaboration with partners from NGOs and the public sector. Microsoft technically developed and sponsored an e-learning tool in collaboration with End Human Trafficking Now and UN.GIFT by the United Nations Office on Drugs and Crime. It is an online training program for business leaders, managers and employees of businesses to help them understand what human trafficking is, identify where it might be a risk to their business, and point to actions they can take to address this risk. The tool can be easily retrieved at http://www.microsoft.com/middleeast/humantrafficking/. In particular, the Microsoft MEA Citizenship Team was recently approached by Nike to integrate the e-learning tool on the Nike Corporate website, in Nike’s effort to fight Human Trafficking in the company’s supply chain.
Furthermore, the Child Exploitation Tracking System (CETS) represents another successful initiative. Upon the Toronto Police’s request, Microsoft developed this unique software tool designed by investigators for investigators to share, search and collaborate on investigations relating to child exploitation. The program integrates and complements current database systems in use, basing its reporting and tracking features on a particular field (nickname, IP address, etc.) or user. To date, Microsoft invested over $10 million in CETS in Brazil, Canada, Chile, Indonesia, Italy, Romania, Spain and the UK, and an additional 13 countries are actively evaluating its adoption. A total of 1,400 investigators were trained, with 800 investigators currently using CETS worldwide. To date, 220 users were arrested in 9 Canadian provinces – multiple arrests were also attributed to CETS.
For more info click here
“Carlson has set the standard with its efforts to raise awareness of child sex trafficking and child sex tourism.”-Luis CdeBaca, Ambassador-at-Large to Monitor and Combat Trafficking in Persons – U.S. State Department
Carlson is a global hospitality company and the world leader in business travel management. Carlson was one of the early industry leaders to combat child sex trafficking by committing to increasing awareness of this issue among its worldwide network of 170,000 people employed in more than 150 countries. For more than a decade, Carlson has served as a model to others who wish to ensure that the travel and hospitality industry is not used as an enabling environment for the trafficking of children.
Carlson began working to end child sex trafficking in 1999 by joining with Her Majesty Queen Silvia of Sweden in the establishment of the global organization, World Childhood Foundation, which is committed to helping the world’s street children – those who are most vulnerable to human trafficking. In 2004, Carlson signed the travel industry’s universal “Code of Conduct for the Protection of Children from Sexual Exploitation in Travel and Tourism” (The Code). The Carlson Rezidor Hotel Group deploys a unique child protection training program for its employees which enables them to be watchful and appropriately report suspicious activity. . The training includes a film clip from the renowned documentary depicting the horrors of human trafficking, “Not My Life,” which was partially funded by the Carlson Family Foundation., The training is required of all Carlson Rezidor hotel and corporate employees. In this way, the company is able to enlist its extensive employee network as a “global army of eyes and ears” in the fight to protect the world’s children.
The company’s work has been recognized by several organizations including the United Nations which honored former CEO Marilyn Carlson Nelson with the UN. Gift and “End Human Trafficking Now!” Business Leader’s Award for her efforts to inspire others to join in this endeavor. Carlson continues to increase its engagement and collaboration with governments, national and international organizations as well as other hospitality and travel companies through the course of their work in the anti-trafficking movement. As one of the founding members of gBCAT, Carlson will continue to work with businesses across industries to leverage their voices to eliminate all forms of human trafficking.
The Coca-Cola Company (the Company) is a US-based multinational with over 130,000 employees worldwide. It manages a portfolio of more than 500 brands with over 3,500 different beverage products, from sparkling and still beverages to fruit juices, energy drinks, teas and coffees. The company brands are sold in over 200 national markets globally.
Within The Coca-Cola System, there are nearly 250 bottling companies that are partners of the Company. These are mostly independently-owned companies with a long-standing and close relationship with The Coca-Cola Company. As bottlers, they are the ones that manufacture, package and distribute the finished branded products to retailers and customers such as grocery stores, convenience stores, restaurants and movie theatres . An average of more than 1.8 billion servings of Coca-Cola products are sold every day.
In the Gulf Region – which is part of Coca-Cola’s operations in the Middle East and Eurasia region – 21 bottling plants operate within the Company’s system. Two of these are directly owned by the Company, with the remainder operating independently. These plants employ between 250 and 500 workers each, with employees typically engaged in production (25%), distribution (30%) and delivery, sales and other operations (45%). These bottling plants themselves have a further 28 core suppliers providing key ingredients (such as sugar) and packaging, for example cans and printed material. Supplier companies, in turn, employ between 100 and 500 workers, depending on the nature of their work and their level of mechanisation.
Workplace rights at the Coca-Cola Company
The Coca-Cola Company’s corporate responsibility expresses an over-arching concern for social and environmental sustainability. Within this context, the Company develops programmes on issues as diverse as water stewardship, sustainable packaging, community engagement, economic impact, and workplace rights.
In addressing the latter, the Company has developed a broad set of principles framed within its Workplace Rights Policy . These principles are guided by international human and labour rights standards, including the ILO’s Declaration on Fundamental Principles and Rights at Work . They apply to workplace rights in The Coca-Cola Company itself and to entities which the Company owns or in which it holds a majority interest, for example the two bottling plants in the Gulf Region. The policy commits to fair and dignified treatment of all employees and prohibits all forms of forced or compulsory labour, including prison labour, indentured and bonded labour, military labour and slave labour. The policy aims to ensure that a consistent approach is applied to workplace rights across global operations and that these principles are integrated into day-to-day business operations, strategy and corporate culture.
The Coca-Cola Company’s workplace rights commitment also extends to its direct and authorised suppliers (e.g. bottling plants) and their business partners, the companies that supply the packaging, key ingredients, and other goods and services. The Coca-Cola Company acknowledges a responsibility to hold these suppliers to standards no less than those required by applicable laws and regulations.
These expectations are outlined in the Company’s Supplier Guiding Principles , which provide a set of standards integrated into all supplier agreements. The guiding principles emphasise:
• The importance of responsible workplace policies and practices;
• The minimum requirement to comply with applicable labour (and environmental) laws and regulations;
• The explicit prohibition of forced labour and other forms of coercion and abuse in the workplace; and
• The expectation that suppliers will develop and implement internal business processes to ensure compliance.
The Supplier Guiding Principles are supplemented by implementing guidelines that provide detailed information on issues such as compliance assessment process, steps that suppliers can undertake to comply with policies, examples of policy violations, corrective measures, best practices and supplier’s roles and responsibilities.
Significantly, these policies clearly outline the risks of forced labor among migrant workers hired through labor brokers. The Company restricts certain practices to mitigate these risks as further explained below.
To assess compliance with these policies and principles, The Coca-Cola Company uses independent, third-party social audits to review workplace rights at suppliers across its supply chain. These audits involve confidential worker interviews with employees and contract workers, and follow protocols and guidelines developed by the Company following extensive validation with external stakeholders.
A diagram representing these diverse layers or spheres of The Coca-Cola Company’s anti-trafficking policies looks like this:
For more information on The Coca-Cola Company’s Workplace Rights Policy, please visit: http://www.coca-colacompany.com/our-company/workplace-rights-policy
The issue: Migrant workers and document retention in supply chains
In early 2009, The Coca-Cola Company began auditing its suppliers in the Middle East and Gulf Region. This included the 19 independent bottling plants and 2 owned and operated by the Company itself. The countries covered included Bahrain, Kuwait, Oman, Qatar, United Arab Emirates and Yemen.
In the first several assessments by third party auditors, it became immediately clear that almost all of the supplier facilities in the region were withholding the passports of migrant workers. When asked why this was taking place, managers typically informed the auditors that this was either required by law, a customary practice or a requirement of insurance companies to safeguard against significant cash theft.
Although the withholding of personal documents is not automatically an indicator of forced labour or coercion in the workplace, nevertheless the practice can be considered an indication of abuse if workers cannot access their passports at their own discretion or if they feel unable to leave their jobs without the risk of losing the document. Withholding the passports of migrant workers can:
• Limit their freedom of movement;
• Indicate a lack of consent to employment;
• Inhibit their ability to obtain another job should they want to do so; and
• In some cases, even limit their access to social or health care services to which they might be entitled.
The Coca-Cola Company response
The Coca-Cola Company response to these audit findings was immediate. The Company commissioned a third party review of national laws and regulations of the countries concerned, and followed up with an immediate tour of the region and its suppliers by senior management from regional and global headquarters.
On the basis of this research, the Company developed further guidance and implementation guidelines on the issue of passport retention, which supplemented its Supplier Guiding Principles. This guidance was developed and validated in a two stage process in the early months of 2009, and subsequently completed in May of that year. The guidelines were then shared with supplier facilities in the region and supported by face-to-face training, ongoing written communications and one-to-one follow-up with supplier relationship managers. Once the new guideline had been distributed, a one-day seminar was held by The Coca-Cola Company for all of its suppliers in these countries. The seminar offered suppliers the opportunity to discuss the new policies, raise questions about them and address next steps in implementing operational changes. This consultative process and the clarity of the new guidelines led to rapid agreement by suppliers and the immediate implementation of changes.
Since the implementation of the new guidelines in mid-2009, no instances of passport retention have been reported or detected by audits. In order to sustain this improvement, The Coca-Cola Company maintains ongoing monitoring and has built the issue and guidelines into routine supplier communications and forums.
Building on the success of this engagement, the Company has implemented additional global polices and guidance to address risks of forced labor among migrant workers. The policies cover both the recruitment and the employment phase and require that:
• Work shall be represented in a truthful, clear manner and in the local language;
• Worker shall not pay recruitment fees (including transportation to and from host country); and
• Worker shall have access to personal identity documents.
• Social auditing can play an essential role in bringing to light certain risks of abuse within the supply chain.
• A collaborative approach of engaging suppliers directly in the change process can greatly facilitate such change and improvements in the supply chain.
• Long-term business relationships and ongoing, regular contact between buyers and suppliers can have a positive impact in implementing changes in the workplace.
• Leading by example and pioneering change and improvements at directly owned facilities can enhance the credibility and legitimacy of those requesting improvements.
• A company’s sphere of influence may extend not only to its immediate suppliers, but to sub-contractors and even third party business partners that provide labour or other services.
• Companies that supplement codes of conduct with implementing guidelines and that assist suppliers in capacity building and in developing management systems usually experience a greater success in ensuring suppliers’ compliance with policies.
The automotive supply chain is one of the most complicated of any industry. Automakers like Ford rely on thousands of suppliers to provide the materials, parts and services necessary to make their final products. Many suppliers serve numerous automakers, and each of those suppliers, in turn, has multiple sub-suppliers. There are often 6 to 10 levels of suppliers between an automaker and the source of raw materials that eventually enter the manufacturing process. The breadth, depth and interconnectedness of the automotive supply chain make it challenging to effectively manage business and sustainability issues.
Understanding and, where necessary, working with suppliers to help improve working conditions in their facilities is one of the key focus of Ford’s human rights efforts. This is a major undertaking, as Ford has tens of thousands of supplier facilities globally (see below). It is also a critical task, as they have less control in suppliers’ facilities than in their own, and sourcing is increasingly expanding to emerging economies.
Ford’s Global Working Conditions Program:
Human rights and working conditions are a primary focus of Ford’s work with suppliers. The Company aims to ensure that everything they make – or others make for them – is produced consistent with local laws and Company policies. This can be particularly challenging at the sub-tier level, where the risk for substandard working conditions is often heightened and the Company has less control. For this reason, Ford had to define its approach carefully and involve suppliers, other automakers, governments, nongovernmental organizations (NGOs) and other stakeholders.
Ford has extensive policies addressing workplace rights, including forced labor and human trafficking, both in company’s own and suppliers’ facilities. The key principles of this policy are framed in the Company’s Code of Human Rights, Basic Working Conditions and Corporate Responsibility. The Code is based in international standards and provides guiding principles for human rights, labor, and environmental standards throughout its global operations.
Ford’s engagement and commitment to fair labor practices extends beyond a formal code of conduct. Among other things, the Company:
• Assists suppliers in building capacity and provides training in working conditions in the framework of the Automotive Industry Action Group (AIAG). Participants are required to cascade the information they learn to management and all personnel within their own company, as well as to their direct suppliers. As of 2012, the Company had directly trained 2,100 suppliers. Through the aforementioned cascading process, the training has impacted to nearly 25,000 supplier managers, more than 430,000 individual workers, and nearly 85,000 sub-tier supplier companies.
• Assesses direct suppliers’ compliance with company policies and labor standards. Assessments are conducted by third party qualified social auditors and include a detailed questionnaire, a document review, factory visits, management and employee interviews, as well as a corrective action plan, if any nonconformity is detected.
• Requires all direct suppliers to abide by the Company’s Global Terms and Conditions, which prescribe that both the Company’s own suppliers and their sub-tier suppliers meet specific expectations, including assuring proper working conditions. They specifically include prohibition of the use of forced labor, child labor and physical disciplinary abuse. In addition, the Global Terms and Conditions serve to:
o Set the expectation that suppliers will work toward alignment with the Company’s Code in their own operations and their respective supply chains
o Make clear Ford’s right to perform third-party site assessments to evaluate supplier performance
o Communicate that Ford can terminate the relationship for noncompliance or for failure to address noncompliance in a timely manner
• Provides suppliers with detailed implementing guidelines. These web-guides amplify the expectations set out in the Global Terms and Conditions, provide specific guidance and recommendations for self-assessments, and inform suppliers on the availability of training programs.
For more information on Ford’s sustainability efforts, please visit www.corporate.ford.com
The issue: Use of forced labor by raw materials sub-suppliers in Brazil
The International Labour Organization (ILO) estimates that 25,000 to 40,000 workers are still victims of conditions analogous to slavery in Brazil. The problem is particularly serious in the Amazon region, where widespread poverty and the vast distances make it very difficult to detect violations. Although most of the workers start their employment voluntarily, they end up trapped in bonded labor due to vast debts with labor brokers that use misleading and abusive practices to recruit workers .
In 2006, Ford discovered that charcoal produced in Brazil with the use of slave labor had found its way into its supply chain. Pig iron is a key ingredient in steel production, and in Brazil, charcoal is often used as fuel in the production of pig iron. The charcoal is made from wood harvested in remote areas of Brazil where instances of forced labor have been found to occur. At the time this issue was brought to the Company’s attention in 2006, pig iron was purchased directly by Ford and used at their Cleveland Casting Plant.
Upon learning of the situation in Brazil, Ford immediately decided to stop sourcing from the site that was identified in the investigation. However, they continued dialogue with the pig iron supplier and helped them to develop management systems until such time as the supplier could ensure it was not supporting forced labor in the supply chain for pig iron. The Company then identified all potential points of entry for pig iron in Ford’s value chain and engaged with all relevant suppliers, seeking assurances from them that forced labor was not employed anywhere in their value chain. This included an intensive mapping of five to six tiers of suppliers (including importers, exporters and trading companies). The Company also requested additional details regarding tier 1 suppliers’ systems for safeguarding human rights throughout their operations, including procurement.
The Cleveland Casting Plant was closed in 2010, and Ford no longer directly purchases pig iron. Regardless, the Company has continued, through integrated supplier development programs, to convey the prohibition of forced labor and to validate, where possible, supplier compliance. Validation continues to be challenging given the number of supply chain actors between Ford and the charcoal camps in Brazil. For this reason, in 2011 the Company renewed an inquiry into the potential points of entry for Brazilian pig iron to its supply chain and is evaluating specific supplier progress on management systems to ensure responsible procurement of this material. Ford is also working with the U.S. State Department, the ILO and the governing committee of the Brazilian National Pact to Eradicate Forced Labor to seek multilateral solutions that will help to validate information and improve transparency.
In response to this situation, Ford together with other U.S. automakers decided to start to work together to offer collective training for suppliers on how to avoid purchasing supplies produced using forced labor. This initiative was first coordinated by the Automotive Industry Action Group (AIAG) and then by Business for Social Responsibility. Initial projects from the initiative include joint statements to create a shared industry voice on various issues relating to working conditions, including forced labor.
In addition, several local companies together with international organizations and the Brazilian government created the Citizens Coal Institute (ICC) with the aim of preventing forced labor instances in the Brazilian charcoal industry. The organization has created a code of conduct and sends inspectors to assess compliance and to disseminate the code. Non-compliant suppliers are decertified and purchases by ICC’s members are discontinued .
This case study illustrates Ford’s proactive approach to addressing human rights issues deep in the Company’s raw materials supply chain. It also underscores the importance of the major effort the Company is undertaking to assess, train and engage suppliers on the Company Code of Conduct and assist them in integrating the Code into their own policies and systems.
Companies face important challenges in managing forced labor impacts in complex supply chains with multiple tiers of suppliers over which little control can be asserted. Ford’s initiative requiring tier 1 suppliers to cascade policies and training to their own suppliers is an effective tool to disseminate best practices and to improve working conditions in sub-tier suppliers. In addition, companies must be ready and able to react to force labor allegations by quickly launching “ad hoc” investigations. Finally, contract clauses enabling companies to cease commercial relations until noncompliance cases are remediated provide suppliers with an important incentive to comply with policies.
A code of conduct is just the first step to ensure fair labor practices in supply chains. Companies need to engage suppliers and assist them developing their own policies and management systems to ensure compliance. Suppliers should do the same with their own suppliers, and so on.
Broader patterns of forced labor like the one described in this case, require not only individual responses by companies, but also coordinated action by industry organizations, governments and other stakeholders, both in the country of origin and of destination. The actions by the ICC illustrate a good step in this direction.
The mission of gBCAT Supply Chain Subcommittee is to reduce risks of human trafficking in business operations by exchanging best practices and sharing information among companies, and by developing tools to prevent, detect and eradicate forced labor in supply chains. During the Subcommittee meetings, members exchange points of view and share best practices to manage human trafficking impacts in complex supply chains. Currently, the Subcommittee is working on a Supply Chain Toolkit that will include the following components:
• Anti-trafficking policies assessment tool
• Tool for detecting risks of products manufactured with forced labor
• Strategies for mapping supply chains in a cost-effective manner
• Questionnaire for assessing suppliers’ compliance with company anti-trafficking policies
• Best practices compilation and case studies
The mission of gBCAT Sex Trafficking Subcommittee is to develop innovative policies and tools to address sex trafficking, especially in the travel and hospitality industry. During the Subcommittee meetings, members exchange their experiences and challenges in developing and raising awareness of company policies. The Subcommittee is working on a Sex Trafficking Toolkit that will include the following components:
• Strategies for detecting sex trafficking instances
• Policies and procedures for what may or may not be done if trafficking is suspected
• Strategies to raise awareness on company anti-trafficking policies among employees
• Strategies on how employees can get involved in the solution by personally volunteering at a shelter and making financial contributions, including the creation of company matching programs
• Compilation of best practices and case studies
gBCAT will develop training resources for orientation and operational guidance to companies who desire to understand human trafficking and how it affects business. Separate training programs will be created for supply chain and for the travel and hospitality industry.
In supply chain, gBCAT will develop additional modules to the e-learning tool developed by Microsoft Corporation together with EHTN and UN.GIFT. In the travel and hospitality industry, gBCAT will develop a core curriculum following the example of our members Delta Air Lines and Carlson Rezidor. Training programs will be then customized to the specific needs of each company/industry.
gBCAT believes that a multi-stakeholder collaborative approach is key to succeed in the fight against human trafficking. gBCAT is continuously seeking partnerships with governments, international organizations, non-profits and civil society in order to identify and formulate solutions to prevent forced labor in supply chains and business operations, and to raise awareness among the business community and the general public. gBCAT frequently organizes and participates in conferences and forums to discuss emerging challenges and solutions.
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ONE STEP FORWARD: HOW COMPANIES CAN JOIN THE FIGHT AGAINST HUMAN TRAFFICKING
JANUARY 10, 2014, 9:30am – 3:00pm
Hosted by Delta Air Lines
1030 Delta Blvd
Sponsored by the Global Business Coalition Against Human Trafficking – gBCAT
Join us for a business-to-business discussion on how companies can get involved in the fight against human trafficking:
This conference will focus on business solutions to address emerging challenges in managing human trafficking risks, including mapping supply chains, hiring migrant workers, training employees, implementing codes of conduct and anti-trafficking reporting. The panelists will emphasize practical ways any company and their employees can use to get involved in the fight against trafficking, offering tools, networks and sharing best practices. This event is directed to CSR, supply chain, HR, legal and compliance leaders, interested in human trafficking, in networking with other likeminded professionals and in getting straight responses to hard questions.
The event will feature panels with experts in the following topics:
• Human Trafficking Update: New Anti-Trafficking Legislation
• Best Practices in Hiring Migrant Workers
• The Role of Technology in Human Trafficking
• Best Practices to Fight Human Trafficking in the Travel, Hospitality and Entertainment Industries
• Challenges of Managing Human Trafficking Impacts in Complex Supply Chains
For more information please contact us at firstname.lastname@example.org
What Can the U.S. Government and American Companies Do to End Human Trafficking?
On December 5, gBCAT Directors Ambassador Mark Lagon and Letty Ashworth (Delta Air Lines) joined Cindy McCain to discuss multi-stakeholder collaborative approaches for fighting human trafficking and insisted on the need of bringing governments, NGOs and businesses together to reduce the number of trafficking victims. The event was organized by Human Rights First as part of their 2013 Human Rights Summit.
(Read more here)
Preventing Child Trafficking & Exploitation: Strategies and Programmes That Work!
On the International Day of the Rights of the Child, November 19, gBCAT Co-Chair David Arkless, joined other human trafficking experts on a panel addressing the ways that governments and civil society, including children themselves, have taken steps to stop trafficking, as well as the critical success factors in the efficacy of official state-sponsored programmes and those implemented by civil society. The panel was hosted by the UN Headquarters in New York.
Human Trafficking e-learning Course
This e-learning course is designed to provide a better understanding of human trafficking and its challenges. Designed to serve as an interactive, web-based resource, the e-learning tool will help identify the potential risks of human trafficking in a business and point out actions that can be taken to address them. The e-learning course was created by UN.GIFT and the EHTN! Campaign, with the support of private partners. The tool is technically developed and sponsored by Microsoft.
Profits and Poverty: The Economics of Forced Labor
According to this new ILO report, forced labor in the private economy generates $150 billion in illegal profits every year, about three times more than previously estimated. This report contains detailed information on the profits generated by different types of forced labor and breakdowns by region, industry and vulnerable populations.
Trafficking in Persons Report 2013
The Trafficking in Persons Report is a comprehensive resource for the study of government efforts in the fight against human trafficking. It includes an examination of the anti-trafficking framework of countries around the world. Each country is placed onto one of three tiers based on the government’s efforts to tackle human trafficking.
U.N. Guiding Principles on Business and Human Rights
The U.N. Guiding Principles represent the first internationally endorsed set of guidelines on business and human rights. The Principles, developed by former UN Special Representative of the Secretary General on business and human rights, John Ruggie, are organized under the “Protect, Respect and Remedy” framework.
U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor, 2013
ILO Global Estimate of Forced Labour 2012
United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children
The UN Trafficking Protocol is one of the three Palermo Protocols that supplements the UN Convention Against Transnational Organized Crime. It establishes the international legal framework for the fight against human trafficking based on the three internationally recognized themes of prevention, protection and prosecution (the 3Ps) and national and international cooperation and coordination.
Trafficking Victims Protection Act
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