The holiday season is a time for contemplation, reflection, and planning for the future. Having spent nearly two years in a pandemic, moreover, has no doubt caused many of us to reassess our values and priorities. With the...more
12/29/2021
/ Child Labor ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Corporate Governance ,
Corporate Social Responsibility ,
Environmental Social & Governance (ESG) ,
International Labor Organization (ILO) ,
NGOs ,
Popular ,
Supply Chain ,
UNICEF
[Warning: The juxtaposition of joyous holiday festivities and forced labor is not intended to make light of human rights violations, but to assist companies in avoiding common mistakes in their anti-human trafficking...more
On Tuesday, October 23, 2018, the Ninth Circuit Court of Appeals issued an important opinion reviving a decade-old Alien Tort Claims Act (ATS) suit based on alleged aiding and abetting slave labor in cocoa farms on the Ivory...more
11/9/2018
/ Aiding and Abetting ,
Alien Tort Statute ,
Appeals ,
Buyers ,
Child Labor ,
Claim Amendments ,
Corporate Liability ,
Domestic Corporations ,
Farm Workers ,
Farms ,
Financing ,
Forced Labor ,
Foreign Corporations ,
Human Rights ,
Remand ,
Reversal ,
Sellers ,
Slavery ,
Supply Chain
On Monday, June 4, 2018, the Ninth Circuit Court of Appeals issued an important opinion, Hodson v. Mars, Inc., holding that food manufacturers do not have any independent obligation under California consumer protection laws...more
In the wake of the 2016 dismissal of human rights cases filed against food companies in California, a new class action case was filed on February 26, 2018 in Massachusetts federal court (Tomasella v. Hershey Co.) alleging...more
3/7/2018
/ Child Labor ,
Consumer Protection Laws ,
Cooperative Compliance Regime ,
Corporate Social Responsibility ,
Food Manufacturers ,
Forced Labor ,
Hersheys ,
Human Rights ,
Human Trafficking ,
Risk Mitigation ,
State and Local Government ,
Supply Chain ,
Transparency
[Warning: The juxtaposition of the jolly old man and forced labor is not to make light of human rights violations but to highlight the hidden evils in supply chains and the potential reputational damage to wholesome...more
12/21/2017
/ Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Forced Labor ,
Human Rights ,
Human Trafficking ,
Manufacturers ,
Modern Slavery Act ,
Pending Legislation ,
Retailers ,
Supply Chain ,
Tariff Act of 1930 ,
Trade Facilitation and Trade Enforcement Act ,
Transparency in Supply Chains Act ,
UK
Amnesty International recently released a report alleging that supply chains for production of palm oil—a common ingredient in many consumer products—are tainted by forced and child labor. In the nearly 150-page report titled...more
12/2/2016
/ Amnesty International ,
Child Labor ,
Disclosure Requirements ,
Due Diligence ,
Forced Labor ,
Human Rights ,
Internal Controls ,
Manufacturers ,
Modern Slavery Act ,
Retail Market ,
Retailers ,
Risk Management ,
Risk Mitigation ,
Supply Chain ,
Transparency in Supply Chains Act
The holiday retail season is an ideal time to check that forced labor and bribery—two top and interconnected supply-chain threats—do not undermine the success of your critical sales period.
Not long ago, many in the...more
11/28/2016
/ Anti-Bribery ,
Bribery ,
Cooperative Compliance Regime ,
Corruption ,
Disclosure Requirements ,
Due Diligence ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Holidays ,
Human Rights ,
Human Trafficking ,
Manufacturers ,
Modern Slavery Act ,
Pending Legislation ,
Proposed Legislation ,
Securities and Exchange Commission (SEC) ,
Subcontractors ,
Supply Chain ,
Tariff Act of 1930 ,
Transparency in Supply Chains Act ,
UK
The federal government took another step in the fight against human trafficking and forced labor. President Obama signed into law on February 24, 2016, the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), which...more
3/4/2016
/ Child Labor ,
Corporate Counsel ,
Forced Labor ,
Human Rights ,
Human Trafficking ,
Imports ,
Manufacturers ,
New Legislation ,
Reporting Requirements ,
Slavery ,
Supply Chain ,
Tariff Act of 1930 ,
Trade Facilitation Agreement ,
Young Lawyers
Companies doing business in the United Kingdom take note: the U.K. government just made the not-so-long-awaited announcement that businesses with an annual turnover of 36 million British pounds (£36M) will be subject to the...more
8/10/2015
/ Compliance ,
Disclosure Requirements ,
Due Diligence ,
Human Trafficking ,
Manufacturers ,
Modern Slavery Act ,
Posting Requirements ,
Reporting Requirements ,
Retail Market ,
Revenue ,
Slavery ,
Supply Chain ,
Transparency in Supply Chains Act ,
UK ,
Websites
It is that time of year again when we dust off the compliance crystal ball and take a look at what might be in store for 2014.
1. Executive Order 13627 Changes Government Contracting -
Want a government contract...more
1/15/2014
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Conflict Mineral Rules ,
Corporate Counsel ,
Enforcement ,
Enforcement Actions ,
Executive Orders ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Office of Foreign Assets Control (OFAC) ,
Securities and Exchange Commission (SEC) ,
Supply Chain ,
Whistleblowers
Supply chain compliance is on the government’s enforcement radar like never before. If the recent Executive Order on Trafficking in Government Contracts and final SEC Conflict Minerals Rules were not notice enough, the...more