Legislatures and courts, both in the United States and abroad, are working toward the eradication of labor trafficking in corporate supply chains. In the United States, consumers have sued manufacturers for failing to disclose the presence of forced labor in their supply chains. These claims have been based on consumer protection laws, the Alien Tort Statute, and the Trafficking Victims Protection Reauthorization Act.
Outside the United States, countries around the world—including the United Kingdom, Australia, and the Netherlands—are combating labor trafficking through legislation that requires companies to disclose steps taken to combat forced labor in their supply chains. Furthermore, litigation in the United Kingdom and legislation in the Netherlands has indicated that directors may be personally liable for labor trafficking that occurs in corporate settings.
These new developments demonstrate the increasing global focus on labor trafficking in corporate supply chains. Companies should therefore consider assessing existing compliance programs and consult with counsel and labor experts to ensure compliance with relevant law.