ESG Case Study:
Reed Smith advises a global conglomerate on Modern Slavery corporate obligations across all of its operating jurisdictions
Modern slavery is the severe exploitation of other people for personal or commercial gain. In 2016, the International Labour Organization estimated that there were 40.3 million victims of modern slavery worldwide, including 24.9 million in forced labor. One in four victims of modern slavery are children.
For global corporations operating in high-risk jurisdictions, particularly across Asia and Africa, there is a possibility that supply chains could be tainted with this issue. In addition, certain industries, such as mining, natural resources, construction and transportation, are more prone to the risk of modern slavery and human trafficking, particularly those operating in emerging markets.
Modern slavery legislation has been passed in the United States (State of California), the UK, a number of European countries and Australia, and numerous other jurisdictions are considering introducing similar legislation.
Global corporations may face and need to manage an array of modern slavery regulations in the different jurisdictions where manufacturing, processing or service delivery takes place. Organizations that have fallen foul of modern slavery regulations have faced investigations, reputational damage, import bans and boycott campaigns. The UK government, among others, is also considering introducing additional financial and criminal penalties.
Very mindful of its growing regulatory and ethical obligations in this area and eager to do the right thing, a major global conglomerate with over 100,000 employees and a presence in more than 70 countries wanted to streamline and coordinate its modern slavery procedures to ensure effective compliance across its extensive supply chain and in each of its business locations.
Throughout the course of 2021, Reed Smith worked closely with our multinational client to develop an interactive global map and database to assist the client to fully assess its modern slavery and human trafficking obligations in each of the jurisdictions in which it operates.
The map and database use a traffic light system to indicate where relevant legislation is in force or pending and keeps track of the changing regulatory landscape.
The firm tailored this solution to our client’s specific needs. Through the map application and database, our client could identify, understand and manage its potential global modern slavery and human trafficking obligations in a more streamlined and cost-effective manner.
Compiled into a user-friendly format, this information has created a complete picture of potential risks. The applications have assisted the client to raise awareness of these vital issues and associated laws within the organization, enhance compliance, and increase its transparency and accountability to regulators, customers and its communities.
The Reed Smith team:
The Reed Smith team was led by London-based regulatory partner Rosanne Kay and associate Emma Shafton, and included Global Regulatory Enforcement lawyers based in Brussels, France, Hong Kong and the United States.
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