STOPPING FORCED LABOR IN THE SUPPLY CHAIN
U.S. Customs and Border Protection (CBP) released a new CTPAT Alert this week specifying what CTPAT members must do to comply with the new forced labor requirements that took effect on January 1, 2023 which includes documenting the threat of forced labor in their supply chains.
“CTPAT importers, exporters, and foreign manufacturers must include the threat of forced labor—an illegal activity under U.S. and international law—into the company’s risk assessment methodology. And, they must also document how they address this threat through a documented social compliance program—also referred to as a social responsibility program (or responsible sourcing).” CTPAT Alert March 2023
The alert defines a social responsibility program as “a set of policies and practices through which a company seeks to ensure maximum adherence to the elements of its code of conduct that covers social and labor issues. Social compliance refers to how a business addresses its responsibilities in protecting the environment, as well as the health, safety, and rights of its employees, the communities in which they operate, and the lives and communities of workers along their supply chains.“
CTPAT members are required to document their efforts to mitigate the threat of forced labor in their supply chains in addition to the key elements of the social compliance program CTPAT members already follow. These steps include:
1. Engaging stakeholders and partners
2. Assessing risks and impacts
3. Engaging in robust communication
4. Training internally and across your supply chain to ensure understanding
5. Requiring codes of conduct from suppliers
6. Allowing confidential reporting
7. Contractual obligations
8. Monitoring complaints: targeted audits and proactive worker participation
9. Remediating violations
10. Independent review
11. Reporting performance
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