Insight

How compliance can help prevent human trafficking

Written by David Povey on Friday July 29, 2022

Today is the United Nation’s World Day Against Trafficking in Persons,[1] with this year’s theme ‘Victim’s Voices Lead the Way’. Now, this is a tragic topic and one that we would all rather not have to think or talk about. But that is precisely why it is so important.

There are a number of charities and bodies that seek to raise awareness of, and prevent, human trafficking – but their work can sometimes seem distant and detached from our roles as compliance professionals. This article will consider how to bridge that gap, asking what we can do to stop human trafficking, with a particular focus on supply chains.

What is human trafficking?

In the United Nations protocol to prevent, suppress and punish trafficking in persons, they set out the following detailed definition:

The recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, or the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation… [including] sexual exploitation, [and] forced labour… slavery or practices similar to slavery, servitude or the removal of organs.[2]

This was the first legally binding instrument with an internationally recognised definition of human trafficking, a significant step in terms of prevention. However, since 2000 the volume of human trafficking hasn’t slowed, with a 2018 report [3] by the Financial Action Task Force (FATF) highlighting that the proceeds from human trafficking had exceeded $150 billion – a huge increase on the $32 billion figure quoted in a similar report from 2011 – making it the third most lucrative crime across the globe behind drugs and weapons.

Why is it an issue for compliance?

Our focus here is on supply chains, as these often bring us into contact with third parties and international travel. The complexity and nature of supply chains across the world has made them prime targets for human trafficking activity. Moving goods and services between countries and across land, sea and air, opens up avenues for traffickers to exploit. Honest and hard-working companies can find themselves being used by criminals, and though often they will be totally unaware that this is happening, the consequences for these companies can be severe.

Beyond the moral and ethical imperative, companies must recognise that a failure to prevent trafficking leaves them exposed to financial, legal, reputational and operational risks. It is their responsibility to make sure that these risks are properly identified and addressed. It is hoped that any unscrupulous parties involved in a supply chain are discovered when a financial institution carries out both its onboarding work and ongoing due diligence.

Another point where wrongdoing may be discovered is through good transaction monitoring practices. Read more about the importance of this here.

Risks and challenges for firms

Access to global markets: your business could lose access to global markets — remember, you can’t grow where you can’t go.

Reputational damage: unethical business practices expose your brand to potential damage which can be hard, or impossible, from which to recover.

Unable to prove you are compliant: unless you have transparency in your supply chain it can be very difficult to prove you have carried out robust due diligence.

Taking focus away from success: bad news is always more powerful that good news, and failings in your supply chain will detract from any business growth goals you have in place.

The points above highlight some of the challenges faced by firms, but let’s not forget that at the heart of human trafficking are the thousands of people that are suffering and struggling every day. Companies may face particular difficulties, and it is important to face up to these and protect themselves, but a far bigger benefit of preventing human trafficking is the reduction of the dangers that the victims endure. To put it simply, we can all keep our eyes and ears open and be more aware of the signs of human trafficking.

What can we do?

To put it simply, we can all keep our eyes and ears open and be more aware of the signs of human trafficking.

Stop the Traffik has identified a number of signs that are common across all types of exploitation, including if a person:

acts as if instructed by another, as though they are forced or coerced to carry out specific activities
demonstrates signs of physical or psychological abuse, such as lacking self esteem, seeming anxious, bruising or untreated medical conditions
seems to be bonded by debt or has money deducted from their salary
has little or no contact with family or loved ones
is distrustful of authorities
has threats made against themselves or family members
is not in possession of their own legal documents.[4]

For companies, they must adhere to important requirements, typically dictated in regulations.

Record and report efforts to identify and remove slavery from any supply chains. This obligation may arise where a certain profit threshold is met but it is best practice to be vigilant in all business.
Carry out a high level of due diligence on all parties they engage with, including suppliers, agents and contractors. Companies should obtain certificates from these parties that demonstrates their compliance with standards relating to human trafficking.
Ensure that adequate training is provided to employees regarding human trafficking.

In more practical terms this means that companies should:

facilitate policies that will prevent human trafficking
execute robust training and awareness programmes
maintain continuous monitoring to spot trafficking risks
obtain compliance certification from suppliers, and
implement and maintain a helpline to allow reporting of trafficking.

Human trafficking is a serious, widespread problem, but one that we can all help to identify and do our best to prevent. Through awareness, monitoring and reporting, compliance professionals and their companies will be better placed to make a difference in the global fight against this terrible activity.