Combat slavery in supply chains

Employers are responsible for providing safe workplaces.

In 2016 it became illegal to import goods with ties to modern slavery.  Employers will need to define and clarify how worker rights and entitlements are protected.

LSS flow chartUS Congress has banned the import of seafood made from forced and child labor.  Departments of Labor, State, and Homeland Security Customs and Border Protection are developing enforcement.  Consumer petitions against the List of Goods made from Child or Forced Labor may trigger inspections.

In the UK, disclosures are mandatory and overseen by the new Anti-Slavery Commissioner.  Seafood companies in Europe have operated under a ban on imports tied to illegal fishing since 2010.

Bottomline: Make sure you have credible evidence onhand to understand your options.  Interview workers to learn how they are paid, any costs, and how they get into work and out again, including any fees and terms with manning agencies.  If you can’t reach them, ask your vendors to provide owners’ names and addresses for all facilities and vessels in your supply chain.  If you have too many products to check every origin, look into findings by the authorities at the US Departments of State and Labor or the UK High Commissioner’s office and understand what they expect.  Reach out to anti-trafficking experts, human rights and frontline NGOs.  Check back with producers to be confident the efforts are helpful.

Don’t be surprised to find real exposures to forced labor in production that hadn’t been noticed before.  Good targets for business are contracts with working conditions, costs and payments spelled out.  The rule to remember is the cost of any work done for the business must be paid by the business.  Prohibited fees are things like deductions from pay for basic gear and equipment, medical attention for work-related injury, and food.  Special attention is needed to the extra exposures migrant workers may have lacking language and sometimes legal status in the country of work.  Withholding of ID is never okay unless legally required.   Employers must understand the details of the crew contract with manning agencies. Contact us to get this work done efficiently and properly the first time.

To learn more, you are welcome to read our 2016 briefings:

Labor Safe Screen briefings are peer reviewed by federal agents and food executives.



In addition to getting your own house in order, wider initiatives to combat slavery in seafood, like the Sustainable Shrimp Supply Chains Taskforce offer a way to get involved.

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Safe Seafood = Safe Fish + Safe People