The U.S. Department of Labor ("DOL") introduced a handbook to help businesses combat child labor and forced labor in their global supply chains. The DOL's Bureau of International Labor Affairs released the report, entitled, “Reducing Child Labor and Forced Labor: A Toolkit for Responsible Businesses,” last week, and it is the first of its kind, and is being released on the heels of the Department of Labor's investigation of Forever 21 and its supply chain. Coincidence? Probably not.
The Toolkit focuses on the need for companies to create social compliance programs that integrate the Bureau of International Labor Affairs' policies and practices to ensure the business entity acts to prevent child labor and forced labor throughout its supply chain. The Toolkit provides step-by-step guidance on the following eight critical elements to aid companies that do not currently have social compliance systems in place or those interested in strengthening existing systems:
1) engaging stakeholders and partners;
2) assessing risks and impacts;
3) developing a code of conduct;
4) communicating and training across the supply chain;
5) monitoring compliance;
6) remediating violations;
7) ensuring independent review; and
8) reporting performance.
Moreover, the report estimates there are 215 million children in child labor worldwide, 115 million of them in hazardous forms of work. It also estimates that 21 million people are in forced labor, six million of them children. Child labor includes instances of children (minors under age 18) working in the worst forms of child labor (“WFCL”) as described in ILO Convention 182, as well situations where children engage in work that is exploitative and/or interferes with their ability to attend school. It highlights key nations where modern-day slavery and unsafe working conditions are commonplace, particularly, China, India, Argentina, Jordan, Malaysia and Thailand. These countries are known to use child and/or forced labor in apparel manufacturing.
The Toolkit lists a number of reasons that motivate employers to develop social compliance systems to combat child or forced labor, including: complying with existing laws such as the Dodd-Frank Act and the Consumer Protection Act; meeting public expectations of a companies’ control over labor standards and human rights in their supply chains through voluntary standards such as the Organization for Economic Cooperation and Development Guidelines for Multinational Enterprises; maintain eligibility for loans from the U.S. Government through programs such as Overseas Private Investment Corporation, which require compliance with specific labor and environmental standards, including standards on child and forced labor; recruiting and retraining employees; and doing good.
The Toolkit can be downloaded at no cost at http://www.dol.gov/ChildLaborBusinessToolkit.