Prohibiting federal contractors from charging workers recruitment fees is a cornerstone of the Federal Acquisition Regulation (FAR) requiring contractors and subcontractors to take specific preventive measures to detect and eliminate forced labor and human trafficking in their supply chains. In December 2018, the U.S. Government amended the FAR to include a comprehensive and clear definition of what constitute “recruitment fees.”
Many company’s forced labor, human trafficking, or ‘modern day slavery’ disclosures – whether mandated by transparency regulations or part of broader sustainability, corporate social responsibility, or human rights reporting – do not reflect a credible understanding of how specific practices of value chain partners and recruitment intermediaries in their supply chains expose vulnerable workers to the risk of forced labor. Consequently, many of the detection and prevention efforts outlined in these disclosures are not sufficiently targeted to effectively address the root causes of these insidious and deeply entrenched abuses.
In 2016, Verité launched the Responsible Sourcing Tool (RST), providing a resource to federal contractors to meet the anti-trafficking compliance measures in the Federal Acquisition Regulation. The tool was developed with support from the U.S. Department of State’s Office to Monitor and Combat Trafficking in Persons. In addition to federal contractors, the interactive website helps companies, advocates, and consumers detect, prevent, and combat trafficking in global supply chains and meet the growing number of legal, regulatory, and market demands for attention to severe exploitation in global supply chains. After a year of operation, Verité takes a look at the progress that has been made.
Last month, the Electronics Industry Citizenship Coalition (EICC) announced, as part of its commitment to eradicating forced labor, the results of a special out-of-cycle membership vote amending version 5.0 of the EICC Code of Conduct to further protect workers by prohibiting all recruitment fees.
In previous Vision pieces, we have pointed out that Executive Order 13627 on “Strengthening Protections against Trafficking in Persons in Federal Contracts” is designed to bolster the U.S. government’s zero-tolerance approach to trafficking in persons in federal contracts. On January 29, 2015, the FAR (Federal Acquisition Regulation) Council released the much awaited “final rule” designed to implement the Executive Order signed by President Obama in September 2012, and Title XVII of the National Defense Authorization Act for 2013 (“Ending Trafficking in Government Contracting”)—both of which will require federal contractors and subcontractors to take specific proactive preventive measures to detect and eliminate human trafficking and forced labor in their supply chains.