- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Aaron Nicodemus2024-03-11T16:31:00
The first step is admitting there is a problem, and child labor is a growing one in the United States.
In the past, child labor violations might have appeared as a distant concern—something that happens overseas, elsewhere, away. Or, it was considered to be at low risk of occurring in the United States.
As a result, U.S. compliance officers have not been accounting for the possibility of child labor violations in their risk assessments. They weren’t considering how and where child labor violations might be occurring. They weren’t taking into account the potential blowback on their company’s reputation if abuses were found within the labor pool used to develop their company’s product or service.
In short, the U.S. compliance community has not been spending time addressing a problem mistakenly thought to be a rarity.
What’s changed? The driving force is the rising flow of underage migrants coming to the United States.
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It’s been nearly two years since the Uyghur Forced Labor Prevention Act took effect, and as enforcement statistics and recent reports demonstrate, many businesses are still not adequately vetting their supply chains.
The Department of Labor ordered Tennessee-based Tuff Torq Corp. to pay nearly $1.8 million over alleged child labor violations.
The European Union announced an agreement to ban products made with forced labor, a decision that will oblige organizations to track and declare more information about their supply chains for goods entering EU markets.
Rooting out potential child or forced labor violations in your company’s supply chain can have benefits beyond protecting reputation and being ethically sound. The process can also help your firm comply with pending child labor laws in other jurisdictions.
Although compliance should be the company’s primary responsibility, auditors have become the last line of defense and are getting pressured and blamed for supply chain issues, including instances of child labor. Is this expected to become the normal for the profession?
Supply chain and ethics and compliance professionals could take a page out of the social media influencer playbook and look to collaborate with suppliers more to create their own win-win scenarios.
