Corporate Social Responsibility: Human Trafficking and Business Dilemmas

Valentina Lodola-Rahaman graduated with an M.S. in Fundraising and Grant Making from New York University with a capstone-thesis entitled, “Human Trafficking: The Global Becomes Local,” that focused on the domestic aspect of human trafficking. In addition, her research work as an Emerging Leaders International Fellow with the Center on Philanthropy and Civil Society, focused on community philanthropy: exploring how data collection, Next-Gen donors, and community foundations can help fight human trafficking. In this article, she illustrates how companies can avoid the risk of human trafficking by taking steps to make it harder for traffickers to traffic people using their products, premises or services and by helping raise awareness of the problem.


Although most countries abolished slavery 150 years ago, bonded and forced labor, trafficking and exploitation persists. The illegal trade in human beings for the purpose of sexual exploitation or forced labor is currently described as a form of “modern-day slavery” and is used in common parlance to describe the enslavement into labor and commercial sexual exploitation of women, men and children.

Trafficking in human beings is not only the 21st century manifestation of slavery but also a global epidemic that plagues almost every region, country and economic sector. The use of trafficked persons can be found across the supply chain in various sectors, such as: agriculture and horticulture, construction, garments and textiles, hospitality and catering, mining, logging and forestry, food processing and packaging, transportation, domestic services, care and cleaning work. Recent examples include global clothing companies that have been accused of exploiting migrant workers in Asia, while chocolate and confectionary companies have been reported employing children who have been trafficked for forced labor under deplorable conditions in cocoa farms in West Africa.

How is human trafficking affecting companies?

Companies and businesses are affected by trafficking in various ways, both directly and indirectly, and it is important to realize that human trafficking operations may exist alongside legitimate businesses. In the first place, companies may be directly connected to the practice through the recruitment, transport or receipt of a trafficking victim into the company or into one of its own subsidiaries. This can occur whether or not the company is aware of it, or whether its own management or human resources department is at fault or a third-party labor provider, for example a private employment agency. Companies could also be directly implicated and employers could face a direct liability if their premises, products or services are used for the purpose of trafficking (e.g., in the transport, tourism or hospitality sectors). In the second place, employers could also be indirectly linked to trafficking. This refers to global brands and the first tier of global supply chains, where forced labor and human trafficking are hidden from view as a consequence of complex and frequently outsourced recruitment and hiring practices.

Whether companies and businesses are directly or indirectly linked to trafficking, a set of business risks is associated with human trafficking, such as: legal risks, threats to brand value and company reputation, trade-related risk, threats to investment and finance.

Why does human trafficking represent a business dilemma?

Dilemmas exist because there is a perceived conflict between the need for a business to respect and support human rights but also to operate in certain countries, regions, areas, situations or circumstance of high exposure to effectively and profitably deliver its core business objectives. The Human Rights Business Dilemmas Forum (HRBDF) is an online, multi-stakeholder platform for multi-national corporations with operations, supply chains and distribution networks in regions of the world that pose risks to their responsibility to respect human rights. The Forum is hosted on the UN Global Compact (UNGC) website, funded by the General Electric Foundation and implemented by Maplecroft in partnership with the UNGC. The forum is specifically designed to help companies and stakeholders understand and share experiences of how they have addressed human rights challenges through a wide array of tools, including: human rights analysis, tool for human rights due diligence, 18 dilemma areas, more than 150 company case studies, resources and links, discussion forum with more than 6000 users and more than 250,000 pages downloaded.

Human trafficking is a worldwide human rights issue, and one that is difficult to tackle. In this context, what actions can companies take to address the potential that their operations may be linked to human trafficking?
Companies should consider the following proactive steps:

  • Conducting due diligence to evaluate the risks of human trafficking associated with the company’s operations, including its supply chain. For global brands the due diligence could include a human rights impact assessment in regions with a high incidence of human trafficking cases;
  • Developing stand-alone policies and standards on human trafficking, or ensuring that prohibitions on human trafficking are incorporated into existing human rights policies and standards;
  • Ensuring that prohibitions on human trafficking and forced labor are included in contractual requirements for contractors and suppliers;
  • Providing training to managers and employees on how to identify and report indicators of human trafficking and forced labor. Establishing effective grievance mechanisms, procedures for investigation and reporting, and protection for whistle-blowers;
  • Identifying and engaging with relevant industry initiatives and other potential partners that can provide critical support for company training and risk assessment efforts; and
  • Annual public reports on performance.

The devastating individual and societal consequences of human trafficking demand a multi-faceted strategy from companies. To deliver such a strategy, companies need to partner with other industry leaders, suppliers, non-governmental organizations, trade unions, child right’s organizations, law enforcement, consumers, governments and communities in multi-stakeholder initiatives and public-private partnerships to responsibly and effectively confronting the issue. Specifically, companies are urged to participate in initiatives like the newly forming Business Coalition Against Human Trafficking comprised of company representatives from a cross-section of industries (e.g., ManpowerGroup, Microsoft, CocaCola, Ford, Delta and Carlson) that focus on developing and sharing best practices for addressing the vulnerability of businesses to human trafficking in their operations.

Nowadays, the travel and hospitality industry has become more conscious of its unique position to address trafficking problem. As an industry, it represents a virtual army of hundreds of thousands of eyes and ears in the air and on the ground. Airline Ambassadors International (AAI) is the only independent charity of the airline industry and has become integrally involved in the global fight against human trafficking. AAI worked closely with Homeland Security and Customs Border Protection to develop an industry specific training consistent with the Department of Homeland Security’s “Blue Campaign”. The training is tailored to the travel sector including airline/airport personnel, hotel employees, tourism companies, law enforcement and ground transportation. Among U.S. airline companies, Delta was the first airline company in the world to sign the Tourism Child-Protection Code of Conduct in 2011. The Code, created by ECPAT, in partnership with the tourism industry is a set of six guidelines that travel companies implement to put in place policies and programs that can effectively deter and react to instances of child sex trafficking.

Human trafficking is an emerging issue in CSR and reflected in the policies of some of the world’s leading companies. Despite the proactive approach and good work of business pioneers, the majority of companies and industries around the world have failed to prioritize the issue with the urgency that deserves.

Business Case for Corporate Compliance with New Human Rights Legislation

All businesses everywhere, regardless of their size, have a responsibility to respect human rights. Over the last two decades compliance with human rights has increased prohibiting corporate manager to deny or evade CSR. Corporate officers who fail to meet this responsibility can subject their companies to the courts of public opinion—including employees, communities, consumers, civil society, as well as investors—and place at risk the worth of their companies reputation and stock.

A global framework is now in place:

  • The United Nations “Protect, Respect and Remedy” Framework for Business and Human Rights (2008), the subsequent UN “Guiding Principles on Business and Human Rights” and “The Framework and Guiding Principles on Business and Human Rights” that were unanimously endorsed by the UN Human Rights Council in 2011.

Corporate supply chain reporting on human rights issues is being legislated:

  • The most recent examples are: the Conflict Minerals Special Disclosures provision of the Dodd-Frank Financial Reform Act and, the California Transparency in Supply Chain Act of 2010 effective since January 1, 2012.


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