Our forced labor compliance experience is deep, and applicable in a variety of contexts, spanning WRO modification requests, Uyghur Forced Labor Prevention Act (ULFPA) supply chain audits and tracing, internal forced labor investigations, responding to warning letters from non-governmental organizations, advising contracting parties to utility scale transactions on forced labor risk (and conducting related due diligence), and Risk and Analysis Survey Assessments (RASA) by US Customs. Clients in numerous industries and jurisdictions seek advice daily to mitigate risk under 19 USC 1307, the governing statute that bans the importation of goods produced in whole or in part with forced labor.
In the EU, we regularly advise clients on the ongoing negotiations relating to the adoption of legislation that seeks to ban goods made using forced labor (the EU's Forced Labour Regulation). We also provide monitoring services and policy-making guidance, and assist in anticipating future requirements.
Additionally, clients engage with our team on the development and implementation of human rights due diligence programs, as well as related reporting and disclosure requirements, including with regard to forced labor-related considerations. Our experience includes advising on the implementation of both soft-law best practices—such as those established in the UN Guiding Principles on Business and Human Rights, or the OECD Guidelines for multinational enterprises—and growing mandatory human rights and environmental due diligence legislation, such as the French Duty of Vigilance Law, the German Act on Corporate Due Diligence Obligations in Supply Chains, the UK Modern Slavery Act, and the upcoming EU Corporate Sustainability Due Diligence Directive (CS3D).
Clients trust us with the establishment of internal policies and procedures to address, in a globally coordinated and efficient manner, the existing and anticipated requirements arising from these voluntary and mandatory obligations, and to respond to related disclosure needs, such as those imposed under the EU Taxonomy Regulation and the EU Corporate Sustainability Reporting Directive (CSRD). Our experience spans the spectrum of stakeholders, including shareholders, investors, employees, communities, customers, and suppliers and other key members of the supply chain. We draw on the in-house experience of our team members to effectively manage human rights within supply chains across the globe, in line with the expectations of our clients, regulators, and other stakeholders.
