Teaching Innovation

Luz Nagle, Developed a final project in which the students write a Human Trafficking Compliance Manual for a private company. Private sector companies are at risk of inadvertently supporting human trafficking. There are increasing allegations that companies use forced labor to build components, extract raw materials, and assemble products. We also read reports of abuse of workers by construction companies and the fishing industry. The growing complexity of supply chains and a greater focus on the issue by regulators, human rights organizations, and some federal and state governments have made this a heightened risk for companies. To address it, some have turned to drafting supplier codes of conduct. In the United States, the Trafficking Victims Protection Act “provides ways to prosecute entities and individuals who indirectly support the actions of traffickers. Additionally, several federal regulations have created mandates for certain companies to have corporate human trafficking compliance programs. Failure to comply with such mandates results in fines, and additional criminal and civil liability exposure.” Worldwide, many countries have implemented a variety of legislation affecting corporations. Companies must answer several questions, such as what should do to ensure that they see the red flags to avoid risks? What rules and regulations do they need to be mindful of in the countries they operate, including in the United States? Each student assume the role of in-house counsel for a multinational company/industry of his/her choice. Through a process of drafting and professor feedback using Teams,the final submission of a compliance manual includes presenting the manual to the class and taking questions (which this semester was done online using Zoom). For the Manual, each student must: Draft policies and procedures to meet the regulatory, legal, and fiduciary obligations of the company or industry you represent; Provide advice on how to conduct business per regulations and any applicable laws; and; Give instruction on how to monitor and verify that the company-industry follows the policies and procedures and that they are effective.Among the issues to addres:Human trafficking risks that the industry/company has in the particular country of operation (corruption related to human trafficking, labor/sex trafficking, any other related risk).The specific risk(s) factor(s) they will have in the countries where they have operations (with suppliers, subcontractors, international and domestic laws/regulations), Human Trafficking, January 2020