After the Super Bowl: Human Trafficking Occurs More Than Once a Year

stadium in lights and flashesOver the past week, significant attention has been paid to the risks of sex trafficking associated with the Super Bowl. Law enforcement resources were dedicated to identifying traffickers and ensuring that services are available for victims, and companies in both the airline and hotel industries took action to ensure that their facilities were not used to facilitate trafficking activities.

All of these actions are laudable, but it is important to ask: what happens after the Super Bowl?

Several commentators have noted the risks of focusing too much attention on the trafficking risks associated with a single event when, in reality, trafficking occurs every day throughout the United States and abroad. To address the problem in a meaningful way, it is important to focus both public and private attention on the larger systemic issues at hand.

To be sure, large sporting events like the Super Bowl have been shown to foster criminal activity including sex trafficking. At a Congressional hearing on January 27, Rep. Chris Smith (R-N.J.) noted specific efforts that are being taken to address trafficking in connection with the 2014 World Cup and the 2016 Summer Olympics. Notably, the trafficking risks associated with such events include both sex trafficking and labor trafficking. Corporations linked to such events, including sponsors, hospitality industry companies, and construction firms should take action to mitigate the risk that human trafficking will occur in connection with their activities.

Beyond large-scale events, trafficking exists on the margins of many other business activities. A recent NPR piece noted that sex trafficking has increased in North Dakota, alongside the growth of the state’s oil fields and population. Another recent article, in the Wall Street Journal, highlighted the risks of labor trafficking in industries ranging from electronics to agriculture.

Companies are increasingly being asked to report on their efforts to address the risks of trafficking in connection with their corporate supply chains. The Wall Street Journal article cited above noted that the reporting requirements of the California Transparency in Supply Chains Act have pushed companies to conduct more thorough due diligence regarding the trafficking risks in their supply chains. The Executive Order Strengthening Protections Against Trafficking in Persons in Federal Contracts has been another driver for corporate efforts to address the risks of both sex and labor trafficking.

In this context, what actions can companies taken to address the potential that their operations may be linked to human trafficking? Companies should consider:

  1. Conducting due diligence to evaluate the risks of human trafficking associated with the company’s operations, including its supply chain. This due diligence could include an evaluation of the relative risk level of the countries in which the company has direct operations or suppliers. This due diligence could be integrated with other due diligence efforts, including due diligence with regard to corruption-related risks.
  2. 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.
  3. Ensuring that prohibitions on human trafficking and forced labor are included in contractual requirements for contractors and suppliers.
  4. Providing training to managers and employees on how to identify and report indicators of human trafficking and forced labor.
  5. Identifying and engaging with relevant industry initiatives and other potential partners that can provide critical support for company training and risk assessment efforts.

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