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Hidden Traffic Podcast

More About the Uyghur Forced Labor Prevention Act with Virginia Newman

 

Virginia Newman is a trade and white-collar compliance attorney, and counsel in the international department at Miller & Chevalier. She advises on Foreign Corrupt Practices Act (FCPA), anti-money laundering (AML), securities laws, anti-forced labor laws, and other human rights-related issues. Virginia also specializes in investigations and litigation. She joins host Gwen Hassan to explore key points in the Uyghur Forced Labor Prevention Act.

 

 

There has been a debate around which comes first: mapping your supply chain or doing a risk assessment. Rather than making it a chicken or the egg scenario, Virginia believes mapping your supply chain is a part of a risk assessment and due diligence. The first step in performing a risk assessment is discussing your products with your product team, she shares: figuring out which products have high-risk inputs, and which ones you should focus on mapping first.

 

This is especially important for large companies that import and distribute countless products. There may be too many products to have a fully mapped and detailed supply chain for every one of them. Taking it one input at a time breaks down the line item list to a more manageable level.

 

Resources

Virginia Newman on LinkedIn

 

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Hidden Traffic Podcast

Closing the Accountability Gaps with Duncan Jepson


 
Duncan Jepson is Managing Director of Liberty Shared. Starting as a documentary filmmaker, he saw the stark contrast between the ones being filmed and the excited executives. He joins host Gwen Hassan to discuss how Liberty Shared is helping organizations take action against human rights violations. 
 

 
Liberty Shared’s main focus is data gathering and research and intelligence sharing –  gathering information about what happens on the ground then communicating that to individuals, groups, and organizations that can do something in response. “We’re not interested in statistics [or] estimations,” Duncan shares, “we’re interested in data as it is accurate and can produce actionable information and evidence.”
 
The system is flawed and incomplete, he adds. The global economy is profit-oriented, so much so that it operates at the expense of other people, and the chance of anyone being held accountable for their part in it is very limited. Liberty Shared is working to identify those gaps of accountability and close them as much as possible. 
 
Resources
Duncan Jepson on LinkedIn
 

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Hidden Traffic Podcast

Forced Labor and Fast Fashion with Mike McDonnell


 
Mike McDonnell, a CSR/ESG Consultant to the RBA/RLI and a founding member of the Responsible Business Alliance’s Responsible Labor Initiative, joins host Gwen Hassan to discuss the impact of fast fashion on workers, forced labor, and the responsibility of companies to ensure that they don’t use vendors and suppliers who engage in unethical and harmful practices.  
 

 
Many workers who end up in the grips of human trafficking often flee hardship and poverty. This makes them targets for exploitation by agencies and facilities. Mike explains that some workers have to pay fees to be hired, and because of these fees, they are put under tremendous pressure by the employers. The workers feel indebted to the ones exploiting them, allowing their superiors to maintain a sense of control over them. Companies may also be receiving free hiring services and benefits through human trafficking, sometimes without their knowledge.
The workers pay fees in two ways: above board by charging limits or extracting cash in rougher aspects. These fees are ongoing so that workers can keep their heads down and out of the line of fire. There are digital programs put in place to audit this. Surveys are given to workers with questions on whether anyone has asked them for money. One of the positives about this type of technology is that companies can monitor real-time when these situations arise.
It’s not enough to not harm a company. It’s not enough to say that you’re following your code of ethics. You have to show it in your actions and break it down to its elements. Rethink your tools, assess your suppliers and their business practices, and these can become your rail factors on whether or not to engage in business with them. If they present too much risk, or you cannot prove that they aren’t engaging in unethical behavior, you will have to rethink your outsourcing.
 
Resources
Mike McDonnell on LinkedIn 
Responsible Labor Initiative
 

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Hidden Traffic Podcast

The Role of Digital Platforms in Human Trafficking with Lisa Thee


 
Lisa Thee is the Data for Good Practice Lead at Launch Consulting Group. She is CEO at AMP Solutions, where she provides advising, consulting, and strategy services for businesses. She also serves on the board of directors and as an advisory board member for several organizations, and is a TEDx Speaker. Lisa joins host Gwen Hassan to discuss the evolution of digital safety, and the role of digital platforms in both the persistence and end of human trafficking.
 

 
Digital platforms have been used as a vehicle for recruiting victims of human trafficking and/or child sexual exploitation, in part due to the absence of standards and regulations for digital safety. There isn’t a strong business incentive to do the right thing in terms of trust and safety, Lisa claims, because it opposes shareholder value and growing your audience. “I think we’re finally at a place as a society where we’re ready to [abandon leveraging] our next generation’s mental and physical health to maintain the status quo,” she says.
 
However, a delicate balance must be struck; making adjustments to trust and safety will directly impact privacy, and vice versa. There is no one-and-done method to solving this problem, as it has never been about technology, but instead, ethics. On a related note, advocating for compliance and ethics from a financial standpoint promotes a win-win scenario for business and for the greater good.
 
Resources
Lisa Thee on LinkedIn | Twitter
LisaThee.com
 

Categories
The ESG Report

The Fight Against Human Trafficking and the ‘S’ in ESG with Gwen Hassan


Gwen Hassan has been championing the fight against human trafficking for quite some time. The heartwrenching story of a young girl in SouthEast Asia brought the issue to her attention, but realizing that human trafficking is also a local issue spurred her to take action. “And since that time,” Tom Fox commends her, “you have been one of the leaders to talk about this issue in the context of either supply chain and overall corporate approach or compliance programs.” In this week’s show, Tom and Gwen discuss why fighting human trafficking is a compliance issue, and where it fits in ESG.
Part of Compliance
Human trafficking takes place everywhere, including in the US. Gwen tells Tom that there’s already an existing infrastructure with regard to third-party diligence, which could be used to fight human trafficking as well. She remarks, “…Why not start using that same set of controls and processes and power to make sure they’re doing their part to root out trafficking from their supply chain as well?” Her belief is that stamping out human trafficking should be part of every corporate compliance program. “The synergy with corporate compliance really came to the forefront with the UK Modern Slavery Act,” she points out. 
Why US Companies Should Care
Why should fighting human trafficking be an issue for companies who don’t trade internationally, Tom asks Gwen. “One of the biggest, kind of, eye-openers for me was learning about the extent of trafficking that’s right here in the US,” she responds. Even if your company does not do business overseas, you could still be contracting with businesses that engage in or support human trafficking. It’s imperative that you do your due diligence about third parties and even their subcontractors.
S or G?
Tom sees fighting human trafficking falling under the S in ESG. Gwen agrees that it does relate to social justice issues in a broad sense. In her opinion, it also is a G: companies should practice good governance, which includes robust third-party diligence. “The process side and the diligence aspects of a sustainable ethics and compliance program, fit very nicely with human trafficking… [and] the reasoning behind why you want to have a good program for human trafficking prevention relates back to social justice and the fair treatment of everyone who’s in your organization,” she remarks. Most business leaders immediately understand the reputational risk human trafficking poses to their companies. “Once you educate people as to the extent of the problem – the fact that it impacts everyone – it really makes a difference in their openness and their willingness to then invest,” she tells Tom. Government actions are helping the fight: once leaders know that there could be enforcement actions against them, they’re more willing to listen.
Resources
Gwen Hassan on LinkedIn | Email
 
 

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The Ethics Experts

Open To Work Bonus Episode 006: Gwen Hassan

In this episode of The Ethics Experts, Nick welcomes Gwen Lee Hassan, managing counsel (director) – global compliance and ethics, to the show.

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The Compliance Life

Gwen Hassan on Balancing Legal and Compliance Roles


The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Gwen Hassan, Managing Counsel and Director of Compliance at CNH Industrial.
In this second episode, we take up the tricky issue of balancing a role as a legal eagle for the company as well as her role in compliance. We explore the different skill set needed for each of these careers and how it is possible to have both in one person. Gwen tells us her favorite part about being a compliance professional and then give us her “elevator speech” about the compliance profession she used at pre-pandemic cocktail parties.

Categories
The Compliance Life

Gwen Hassan on the Twisting Road to Compliance


The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Gwen Hassan, Managing Counsel and Director of Compliance at CNH Industrial.
In this first episode, we consider Gwen’s journey to her role, She discusses her educational background, a family tragedy which led to her legal education and her initial exposure to the field of compliance. As with all the guests on The Compliance Life, there were many twists and turn which led to her current position.