4. Taking Corrective Action & Developing Systems Improvement Plans

Forced labor and human trafficking are crimes under international human rights law and in most countries around the world. They are among the worst forms of abuse in the world of work.

A suspected case of forced labor in the supply chain must be dealt with immediately, firmly and comprehensively; and the response must consider the needs and well-being of the affected worker(s) first and foremost.

Many companies have the means and mechanisms to respond and react to non-conformance issues surfaced during social audits, but they may not be well-positioned to anticipate and avoid these problems in the first place, or to prevent them from happening again. Taking a reactive approach to problems can be more costly in the long run, and facility audits have shown that social responsibility problems tend to persist when remedial or corrective actions are either poorly maintained or are not implemented at all.

Developing a systems improvement plan that includes corrective and preventive measures helps brands and their suppliers to take both effective action against and proactively prevent practices that can lead to trafficking or forced labor for migrant workers.

Corrective action should provide for the full protection of the worker, and measures should be taken to support their rehabilitation (including physical and mental health), their repatriation (if desired by the worker), and/or their reintegration into the labor market and community. Wherever possible, cooperation should be forged with public or non-governmental victim service providers with expertise in supporting victims of human trafficking.

Taking action should be based on immediate corrective measures and longer-term systems improvement strategies. These should be formalized into a written plan that can include mechanisms and guidance to respond to immediate problems and proactive measures to anticipate and avoid them. It should also include guidance on preventing a recurrence of abuse. Developing a broad strategy of this kind can help brands to take effective action against forced labor and work with their suppliers to establish good practices to prevent the conditions that may enable or result in such forms of abuse.

In general, a systems improvement plan must:

  • Detail the company’s specific responses to the issues (ensuring at all times that vulnerable workers are protected, that contingencies are in place to respond to issues where they happen);
  • Address the root causes of the issues, including the policies and practices that contributed to the problem;
  • Map out the risks and their sources – the particular business processes, operational functions, or structural gaps from which the risks arise; and
  • Feed the results into a management systems improvement plan.

The tools to the right offer more guidance on corrective action and systems improvement planning, where the trafficking or forced labor of migrant workers is concerned.