The U.S. Department of Labor’s (DOL) Bureau of International Labor Affairs has released “Reducing Child Labor and Forced Labor: A Toolkit for Responsible Businesses,” the first guide developed by the U.S. government to help businesses combat child labor and forced labor in their global supply chains. According to the International Labor Organization (ILO), worldwide there are 215 million children in child labor, with 115 million performing hazardous work. It also estimates that 21 million people are in forced labor, six million of them children. 
Using the DOL’s toolkit should help employers reduce “the chance that your products—and the raw materials they come from—are manufactured, mined or harvested by children who should be in school, or by workers locked in sweatshops or forced into work through false promises or threats.”
Social compliance programs
The kit highlights the need for a social compliance program that addresses how companies can prevent the use of child and forced labor throughout their supply chain. The toolkit defines a “social compliance program as “an integrated set of policies and practices through which a company seeks to ensure maximum adherence to its code of conduct.” The DOL said a social compliance system includes eight steps:
- Engage stakeholders and partners. This allows you to gather more ideas and perspectives, which can help you foresee consequences of certain decisions and actions, expectations, and key issues, while also giving you buy-in from the top levels.
- Assess risks and impacts. Identify both existing child labor and forced labor in your supply chains, or risks of where in the supply chain these abuses may occur.
- Develop a code of conduct. The DOL calls a code of conduct the “foundation of a social compliance program” that “sets out the social (and often, environmental) standards and policies with which a company and its suppliers are expected to comply. “
- Communicate and train across the supply chain. The DOL says, “Training, capacity building, and an emphasis on continuous improvement have been found to be the most effective way to make progress toward greater compliance with codes of conduct.”
- Monitor compliance. Watch for violations of your company’s code of conduct in your supply chain. The DOL warns that monitoring alone “uncovers problems; it does not solve problems.”
- Remediate violations. Once you’ve found violations, all affected parts of the supply chain should be involved in fixing the problem. According to the DOL, “Remediation actions should always be designed to both correct the problem found and prevent it from recurring.”
- Do independent review. The DOL says an independent review must have independent monitoring (auditing) and independent verification. In this context, the agency defines “independence” as “a lack of a direct financial transaction between the company and external entity.”
- Report performance. According to the United Nations Guiding Principles on Business and Human Rights(2011), self-reporting provides “a measure of transparency and accountability to individuals or groups who may be impacted and to other relevant stakeholders, including investors.”
You can find the toolkit on the DOL’s website at www.dol.gov/ilab/child-forced-labor