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U.S. law prohibits the importation of goods mined, produced, or manufactured, wholly or in part, in any foreign country by forced labor, including convict, indentured, and forced child labor. Enforcement of this prohibition is on the rise, including Withhold Release Orders (WRO) and shipment detentions.
It is therefore no longer enough for importers to know the conditions of manufacture only back to their tier one suppliers; instead, they need to have complete supply chain transparency all the way back to the point of extraction, growth, or original input creation. Importers should be taking affirmative steps to ensure compliance and manage risk.
ST&R Forced Labor Approach
Importers should be taking affirmative steps to ensure compliance and manage risk. Our firm has developed the ST&R approach to address the focus on forced labor:
- Stocktaking of your existing corporate social responsibility programs and augmenting them with forced labor specific updates;
- Testing and Tracing your company and suppliers’ ability to respond to documentation requests and ensure the measures put in place are sufficient; and
- Responding, if necessary, to any potential CBP detention that may be issued.
Click here for a pdf describing our three-pronged approach in more detail.
Why Use ST&R’s Forced Labor Services
Comprehensive guidance. ST&R can assess companies’ current compliance, test measures they have put in place, and help them develop remedial protocols. ST&R also assists in developing and implementing effective due diligence strategies, including updating or creating audit procedures and questions, corporate policy documents such as compliance manuals and vendor manuals, vendor agreements and related documents, and training materials. In addition, we work with corporate legal, procurement, and CSR departments to ensure all relevant personnel understand the ramifications of forced labor laws and regulations.
Representation. If your goods get caught in a WRO, ST&R examines your contracts, purchase orders, and other communications to minimize the impact and get your operations back on track. ST&R also advocates for company interests before agencies like U.S. Customs and Border Protection, the Office of Foreign Assets Control, and the Bureau of Industry and Security and monitors their related regulations and policies.
Cost effectiveness. ST&R utilizes companies’ existing corporate social responsibility and customs compliance resources, which ensures our approach is efficient, less costly, and rapidly implemented.