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2016 Corporate Responsibility Summit: A Legal Perspective on Human Trafficking


Moving the needle from theory to practice was at the heart of AIAG’s 2016 Corporate Responsibility Summit, held April 27-28, 2016, at the Suburban Collection Showplace in Novi, Michigan. Speakers addressed a variety of CR topics, providing the latest information to help participants build a business case for sustainability.

In this fifth — and final — part of an article series recapping the 2016 Summit, here are some highlights from a breakout session on human trafficking.

The Next Frontier in Compliance

Human trafficking was the main topic of a breakout session where attorneys Michael Littenberg and Peter Nestor answered participants’ questions on a sensitive topic.

Littenberg began the discussion by telling attendees that the industry is just touching “the tip of the iceberg” when it comes to challenges in human trafficking, adding that local, state, and national regulations dealing with human trafficking will only increase. Nestor pointed out that recent cases and decisions passed down in the courts have held companies responsible for the actions suppliers took on their behalf.

“Even if your company is not conducting human trafficking, if there is some financial gain your company is experiencing from human trafficking, you will be held criminally liable,” said Nestor.

“There is an increasing amount of litigation around these issues,” Littenberg agreed. “Companies need to be on top of their supply chains. Regulations in human trafficking are going one direction. We’re going to see more of them — not less.”

Littenberg added that “no one will have this figured out right away,” stating that regulators and NGOs are looking for “reasonable good faith.” They want to see companies looking for human trafficking in their supply chains and trying to come up with solutions.

He also told suppliers in the room that OEMs are going to ask their supply chains for due diligence on human trafficking. “OEMs are working on how they want to collect the data and how they want to use it,” he said.

“You need to come up with a due diligence method that works for your company,” said Nestor. “Human trafficking is difficult to uncover, and it’s an incredibly complex problem. But it is modern slavery, and the entire purpose is to keep it secret. Sending an auditor to a company in your supply chain with a clipboard asking, ‘Do you have slaves working here?’ isn’t going to cut it.”

AIAG members can access all the presentations from this year’s Corporate Responsibility Summit online at www.aiag.org.

Carla Kalogeridis is AIAG’s e-news editor.