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Human Trafficking and Supply Chains: Q&A with Tim Nelson of the Slave-Free Alliance

The International Labour Organization estimates that 25 million people are subject to human trafficking around the world, with children comprising one of every four victims. In many cases, the victims are used and transported by their traffickers in supply chains. 

Tim Nelson is the international development director for Hope For Justice, an anti-trafficking organization that aims to end modern slavery. He also holds the same title at the Slave-Free Alliance, an affiliated group that collaborates with businesses to assess and prevent the risk of human trafficking in their supply chains. Nelson recently appeared on RIMScast to discuss the how human trafficking has evolved into a major supply chain risk and how employers and employees can identify signs of this abuse.

Check out some highlights below, and to take a free deep-dive with Nelson and learn how to take action to prevent human trafficking in your company and community, download RIMScast episode 120.

For more information on steps businesses should take to help identify and combat modern slavery on their premises, you can also check out the Risk Management feature article “Human Trafficking: How Businesses Can Combat the Modern Slavery Epidemic.”

What inspired the creation of the Slave-Free Alliance?

Tim Nelson: We primarily started in the U.K., and formed because of the Modern Slavery Act, which requires companies with £36 million (about $50 million) or more in their annual revenue to state their efforts to remove slavery from their supply chain. Consequently, we tend to work with businesses above that £36 million level and we try and effectively help them honor their commitment.

We also work alongside federal or local police and alongside other NGOs and effectively try and be a trusted friend. Many people, because of the countries that they come from or what they’ve been told, are suspicious of police or are worried about corruption. We can be there to build that bridge of trust.

How can someone identify trafficking and modern slavery?

TN: Traffickers are those individuals who would use other people to generate profit for themselves and are looking for every opportunity. Global estimates indicate that there’s $150 billion made from this illegal activity. And therefore, the traffickers have thought it through. 

One of the complexities in identifying it is that human trafficking is hidden in plain sight. The common form that most people are aware of is sexual exploitation. But ultimately, traffickers [also] realized that they could traffic individuals to work in the supply chains of businesses, making components, working in manufacturing, working in agriculture.

Could you provide an example of how traffickers permeate supply chains?

TN: Last year there was a case where 400 victims were identified as being slaves within the primary supply chain of some of the major supermarkets within the U.K. And, like we said earlier, it was in plain sight—no one could see how this was happening.

This particular occurrence happened because the traffickers had gotten control of a recruitment company and they were able to bring individuals from a non-English-speaking nation to the U.K. Those individuals were given jobs, but the traffickers had control of their bank accounts. They were forcing these 30-plus individuals to live in a three-bedroom property. Many of them were washing themselves in a local river—not having running water was a sign that this is not how people should be living in 2020. 

National Slavery & Human Trafficking Prevention Month is held annually in January to educate about the different forms of human trafficking. What can risk professionals do to ensure the awareness continues all year?

TN: I would encourage all businesses to realize that they’ve got the power to change this so easily if they start to engage and put in different processes and systems. And part of what we’re trying to do is not to just encourage individuals or companies to stop buying goods from a particular company. If you just stop dealing with a company because you suspect there’s modern day slavery or trafficking happening, that company will close and another one will open like a phoenix. Companies can also sometimes be complicit just by not even looking or allowing enough due diligence to show that they are slave-free within the supply chain.

Is there a bottom-line impact as well?

TN: What we are seeing now is, internationally, inaction can be a major risk to your business. I can think of companies where issues around slavery were brought to the fore and share prices dropped by half as institutional investors pulled out. This is a key ESG issue, which makes it a C-suite-level risk in many cases.

What should companies expect when they engage with the Slave-Free Alliance?

TN: The first thing that we would do is conduct a gap analysis. This is not just looking at where you’re getting supply from—it’s to try and identify the weaknesses that may be in your supply chain. And that gap analysis forms something almost like a risk register.

Every company is different. I spoke to a Fortune 100 company last month that didn’t even have a procurement division. And that’s what I would have assumed every major multinational had. But every company has a different approach to it.

Quite often, a lot of people find that the even the thought of how big their supply chain creates a massive complexity because there might be just three people running the procurement department.

When we see something that would sit within the risks that we identify, then we work with the companies to diminish that risk. It could be an [unannounced] site assessment or working with those people who are going in and auditing the factories themselves.

For more information about how your business can combat and identify modern slavery, visit the Slave-Free Alliance and Hope For Justice. You can report suspected activity in the U.S. to the National Human Trafficking Hotline and internationally to the International Labour Organization.

Strengthening Diversity, Equity and Inclusion Efforts

Improving diversity, equity and inclusion in the workplace seemingly remains an elusive goal for many companies. This persists even as many business leaders have stepped up to demonstrate that they value diversity and inclusion by making public commitments and dedicating time and money to training and development for their teams.

Society has a legal and moral obligation to extend equal opportunity to all people—regardless of gender, gender presentation, sexuality, sexual orientation, skin color, social class, religion and age, among other factors. But there is also a strict business dollars-and-cents reason for doing so: judging people on their talents and their potential, regardless of any of the factors above, means that you are getting the best people available. Discriminatory hiring practices simply dilute the talent pool.

A diverse workforce also brings a range of viewpoints and perspectives to a company. If employees feel safe to bring their authentic selves to work, they will feel empowered to help develop new ideas, products and missions to support the business and cater to its customers. Medium’s HR Blog and Resources published an article showing that diverse companies have increased revenue, more innovation, improved decision making, higher rates of job acceptance and better performance compared to competitors.  

Additionally, a 2018 analysis by McKinsey painted an even clearer picture:

  • Companies in the top 25th percentile for gender diversity on their executive teams were 21% more likely to experience above-average profits.
  • Companies with more culturally and ethnically diverse teams were 33% more likely to see better-than-average profits.

While most leadership teams believe that it is important to prioritize diversity and inclusion, they may also think it is something that will just fall into place. In reality, it will only succeed if it is deliberate—companies must plan for it, buy into it and incentivize it. It is also easy for businesses to believe they are doing a good job promoting inclusion and unwittingly stumble. Unconscious bias is real, and even people with the best of intentions can be guilty of microaggressions and other offenses against underrepresented groups.

Organizations seeking to embrace inclusion need to do so from the very top, and the practices, language, norms and processes that support these inclusionary goals need to move directly and effectively down the organizational chart. Something along the lines of superficial copy written in a policy memo will not do. Too often those kinds of actions are taken to “tick a box” without ever moving the needle. Company leadership needs to clearly set the tone and be certain managers and supervisors are not only onboard, but executing these missions on a regular basis. As with any for-profit project, achieving diversity is a goal that requires a comprehensive plan identifying the deficiencies and setting goals and a timeline to correct them.

Ensuring that promotions and new hires reflect diversity are obvious goals, but how does a company achieve them if it does not recognize that groups are still underrepresented in its workforce despite following what it believes are anti-discriminatory practices? A few years ago, a Silicon Valley startup called GapJumpers developed a platform to allow companies to hold blind auditions for openings in lieu of the traditional application and resume review process. They developed this process from an initiative that many of the world’s classical music orchestras undertook in the 1970s to try to diversify groups of predominantly white male musicians. The results were eye-opening: 60% of the applicants that made it through the selection process for interviews were from underrepresented groups. This approach may be out-of-the-box thinking for many organizations, but the fact that many companies are still struggling to achieve their diversity goals indicates that this is the time to throw out the old playbook.

Goals need to be set high enough so they are challenging while remaining realistic considering the company’s size and turnover rate. Achieving diversity is not a quick, one-size-fits-all fix and it is not going to happen overnight. However, as with many goals worth achieving, mindfulness, perseverance and commitment can prevail.

Responding to Litigation Hold Notices

The purpose of a litigation hold is to preserve relevant information when an organization reasonably believes this information can lead to an investigation or litigation. The information to be preserved can be documents, equipment and/or electronic information or materials that may be relevant to a lawsuit or an investigation, depending on your industry. If relevant documents or information are lost, altered or destroyed, the company could suffer serious legal consequences.

The spoliation of evidence is “the intentional, reckless, or negligent withholding, hiding, altering, fabricating, or destroying of evidence relevant to a legal proceeding.” The maximum penalty for destroying or concealing evidence is either six months in a county jail or a fine up to $1,000, or both. For example, spoliation can occur when documents are shredded, emails erased, physical evidence is sold, destroyed or hidden and otherwise rendered unavailable for trial. It is the company’s duty to take all reasonable steps to preserve potentially relevant information.

The risk professional’s role is vital—he or she may be aware of an incident that might give rise to a claim or suit, well before a suit is filed, sometimes even a year or more. For example, if you receive an incident report that a third-party vendor fell on your property, you would call security to see if there is video of the incident, and if so, secure a copy of that video. You would interview any witnesses, preferably on the day of the event while memories are fresh, and document the incident in their words. If the victim alleges that something caused the fall, then you should take photos of location and determine whether the pavement was wet or dry, there was debris in the aisle, what the weather conditions were, and other considerations. Once you complete the investigation, all documentation should be stored and secured.

If there is a claim that is either in a lawsuit or the company believes could later become a lawsuit, the clock starts ticking on litigation hold notices. In the United States, the law requires that companies comply with their duty to preserve evidence. Evidence is broad and can include an automobile involved in an accident; emails; a chair involved in a slip and fall; videos, voicemail, photographs or text messages; among others. The notice can involve official company files, personal files or non-official files. All information that may be relevant to the matter must be preserved.

Preserving potential evidence that the company believes may reasonably lead to a lawsuit or investigation takes a coordinated effort that can involve legal, risk management, IT, HR, compliance, engineering, security and any other department.

If you are an employee who may have information pertinent to investigation or lawsuit, you would be considered the custodian of this information and would have a legal obligation to preserve such evidence. As custodian, the legal department or possibly a third-party administrator would instruct you to preserve the evidence. The general procedure is that you would receive a notice on a matter that could be involved in an investigation or a lawsuit. You will be required to review, comply, sign and certify a document that states you agree to preserve information that would be related to the event. There may be a requirement to return signed document within a certain amount of time from receipt, and violation may result in disciplinary action that can include termination.

The evidence required may be very specific (such as video recorded on this date), or general (like all related emails), and may include a date range. Once identified, do not destroy, alter, modify or delete documents subject to the hold notice. When the lawsuit or investigation is completed you will receive a termination and release of this obligation. The evidence may be saved as part of the company record retention program.

Risk management can play an important role in this process by storing the hold notice in the claim file, periodically reminding custodians of their obligations, involving and sending new notices for new custodians that might have evidentiary material, and notifying custodians of termination of hold notices.

How to Make the Most Out of 2021’s Virtual Conferences for Rising Risk Professionals and Employers

Amid a second wave of the COVID-19 pandemic, people around the world are going back into lockdowns or rolling back phased reopenings, and it appears remote work arrangements and virtual events will continue to be the norm for many. Throughout the pandemic and now, moving into 2021, these shifts have prompted serious consideration about what it means to connect at work and how to build and maintain relationships in your professional network without seeing people in person.

As the job market remains in flux from the pandemic, this is a particularly pressing concern for students, early-career professionals, and others who are just establishing themselves in the risk profession. To that end, insurance and risk management student organization Gamma Iota Sigma has composed virtual conference guides for both students and employers to make the most out of the growing number of virtual recruitment and networking events.

According to Grace Grant, the organization’s executive director of chapter operations, Gamma Iota Sigma created the Virtual Conference Guide after roundtable discussions with a range of industry and professional association partners regarding student engagement, recruitment and collaboration amid the pandemic. “Throughout the course of the summer, nearly 30 different groups participated in these discussions where we discussed lessons learned and opportunities we were facing in light of the COVID-19 pandemic,” Grant said. “Because many of our partner organizations also host annual conferences, and everyone was pivoting to a virtual option, it became apparent that both students and employers would benefit from a best practices guide for virtual conference attendance.”

“For an industry that is largely centered around business relationships, the pivot to virtual a conference season presents a challenge, but also opportunities,” said Alyssa Bouchard, vice president of industry engagement at Gamma Iota Sigma. “While virtual engagement can’t always take the place of face-to-face engagement, it does allow for increased access. Virtual conferences have lower registration fees in many cases.


They have no associated travel costs or commitments. For some, the lack of business travel or daily commutes in our virtual environment means more time in the day. Collectively, this creates a big opportunity for rising risk professionals to pursue career development opportunities which might not have previously been an option but are now right in front of them—literally. It is a great time for rising risk professionals to participate in industry conferences and events to expand their industry knowledge and networks.”

For rising risk professionals looking to seize those expanded opportunities via virtual conferences and events, click here for the Virtual Conference Guide for Students.

On the day of the event, some of the key tips for students include:

  • Prepare your space. Find a quiet and comfortable space for attending the conference. Make sure you have all necessary technology and information within reach. Set up a neutral and professional background. Be aware of personal items that may show in your screen. Make sure your space is well-illuminated so conference attendees can clearly see your face during video interactions. Have water and a snack nearby so you can refuel when needed!
  • Check your Wi-Fi bandwidth. If possible, sit close to the router. Turn Wifi “off” on unused devices to free up bandwidth. If needed, ask your housemates to refrain from streaming during the event.
  • Dress to impress. Wear head-to-toe professional attire that is reflective of your professional brand and leaves conference attendees with a good impression. Some conference hosts will specify a recommended dress code for the event. If not, wear business professional attire.
  • Minimize distractions.
    • Close other tabs on your computer. Turn off notifications on your phone and other devices so you can focus on the conference.
    • Notify members of your household that you are participating in a virtual conference to better manage potential disruptions.
  • Build your network. Many virtual conferences will host virtual networking lounges, interest groups, chat rooms or other opportunities to meet attendees. Leverage these opportunities!
    • Virtual conferences offer a variety of communication methods to connect with other attendees. If you have meetings scheduled, confirm whether they are text, audio, or video meetings before joining the meeting.
    • Don’t be afraid to reach out and introduce yourself to other conference attendees. Share your elevator pitch when joining new conversations.
    • Be aware of your audience and know whether the chat is one-on-one or a group conversation.
    • If you plan to reconnect after the event, establish the best way to do so before signing off.
  • Keep a list of action items. How will you use the information you’ve acquired at the conference? Keep a list of to-do items for after the event. For example, 1) Submit online application for internship at ABC Insurance Company, 2) Follow up with Sheryl on offer to job shadow, 3) Review XYZ Brokerage’s career brochure, 4) Conduct additional research on product recall insurance.

For companies looking to recruit the next generation of risk professionals, click here for the Virtual Conference Guide for Employers.

For example, on the day of the event, GIS advised employers to:

  • Be proactive. Don’t wait for students and candidates to come to you! Find ways to actively engage conference attendee in the virtual lobby, lounges, and sessions. If a candidate visits your booth, give them a warm welcome.
  • Facilitate informal networking opportunities. Encourage attendees from your company to hang out in the virtual networking lounge, interest groups, or chat rooms when they’re not scheduled to be somewhere else. This will allow them to engage with students and/or potential candidates in a less formal setting.
  • Identify next steps. If speaking with a booth visitor or interviewee, clarify action items following the conference. Do they need to complete a job application? When will they hear back from you about a second-round interview?

    How can they find more information about your organization and/or opportunities?