Compliance Week Quotes Michael Navarre on Human Trafficking Policies

June 19, 2014

Steptoe special counsel Michael Navarre was quoted in an article in Compliance Week titled “Human Trafficking Prevention Disclosures May Be in the Offing.”  The article, published June 17, discusses legislative and regulatory actions aimed at policing human trafficking and efforts by US companies to eliminate human trafficking in their supply chains.

In particular, the article points to growing pressure on global businesses to police human trafficking as an issue themselves, not unlike issues under the Foreign Corrupt Practices Act (FCPA).  “You have to institutionalize your program,” Mr. Navarre says.  “You have to have someone who is in charge of it, and you have to have some policies and procedures that govern how you do it.  You also want to incorporate it into your overall compliance and ethics program alongside the due diligence and risk assessment you do for FCPA issues.”

The full article can be read at Compliance Week (subscription required).