Header Photo Credit: Santiago Arcos/UNICEF/UN0310005
About Comply Chain
Comply Chain is a series of documents intended to help companies build or improve a social compliance system to avoid violation of U.S. trade law prohibiting importation of goods made in whole or in part with forced labor. In this era of globalization, the production of goods in foreign countries has increased at a rapid pace and global government oversight of labor rights has not always kept up. Adherence to the guidance provided by Comply Chain helps responsible businesses navigate the legal, moral, and public relations risks of labor exploitation in global supply chains.
This tool was created by the U.S. Department of Labor’s (USDOL) Bureau of International Labor Affairs (ILAB)’s Office of Child Labor, Forced Labor, and Human Trafficking (OCFT). ILAB's mission is to strengthen global labor standards, enforce labor commitments among trading partners, promote racial and gender equity, and combat international child labor, forced labor, and human trafficking.
As mandated by the Trafficking Victims Protection Reauthorization Act of 2005 (TVPRA), ILAB also publishes a List of Goods Produced by Child Labor or Forced Labor, including goods that are produced with inputs that are made with forced labor and child labor. Read more about OCFT’s mission here.
Comply Chain is the result of ILAB's work with stakeholders involved in the production of goods appearing on the aforementioned TVPRA List of Goods.
In addition to offering standard practices for companies to follow, Comply Chain serves as an organizing framework for multiple U.S. Government agencies' work on child labor and forced labor, supply chain-focused research, and technical assistance projects related to responsible business conduct. The tool has been incorporated into the U.S. National Action Plan on Responsible Business Conduct (NAP-RBC). The NAP-RBC encompasses the U.S. government's efforts and commitments to protect human rights in the overseas operations of U.S. businesses through research, technical cooperation, federal procurement practices, labor diplomacy, and public-private dialogue. The NAP-RBC also emphasizes the positive contributions that businesses can make to respect human rights.
Comply Chain's eight-step framework is referenced in the Forced Labor Enforcement Task Force's Importer Guidance and the Commerce/International Trade Administration's training on forced labor in global supply chains. Comply Chain's eight steps provide guidance on critical elements of social compliance and act as a primer to identify and assess risk, prevent and remedy violations, and support workers' access to grievance mechanisms and remediation.
Toward Worker-Driven Social Compliance Systems
This tool supports the efforts of companies and other stakeholders seeking to address labor exploitation in supply chains and responds to the evolution of responsible business practices globally by helping companies build worker-driven social compliance systems. A worker-driven social compliance system is an approach to ensuring fair and ethical labor practices within supply chains and workplaces. Worker-driven social compliance systems prioritize the active involvement and empowerment of workers themselves. In a worker-driven social compliance system, the workers play a central role in identifying and addressing labor rights violations and other concerns within their workplaces. They are organized into independent, democratic organizations or worker-led committees representing their collective interests and advocate for their rights.
Comply Chain helps companies build worker-driven social compliance systems that put workers and their organizations at the center of effective solutions to ensure real, independently verifiable protection of human rights in global supply chains.
Private-sector companies need to take steps to ensure fair labor standards and worker-centered policies in their supply chains. While strong government regulations are critical, it is imperative that the private sector ensure a rapid and appropriate response to labor violations in countries where governments lack strong monitoring and enforcement mechanisms. For this reason, companies need to independently exercise rigorous due diligence practices that promote transparency and accountability within their supply chains. There is also a need for effective remediation and grievance pathways for workers.
Comply Chain builds on traditional compliance systems that rely on audits and inspections conducted by third-party organizations or brands. The tool assists companies in building social compliance systems that prioritize the active involvement and empowerment of their workers. The continued development and further updating of this tool is an effort to ensure that worker feedback and empowerment are at the center of a company’s due diligence efforts.
How Do I Use Comply Chain?
Comply Chain provides steps to build or improve a social compliance system. It is intended for use by multinational corporations, small- and medium-sized enterprises, workers and civil society organizations, and academia to understand the role each can play in building a more just and ethical social compliance system.
If you see a good practice that is missing, share it with us by e-mailing ILAB at GlobalKids@dol.gov.
Disclaimers
The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.
Important Notice
All references to specific companies and non-governmental entities within this guide are for informational purposes only to demonstrate good practices. References to these entities should not be interpreted as an official endorsement by the U.S. Department of Labor of those entities, their products, or services, and their inclusion should not be interpreted as a comprehensive review of these entities’ practices in all areas.
ILAB chose to highlight certain companies’ practices in Comply Chain based on an extensive literature review and engagement in worker-driven social compliance-focused fora. These companies have shown good practice in one or more areas of the tool’s “Steps.” These examples are illustrative and not exhaustive. Many other companies have also developed, or are developing, good practices in these areas that could also be shared. These examples are also snapshots in time, and ILAB recognizes that companies’ practices may change. ILAB welcomes input from the public on additional company strategies and practices that could be highlighted in Comply Chain.
This tool was developed for USDOL/ILAB.
You may incorporate content from this tool into your own materials with attribution to the Department of Labor’s Comply Chain tool.
