Following the 2011 endorsement of the UN Guiding Principles on Business and Human Rights (UNGPs), states have begun to implement National Action Plans (NAPs) to operationalize the UNGPs. Using a case study approach and applying a conceptual framework for polycentric governance, this article aims to provide an early assessment of the effectiveness of NAPs adopted by the United Kingdom and the United States to combat one of the worst human rights abuses in global supply chains: modern slavery. This study demonstrates that both NAPs contain elements addressing the governance gaps surrounding modern slavery, such as enacting new laws, adapting existing regulations, strengthening multi-stakeholder mechanisms for business accountability, and promoting innovation. However, it is argued that the NAPs themselves were not the catalysts for the majority of these measures. This article concludes that states should optimize the five characteristics of polycentric governance outlined in this study to improve the relevance and effectiveness of NAPs as drivers of change.
1 ILO and Walk Free Foundation, Global Estimates of Modern Slavery: Forced Labour and Forced Marriage (Geneva, Switzerland: ILO, 2017), 9.
2 Ruggie, John, Just Business: Multinational Corporations and Human Rights (New York, USA and London, UK: WW Norton & Co., 2013).
3 Trinna Leong, ‘“Forced labor” rife in Malaysian electronics factories: report’, Reuters (17 September 2014), https://www.reuters.com/article/us-malaysia-labour-report-idUSKBN0HC08E20140917 (accessed 12 July 2019).
4 Margie Mason et al, ‘Global supermarkets selling shrimp peeled by slaves’, Associated Press (14 December 2015), https://www.ap.org/explore/seafood-from-slaves/global-supermarkets-selling-shrimp-peeled-by-slaves.html (accessed 12 July 2019).
5 In management literature, the occurrence of modern slavery in the ‘supply chain’ refers to ‘anywhere along the supply chain from raw material extraction to the final customer for service provision or production’; see Stevenson, Mark and Cole, Rosanna, ‘Modern Slavery in Supply Chains: A Secondary Data Analysis of Detection, Remediation and Disclosure’ (2018) 12:3 Supply Chain Management: An International Journal 81.
6 UN Human Rights Council, ‘Business and human rights: mapping international standards of responsibility and accountability for corporate acts’, A/HRC/4/35 (19 February 2007).
7 UN Economic and Social Council, ‘Interim report of the Special Representative of the Secretary-General on the issue of human rights and transnational corporations and other business enterprises’, E/CN.4/2006/97 (22 February 2006), 6.
8 Human Rights Council, note 6, 3.
9 Barnett, Michael and Sikkink, Kathryn, ‘From International Relations to Global Society’, in Goodin, RE (ed.), The Oxford Handbook of Political Science (Oxford, UK: Oxford University Press, 2013), http://www.oxfordhandbooks.com/view/10.1093/oxfordhb/9780199604456.001.0001/oxfordhb-9780199604456-e-035 (accessed 19 April 2018).
10 Augenstein, Daniel and Lindahl, Hans, ‘Introduction: Global Human Rights Law and the Boundaries of Statehood’ (2016) 23:1 Indiana Journal of Global Legal Studies 3.
11 Nolan, Justine, ‘From Principles to Practice’, in Martin, Jena and Bravo, Karen E (eds.), The Business and Human Rights Landscape: Moving Forward, Looking Back (Cambridge, UK: Cambridge University Press, 2015), 388 (noting that ‘private compliance programs’ were ‘sometimes complementary to existing national laws and, at other times, superseded state efforts to protect workplace rights’).
12 Burca, Grainne De, Keohane, Robert and Sabel, Charles, ‘New Modes of Pluralist Global Governance’ (2013) 45 Journal of International Law & Politics 726.
13 UN Human Rights Council, ‘Promotion and protection of all human rights, civil, political, economic, social and cultural rights, including the right to development’, A/HRC/RES/17/4 (6 July 2011).
14 UN Human Rights Council, ‘Mandate of the Special Representative of the Secretary General on the issue of human rights and transnational corporations and other business enterprises’, A/HRC/8/7 (18 June 2008).
15 The 21 countries that have produced NAPs are the United Kingdom, Netherlands, Denmark, Finland, Lithuania, Sweden, Norway, Colombia, Switzerland, Italy, USA, Germany, France, Poland, Spain, Belgium, Chile, Czech Republic, Ireland, Luxembourg and Slovenia; see https://www.ohchr.org/en/issues/business/pages/nationalactionplans.aspx (accessed 14 May 2019). Additional countries have produced chapters on business and human rights within broader human rights national action plans; see https://globalnaps.org/ (accessed 14 May 2019).
16 Ruggie, John, ‘Global Governance and “New Governance Theory”: Lessons from Business and Human Rights’ (2014) 20 Global Governance 9.
17 The term ‘modern slavery’ does not have a legal definition, but ‘slavery’, ‘forced labour’, and ‘human trafficking’ are each defined in international legal instruments such as the ILO Convention on Forced Labour (1930), the UN Slavery Convention (1926), and the UN Protocol to Prevent, Suppress and Punish Trafficking in Persons, especially Women and Children. For the purposes of the ILO’s data initiative, ‘modern slavery’ is used to describe all three practices; see ILO, ILO Data Initiative on Modern Slavery, (Geneva: ILO, 2015).
18 OHCHR, Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework (New York and Geneva: 2011).
19 Ruggie, note 16, 9.
20 Davitti, Daria, ‘Refining the Protect, Respect and Remedy Framework for Business and Human Rights and its Guiding Principles’ (2016)16:1 Human Rights Law Review 55–75 (describing the failure of the UN Draft Norms on the Responsibilities of Transnational Corporations and Other Business Enterprises with Regard to Human Rights).
21 UN Economic and Social Council, ‘Human rights and transnational corporations and other business enterprises’, E/CN.4/2005/L.87 (15 April 2005).
22 John Ruggie, ‘The Social Construction of the UN Guiding Principles on Business and Human Rights’, Corporate Responsibility Initiative Working Paper No. 67 (Cambridge, MA, USA: John F Kennedy School of Government, Harvard University, 2017), 12.
23 UN Human Rights Council, ‘Business and human rights: mapping international standards of responsibility and accountability for corporate acts’, A/HRC/4/35 (19 February 2007), para 52.
24 UN Human Rights Council, ‘Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework’, A/HRC/17/31 (21 March 2011), para 5.
25 Ruggie, note 16, 9.
26 John Ruggie, ‘Presentation of Report to United Nations Human Rights Council, Professor John G Ruggie, Special Representative of the Secretary-General for Business and Human Rights,’ Geneva (30 May 2011), http://www.ohchr.org/Documents/Issues/TransCorporations/HRC%202011_Remarks_Final_JR.pdf (accessed 15 April 2018).
27 Human Rights Council (21 March 2011), note 24, para 5.
28 Vargas, Claret, ‘A Treaty on Business and Human Rights? A Recurring Debate in a New Governance Landscape,’ in Rodriguez-Garavito, Cesar (ed.), Business and Human Rights: Beyond the End of the Beginning (Cambridge, UK: Cambridge University Press, 2017), 113.
29 There is extensive discussion of the treaty option and debate in the business and human rights literature. See, e.g., Bilchitz, David, ‘The Necessity for a Business and Human Rights Treaty’ (2016) 1:2 Business and Human Rights Journal 203–227 . See also Blackwell, Sara and Meulen, Nicole Vander, ‘Two Roads Converged: The Mutual Complementarity of a Binding Business and Human Rights Treaty and National Action Plans on Business and Human Rights’ (2016) 6:1 Notre Dame Journal of International & Comparative Law 51–76 . See also chapters 3, 4 and 6 of Rodriguez-Garavito, Cesar (ed.), Business and Human Rights: Beyond the End of the Beginning (Cambridge, UK: Cambridge University Press, 2017 ): chapter 3, Surya Deva, ‘Business and Human Rights: Time to Move Beyond the “Present”?,’ 62–75; chapter 4, Tara Melish, ‘Putting “Human Rights” Back into the UN Guiding Principles on Business and Human Rights: Shifting Frames and Embedding Participation Rights,’ 77–96; and chapter 6, Vargas, note 28, 111–126.
30 See Vargas, note 28, 113–114 (describing the key concerns and goals of treaty proponents).
31 Deva, note 29, 62.
32 Blackwell and Meulen, note 29, 52–53.
33 Ramasastry, Anita, ‘Closing the governance gap in the business and human rights arena: lessons from the anti-corruption movement’ in Deva, Surya and Bilchitz, David (eds.), Human Rights Obligations of Business: Beyond the Corporate Responsibility to Respect? (Cambridge, UK: Cambridge University Press, 2013), 164.
34 Nye, Joseph S and Donahue, John D, Governance in a Globalizing World, (Washington, DC, USA: Brookings Institute Press, 2000), 14.
35 Nye and Donahue, note 34, 19.
36 Barnett and Sikkink, note 9, 3.
37 Ruggie, note 16, 8.
38 Backer, Larry, ‘Fractured Territories and Abstracted Terrains: Human Rights Governance Regimes Within and Beyond the State’ (2016) 23:1 Indiana Journal of Global Legal Studies 69.
39 Nye and Donahue, note 34, 25.
40 Finnemore, Martha and Sikkink, Kathryn, ‘International Norm Dynamics and Political Change’ (1998) 52:4 International Organization 887–917.
41 Nolan, note 11, 397.
42 In the business and human rights arena, the conflict minerals regulatory regime is a relevant case study for the application of polycentric governance theory. See Darin Prenkert, Jamie and Shackelford, Scott J, ‘Business, Human Rights, and the Promise of Polycentricity’ (2014) 47 Vanderbilt Journal of Transnational Law 451–500.
43 See, e.g., Robert O Keohane and David G Victor, ‘The Regime Complex for Climate Change’, Discussion Paper 2010-33 (Cambridge, MA, USA: Harvard Project on International Climate, January 2010), 2. See also Ostrom, Elinor, ‘Polycentric Systems for Coping with Collective Action and Global Environmental Change’ (2010) 20 Global Environmental Change 550–557.
44 Ostrom, Elinor, ‘Beyond Markets and States: Polycentric Governance of Complex Economic Systems’ (2010) 100 American Economic Review 643.
45 Prenkert and Shackelford, note 42, 473.
46 Ostrom, note 43, 552.
47 Prenkert and Shackelford, note 42, 491.
48 Ostrom, note 43, 550.
50 Ruggie, John, ‘Hierarchy or Ecosystem? Regulating Human Rights Risks of Multinational Enterprises’, in Rodriguez-Garavito, C (ed.), Business and Human Rights: Beyond the End of the Beginning (Cambridge, UK: Cambridge University Press, 2017), 47.
51 Prenkert and Shackelford, note 42, 474 and 492 (describing the pivotal role of civil society in gathering evidence of human rights abuses in the conflict minerals trade, which in turn influenced national and local state actors to enact legislation requiring corporate human rights due diligence reporting).
52 Ostrom, note 43, 552.
53 De Burca, Keohane and Sabel, note 12, 726–727.
54 One example of an adaptive, polycentric approach is the C40 Cities Climate Leadership Group, which provides cities with resources to exchange information, and influence national and international policy on climate change. See Ostrom, note 43, 553.
55 Prenkert and Shackelford, note 42, 460.
56 See Ostrom, note 43, 555 and 554–556 (describing the five common criticisms of leakage, inconsistent policies, inadequate certification, gaming the system, and free riding). Other scholars have also pointed out limitations to polycentric governance. See, e.g., Keohane and Victor, note 43, 17 (noting that the multi-stakeholder variation in interests in a polycentric system may provoke conflict that leads to gridlock instead of innovative solutions). See also Black, Julia, ‘Constructing and Contesting Legitimacy and Accountability in Polycentric Regulatory Regimes’ (2008) 2 Regulation & Governance 138–139.
57 Beckert, Sven, Empire of Cotton: A Global History (New York, USA: Vintage Books, 2014), 85.
58 Ibid, 121.
59 Bales, Kevin, ‘Slavery and the Human Right to Evil’ (2004) 3:1 Journal of Human Rights 55–65.
60 Only nine countries have not ratified the Convention: Afghanistan, Brunei Darussalam, China, Republic of Korea, Marshall Islands, Palau, Tonga, Tuvalu and the United States. See https://www.ilo.org/dyn/normlex/en/f?p=1000:11001 (accessed 25 August 2018).
61 Walk Free Foundation, The Global Slavery Index 2018 (Minderoo Foundation Pty Ltd, 2018), https://www.globalslaveryindex.org/resources/downloads/ (accessed 25 August 2018), vii, 30.
62 ILO, Profits and Poverty: The Economics of Forced Labor (Geneva, Switzerland: ILO, 2014), 13.
63 ILO, Combatting Forced Labour: A Handbook for Employers and Business, (Geneva, Switzerland: ILO, 2015), 9.
64 Ibid, 9–11.
65 Verité, Forced Labor in the Production of Electronic Goods in Malaysia: A Comprehensive Study of Scope and Characteristics (Verite, 2014) https://verite.org/wp-content/uploads/2016/11/VeriteForcedLaborMalaysianElectronics2014.pdf (accessed 12 July 2019).
66 Ibid, 179.
67 See, e.g., Bales, Kevin, ‘Winning the Fight: Eradicating Slavery in the Modern Age’ (2009) 31:1 Harvard International Review 14 ; see also Andrew Crane et al, ‘Governance Gaps in Eradicating Forced Labor: From Global to Domestic Supply Chains’(6 September 2017) Regulation & Governance 2, https://onlinelibrary.wiley.com/doi/full/10.1111/rego.12162 (accessed 12 July 2019).
68 See, e.g., Crane, Andrew, ‘Modern Slavery as a Management Practice: Exploring the Conditions and Capabilities for Human Exploitation’ (2013) 38 Academy of Management Review 49–69 . See also Craig, Gary, ‘The UK’s Modern Slavery Legislation: An Early Assessment of Progress’ (2017) 5:2 Social Inclusion 16–27 ; see also Mehra, Amol and Shay, Katie, ‘Corporate Responsibility and Accountability for Modern Forms of Slavery’ (2016) 14:2 Journal of International Criminal Justice 453–468.
69 Crane et al, note 67, 21.
70 Walk Free Foundation, note 61, 30. See also US Department of State, Democratic People’s Republic of Korea: 2017 Human Rights Report, https://www.state.gov/documents/organization/277333.pdf (accessed 12 July 2019).
71 US Department of State, Uzbekistan 2017 Human Rights Report, https://www.state.gov/documents/organization/277543.pdf (accessed 10 August 2018). See also Amelia Neumayer, ‘New Research Shows Forced Labor Still Rampant in Uzbekistan’, Human Rights Watch (25 May 2018), https://www.hrw.org/news/2018/05/25/new-research-shows-forced-labor-still-rampant-uzbekistan (accessed 2 September 2018).
72 UN, ‘Issue Brief #5: Smuggling of migrants, trafficking in persons and contemporary forms of slavery, including appropriate identification, protection and assistance to migrants and trafficking victims’ (September 2017), https://refugeesmigrants.un.org/sites/default/files/ts5_issue_brief.pdf (accessed 10 July 2018). Verité identified this practice in its report on forced labour in Malaysia; see Verité, note 65.
73 Mehra and Shay, note 68, 455, 468.
75 Crane et al, note 67, 12.
76 OHCHR, note 18, 3.
78 In 2011, the UN Human Rights Council appointed the UN Working Group on Business and Human Rights (UNWG) to promote implementation of the UNGPs; see Human Rights Council, ‘Human Rights and Transnational Corporations and Other Business Entities’, A/HRC/RES/17/4 (6 July 2011).
79 UNWG, Guidance on National Action Plans on Business and Human Rights (Geneva, Switzerland: November 2016), 1.
82 Ibid, 6–8.
83 ICAR and DIHR, National Action Plans on Business and Human Rights: A Toolkit for the Development, Implementation, and Review of State Commitments to Business and Human Rights Frameworks, (Washington, DC, USA: International Corporate Accountability Roundtable, 2014).
84 For an analysis of 12 NAPs, see ICAR, the European Coalition for Corporate Justice (ECCJ), and the Center for the Study of Law, Justice, and Society (Dejusticia), Assessments of Existing National Action Plans (NAPs) on Business and Human Rights: August 2017 update (August 2017). In the academic literature, see, e.g., Felice, Damiano de and Graf, Andreas, ‘The Potential of National Action Plans to Implement Human Rights Norms: An Early Assessment with Respect to the UN Guiding Principles on Business and Human Rights’ (2015) 7:1 Journal of Human Rights Practice 40–71 . See also O-Brien, Claire Methven et al, ‘National Action Plans: Current Status and Future Prospects for a New Business and Human Rights Governance Tool’ (2015) 1 Business and Human Rights Journal 117–126.
85 UK Secretary of State for Foreign and Commonwealth Affairs, Good Business: Implementing the UN Guiding Principles on Business and Human Rights, September 2013.
86 UK Secretary of State for Foreign and Commonwealth Affairs, Good Business: Implementing the UN Guiding Principles on Business and Human Rights Updated May 2016 (London, UK: Williams Lea Group, 2016), 3.
88 Ibid, 3 and 8.
89 Ibid, 8.
90 Ibid, 15.
91 Ibid, 16 and 18.
92 Craig, note 68, 16–17.
93 UK Secretary of State for the Home Department, The Government Response to the Report from the Joint Committee on the Draft Modern Slavery Bill Session 2013-14 HL Paper 166 / HC 1019: Draft Modern Slavery Bill (London, UK: Williams Lea Group, 2014).
94 See Craig, note 68, for a description of the historical and political context surrounding the development of modern slavery policy and legislation in the UK. See also Martin, Jena, ‘Hiding in the Light: the Misuse of Disclosure to Advance the Business and Human Rights Agenda’ (2018) 56:3 Columbia Journal of Transnational Law 534.
95 ICAR and ECCJ, Assessment of the National Action Plan (NAP) on Business and Human Rights of the United Kingdom (2016), August 2017, 9.
96 UK Home Office, Transparency in Supply Chains etc. A Practical Guide, 4 October 2017, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/649906/Transparency_in_Supply_Chains_A_Practical_Guide_2017.pdf (accessed 1 July 2019), 5.
97 UK Independent Anti-Slavery Commissioner, Annual Report for the period 1 October 2016 to 30 September 2017, (London, UK: The APS Group, 2017), 33.
98 UK Home Office, note 96, 4.
99 Ibid, 9.
100 UK Parliament, Modern Slavery Act 2015, Section 54. CSOs such as CORE have advocated for the removal of this legal loophole; see CORE, ‘Briefing for the General Debate on the Implementation of the Modern Slavery Act 2015’ (26 October 2017), https://corporate-responsibility.org/wp-content/uploads/2017/10/171026_briefing-for-general-debate-on-MSA-implementation_web.pdf (accessed 1 September 2018).
101 Martin, note 94, 577–578 (describing the paradox in which the Waitrose supermarket chain had a documented case of forced labour in its supply chain and yet was in full compliance with the MSA).
102 Fasterling, Björn and Demuijnck, Geert, ‘Human Rights in the Void? Due Diligence in the UN Guiding Principles on Business and Human Rights’ (2013) 116:4 Journal of Business Ethics , Special Issue on Universal Ethics, Cultural Diversity and Globalization – 17th IESE International Symposium (September 2013) 808.
103 Wen, Shuangge, ‘The Cogs and Wheels of Reflexive Law – Business Disclosure under the Modern Slavery Act’ (2016) 43:3 Journal of Law and Society 352.
105 Martin, note 94, 578.
106 Ibid, 575.
107 Crane et al, note 67, 16.
108 UK Home Office, note 96, 7.
109 Know the Chain, Eradicating Forced Labor in Electronics: What do Company Statements under the UK Modern Slavery Act tell us?, March 2018, https://knowthechain.org/wp-content/uploads/KTC-ICT-MSA-Report_Final_Web.pdf (accessed 12 July 2019).
110 Ibid, 8.
111 Ibid, 13.
112 UK Secretary of State for Foreign and Commonwealth Affairs, note 87, 16 and 18.
113 Jo Swinson, ‘Benchmarking Business Ethics’, Huffington Post (18 December 2014), https://www.huffingtonpost.co.uk/author/jo-swinson/ (accessed 12 July 2019).
114 UK Government, ‘Jo Swinson pledges support for a new ranking of companies’ human rights performance’ (18 December 2014), https://www.gov.uk/government/news/jo-swinson-pledges-support-for-a-new-ranking-of-companies-human-rights-performance (accessed 12 July 2019).
115 CHRB, Corporate Human Rights Benchmark Methodology 2018 For the Agricultural Products, Apparel and Extractives Industries (CHRB Ltd, January 2018), https://www.corporatebenchmark.org/sites/default/files/CHRB%202018%20Methodology%20Web%20Version.pdf (accessed 12 July 2019), 40.
116 CHRB, Corporate Human Rights Benchmark Key Findings 2017 (CHRB Ltd, March 2017), https://www.corporatebenchmark.org/sites/default/files/2017-03/CHRB_Findings_web_pages.pdf (accessed 12 July 2019), 6.
117 Ibid, 32–33.
119 Mike Scott, ‘Business Starts to Take Human Rights Seriously as Laws and Benchmarks Start to Bite’, Forbes (21 May 2018), https://www.forbes.com/sites/mikescott/2018/05/21/business-starts-to-take-human-rights-seriously-as-laws-and-benchmarks-start-to-bite/#542661b67f5d (accessed 12 July 2019).
120 Niamh Michaill, ‘Human rights report names, shames and praises food firms’, Food Navigator (15 May 2018), https://www.foodnavigator.com/Article/2018/05/15/Corporate-Human-Rights-Benchmark-report-shows-lack-of-uptake# (accessed 12 July 2019).
121 Australasian Centre for Corporate Responsibility, ‘Special resolution to amend our company’s constitution’, https://d3n8a8pro7vhmx.cloudfront.net/accr/pages/547/attachments/original/1506481338/WOW_resolution.pdf?1506481338 (accessed 12 July 2019).
122 Australasian Centre for Corporate Responsibility, ‘ACCR resolution withdrawn after Woolworths and NUW reach historic agreement on human rights of farmworkers’ (22 November 2017), https://d3n8a8pro7vhmx.cloudfront.net/accr/pages/436/attachments/original/1511331870/ACCR_media_release_-_WOW_human_rights_commitments%281%29.pdf?1511331870 (accessed 12 July 2019).
123 US Department of State, Responsible Business Conduct: First National Action Plan for the United States of America, 16 December 2016, https://www.state.gov/documents/organization/265918.pdf (accessed 12 July 2019).
124 See https://www.ohchr.org/en/issues/business/pages/nationalactionplans.aspx (accessed 12 July 2019).
125 The US NAP also references its commitment and action on SDG 8.7 to eliminate forced labour and human trafficking; US Department of State, note 123, 16.
126 US Department of State, note 123, 6.
127 Trade Facilitation and Trade Enforcement Act of 2015, H.R. 644 (24 February 2016) (United States), https://obamawhitehouse.archives.gov/the-press-office/2016/02/25/signing-statement-hr-644 (accessed 12 July 2019).
128 US Department of State, note 123, 11.
129 Ibid, 10.
130 Ibid, 14.
132 Ibid, 20.
133 US Department of State, note 123, 9.
134 ICAR, Assessment of the United States National Action Plan (NAP) on Responsible Business Conduct, March 2017, 9.
136 Kevin McAleenan, ‘TFTEA – Two Years and Counting’, US Customs and Border Protection (28 February 2018), https://www.cbp.gov/newsroom/blogs/tftea-two-years-and-counting (accessed 10 July 2018).
137 Human Rights First, ‘TIP Report Underscores Need for Global Accountability to Combat Human Trafficking’ (27 June 2017), https://www.humanrightsfirst.org/press-release/tip-report-underscores-need-global-accountability-combat-human-trafficking (accessed 25 August 2018).
138 Ibid, 26.
139 Final Rule, 80 Fed. Reg. 4967 (2 March 2015) (United States), https://www.federalregister.gov/documents/2015/01/29/2015-01524/federal-acquisition-regulation-ending-trafficking-in-persons (accessed 1 September 2018).
141 Mehra and Shay, note 68, 462.
142 This organization is now called the Responsible Business Alliance.
143 Responsible Business Alliance, ‘Electronics Industry Leads the Way in Combating Forced Labor EICC Code of Conduct Bans Recruitment Fees, Strengthens Key Protections for Workers’ (8 April 2015), http://www.responsiblebusiness.org/news-and-events/news/electronics-industry-leads-the-way-in-combating-forced-labor/ (accessed 12 July 2019).
145 Institute for Human Rights and Business, ‘Launch of the Leadership Group for Responsible Recruitment’ (5 May 2016), https://www.ihrb.org/employerpays/view-news/news-launch-of-the-leadership-group-for-responsible-recruitment (accessed 12 July 2019).
147 US Department of State, note 123, 15.
148 See https://partnershipforfreedom.org (accessed 12 July 2019).
149 US Department of State, note 123, 14. The Partnership for Freedom was part of the US government’s broader strategy to address human trafficking; see Partnership for Freedom, ‘White House Announces Pathways to Freedom, a new Partnership for Freedom challenge’ (24 October 2016), https://partnershipforfreedom.org/white-house-announces-pathways-to-freedom-a-new-partnership-for-freedom-challenge/ (accessed 12 July 2019).
150 See https://partnershipforfreedom.org/rethinksupplychains/#winners-current (accessed 12 July 2019).
151 Nakamura, Katrina et al, ‘Seeing Slavery in Seafood Supply Chains’ (2018) 4, e1701833 Science Advances 2.
153 Ibid, 8.
154 See ICAR-DIHR, note 83, 80.
155 UNWG, note 79, i.
156 US Department of State, note 123, 11.
157 OHCHR, note 18, 10.
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