Deloitte's recent poll of representatives of companies with anti-trafficking programs currently in place or planning to launch such programs in the next 12 months revealed that the company's global GC/CLO is the executive most commonly slated to assume lead responsibility for managing the program for those companies that are planning a launch, whereas the global CCO or CRO is most commonly assuming that role for companies with existing anti-trafficking programs.
Additional key findings include:
- For those companies with existing programs, nearly half conduct due diligence on new third parties and on an ongoing basis for existing third parties to prevent engagement with human traffickers. In contrast, third party due diligence activities at those companies that plan to launch a program in the next 12 months are much more limited - with most respondents indicating that they plan to either conduct due diligence on existing third parties (22%) or new third parties (25%) - or not at all (17.6%).
- More than 40% of companies with existing programs use advance technologies such as AI or cognitive computing to monitor transactions for possible ties to human trafficking, as compared to just 26% of companies that plan to launch within the next 12 months.
Note that the number of "existing program" and "planned program" respondents differed by polling question, which defeats comparability across questions or between respondent groups; however, the information is still instructive for benchmarking purposes and for those who may want to learn from companies that already have anti-trafficking programs in place to inform their program planning efforts. See Deloitte's release, Covington's "Trump Administration Renews Focus on Anti-Human Trafficking Efforts," and additional information & resources on our Compliance & Ethics page. This post first appeared in the weekly Society Alert!