In June 2018, CBIS had a dialogue with Verizon on child exploitation. Verizon’s Oath division (Yahoo! and AOL) has joined the Technology Coalition to combat child exploitation online with tech partners, at our urging.

In October 2017, CBIS attended the World Congress on Child Dignity in the Digital World in Rome, and the Declaration of Rome – an action plan for faith leaders, governments, and companies to better address child sexual exploitation online – which was subsequently endorsed by Pope Francis. CBIS is now part of a subroup of experts working to roll out the Declaration and will report to the Vatican on progress. In 2018 ,we began organizing an advisory committee of investors that specialize in children’s human rights, to draft expectations for the technology sector to better protect children from the digital threats of exploitation, grooming, and trafficking online.

In May 2017, CBIS’ Tracey Rembert and Shaska Chirinos met with Chicago Police Department detectives to learn more about how internet technology is used to both assist and deter law enforcement in identifying child sex traffickers. We are also interviewing leading nonprofits like Thorn, The Technology Coalition, the ACLU and Unicef to understand how the many pieces of technology, privacy law, and online sex abuse connect. We will use this information to work with our focus companies to implement best practices for oversight and disclosure, and specific policies that better identify and prevent child sexual abuse online.

CBIS is engaging with AT&T, Spring, T-Mobile, and Verizon to encourage the companies to develop solutions to combat child sex trafficking and exploitation online and foster effective content filtering strategies on devices. The internet and devices to access it have transformed pornography and child victimization into an on-demand market. The ability to tag, analyze, block and filter illegal content is crucial, in order to identify victims, assist child protection groups, and educate law enforcement on trends. Even more troubling are the rising numbers of children forced into commercial sex acts online, through popular apps and websites. Tech and telecom companies are at the center of the debate, with the ability to block images, educate kids and parents, and save victims from abuse. CBIS had previously sent letters to each company inquiring about their content filtering options available on mobile devices. We are currently building a coalition of Catholic investors to join us in engaging each of our telecom companies.

In October 2017, CBIS attended the World Congress on Child Dignity in the Digital World in Rome, and the Declaration of Rome – an action plan for faith leaders, governments, and companies to better address child sexual exploitation online – which was subsequently endorsed by Pope Francis. CBIS is now part of a subroup of experts working to roll out the Declaration and will report to the Vatican on progress. Beginning in 2018 ,we will be organizing an advisory committee of investors that specialize in children’s human rights, to draft expectations for the technology sector to better protect children from the digital threats of exploitation, grooming, and trafficking online.

CBIS also sent a letter to Sprint’s board seeking policy changes where parents would opt-out of parental controls, and for the company to improve its Acceptable Use Policy to better protect children and block abusive content.

In May 2017, CBIS’ Tracey Rembert and Shaska Chirinos met with Chicago Police Department detectives to learn more about how internet technology is used to both assist and deter law enforcement in identifying child sex traffickers. We are also interviewing leading nonprofits like Thorn, The Technology Coalition, the ACLU and Unicef to understand how the many pieces of technology, privacy law, and online sex abuse connect. We will use this information to work with our focus companies to implement best practices for oversight and disclosure, and specific policies that better identify and prevent child sexual abuse online.

The internet and devices to access it have transformed pornography and child victimization into an on-demand market. The ability to tag, analyze, block and filter illegal content is crucial, in order to identify victims, assist child protection groups, and educate law enforcement on trends. Even more troubling are the rising numbers of children forced into commercial sex acts online, through popular apps and websites. Tech and telecom companies are at the center of the debate, with the ability to block images, educate kids and parents, and save victims from abuse.

CBIS is engaging with AT&T, Spring, T-Mobile, and Verizon to encourage the companies to develop solutions to combat child sex trafficking and exploitation online and foster effective content filtering strategies on devices. CBIS had previously sent letters to each company inquiring about their content filtering options available on mobile devices. We are currently building a coalition of Catholic investors to join us in engaging each of our telecom companies.

 

Target’s Vice President of Corporate Responsibility announced a new Sustainable Seafood Policy that commits the company to collaborate with companies and NGOs to promote ethical working conditions and support for public policy that will ensure implementation of core labor standards. CBIS has been calling for worker protections for two years and was pleased the company took these steps in November 2018.

In a call with Target in February 2017, CBIS encouraged the company to release details of audits of its Thai seafood suppliers in light of egregious forced labor violations over the past 3 years, and share information about its participation in The Seafood Task Force, an influential, diverse coalition tackling human rights in Thailand, which Target joined at CBIS’ urging.

In October 2016, CBIS participated in a call with Target regarding Target’s new Responsible Sourcing and Sustainable Design 2020 goals. The company shared its key areas of focus: improving worker well-being, achieving net-positive manufacturing, and deriving key raw materials from ethical and sustainable sources. We have asked for additional detail on each of these areas of focus. The company made clear that it is committed to collaboration and transparency, including to the Seafood Supply Chain Task Force, a key area of interest for CBIS given our ongoing concerns regarding slave labor in the seafood supply chain in Thailand. The company is making headway to make sure that workers do not pay a fee for jobs, as is the case with unscrupulous labor brokers. In related news, we were pleased that Target is now having its fresh and frozen shrimp certified by Marine Bay Aquarium Project, and the company is also looking to certify tuna. The company also shared its recently published factory matrix that outlines the nearly 500 factories, by country, it is using to produce its goods. Shareholders welcome transparency of this kind since it can help to identify leading and lagging factories in terms of worker safety, environmental performance and human rights standards.

We are pleased to announce that Target joined the Shrimp Sustainable Supply Chain Task Force in September 2016, a longtime ask of CBIS. Key goals of the Task Force include: Creating a standard code of conduct model for Thai ports, brokers and vessels; conducting audits of vessels; and tracking and tracing systems from vessel to feed mill. The multi-stakeholder alliance includes European and American retailers, their suppliers, NGOs and the major Thai shrimp processors and feed companies. Members include Costco, Walmart, World Wildlife Fund and our own Thai Union. We believe Target’s advances can help to reduce reputational risk, protect at-risk workers, and ultimately make its seafood supply chain more resilient. We continue to urge Target to publicly report on its progress and to join additional programs that help migrant workers choose good employers, find safe work and living conditions, and avoid exploitative labor brokers. Target mentioned that it is now looking to take additional steps to trace its tuna supply chain.

In early 2016, Target hired a labor and human rights experts to be onsite in Bangkok to assess the seafood supply chain in Thailand. This is one of many steps Target has detailed to address human trafficking in the seafood supply chain in Thailand, including furthering knowledge of abuses in the shrimp supply chain through in-country meetings with the Thai government, the International Labor Organization, and key vendors; working with other retailers to communicate the need to address this issue with the Thai government; and implementing a process to trace the supply chain from ocean to table. Target audits its seafood processing facilities but does not currently make audit findings public.

After an investigation in January 2016 revealed that poor migrant workers and children were sold to factories in Thailand and forced to peel shrimp that ended up in global supply chains (Slave-peeled shrimp tied to major retailers, restaurants — 12/14/2015) CBIS contacted Target. Target is aware of the investigation and the need for even more productive multi-sector collaboration on this critical issue. As part of its traceability commitment, Target has been vigilant in evaluating its own supply from Southeast Asia and is working with a wide range of stakeholders (industry, NGOs, government, etc.) to address human rights violations. Target is currently assessing the opportunity to engage more formally with the Shrimp Sustainable Supply Chain Task Force – a group of retailers, manufacturers, government, and human rights organizations working to create procedures for ports, and to trace the seafood supply chain from vessel to feed mill – and its collaborative plan to achieve more oversight.

In September 2017, CBIS met with Coca-Cola’s director of global workplace rights and a small working group of ICCR members to strategize around best practices in respecting human rights in the company’s operations and supply chains. This intelligence can help us assess human trafficking policies at other major companies that are sourcing commodities around the globe.

In the second quarter of 2014, Coca-Cola published its Human and Workplace Rights Issue Guidance for its suppliers and bottlers that seeks to protect human rights in its supply chain. Although CBIS’ focus with Coca-Cola is on water stewardship, the guidance document is an important step for a major corporation in recognizing worker rights and establishing clear expectations for its partner companies. A particular focus of the guidance is on the ethical recruitment of workers including no worker-paid recruitment fees, employer-paid transportation to host countries, and full payment of earnings to workers (no automatic debiting of payments to cover expenses).

CBIS has been pressing Campbell’s Soup for two years to address the chain of indebtedness and worker dignity in their supply chain. In June, Campbell Soup released a Code of Conduct for suppliers that addresses labor trafficking:

  • Forbids suppliers from charging workers fees or retaining passports, so workers have freedom of movement.
  • Requires suppliers to provide workers with itemized wage statements, in a language understood by the worker.
  • Calls for audits of vendors, subcontractors and independent contractors.

When we next meet with the company, we plan to discuss the rollout of the Code to suppliers, to better understand implementation, effectiveness and adherence.

In January 2017, CBIS engaged in a robust conversation with the Siemens Head Of Regulatory Compliance for Conflict Minerals regarding the company’s due diligence and monitoring on its conflict minerals sourcing from smelters and refiners. Siemens reported that it is very active with the Conflict Free Sourcing Initiative, which is working to expand its audit protocols to assure compliance will met to the new EU law. While Siemens demonstrated that it is closely working with the leading industry initiative on the sustainable sourcing of minerals, the company falls behind peers on its transparency through disclosure of performance. CBIS encouraged Siemens to increase its disclosure of progress on ensuring its supply chain is free from conflict minerals.

In July 2016, CBIS requested a meeting with Siemens, which supplies products, systems and solutions on energy management, and building and manufacturing technologies, to better understand how its intends to comply with a new EU conflict minerals rule. The rule calls on companies to report on their mineral sourcing practices based on a new set of performance indicators under development.

The mining of certain minerals (including tin, tantalum, tungsten and gold) have been linked with funding multiple human rights abuses in the Democratic Republic of Congo and other conflict zones.  These minerals can enter multinational companies’ supply chains as they manufacture products such as jewelry, laptops, mobile phones and cars.

The implementation of the Dodd-Frank Wall Street Reform Act (Section 1502) in 2010 ushered in significant progress in the development of traceability and certification mechanisms to distinguish “conflict-free” mines from those that continue to finance armed groups and promote violence. While increased traceability and transparency have led to a reduction in the number of tin, tantalum, tungsten, and gold (3TG) conflict mines in eastern Congo, the Democratic Republic of Congo (DRC) and neighboring regions remain in a state of armed conflict.

In June 2016 the European Parliament provisionally agreed to a reporting mechanism that would be mandatory for those that import the minerals and metals as raw materials into the EU, and request voluntary disclosure from other companies, like those whose finished products may contain conflict minerals (i.e. Siemens.) The regulation would cover all conflict regions worldwide, unlike Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires declarations of conflict minerals only from the Democratic Republic of Congo and adjacent countries.

In May 2016, CBIS attended the Nucor annual shareholders’ meeting to question executives on initiatives to prevent slave labor in the company’s Brazilian supply chain, and its disclosure to shareholders of its progress.

In the fourth quarter of 2014, Nucor issued an update of steps it is taking to combat human trafficking in Brazil. In 2007, investigations revealed the prevalence of forced labor and armed surveillance by charcoal producers in Northern Brazil. Because charcoal is an input in Nucor’s steel production, the company has taken steps to eradicate slave labor from its supply chain. A new update from Nucor reported that between May 2010 and June 2014, 822 random, unannounced audits of charcoal facilities supplying its member pig iron manufacturers were conducted, covering ~25,000 laborers, and the ICC found no instances of forced labor or armed surveillance by employers or hired guards.

In 2018, Apple blocked the Telegram app until it fixed a vulnerability that allowed child sex imagery to be sent to others. They have also launched new and stronger parental controls for parents to monitor time and app usage and suspicious activity of children’s internet and phone use, addressing one of our key asks.

In October 2017, CBIS attended the World Congress on Child Dignity in the Digital World in Rome, and the Declaration of Rome – an action plan for faith leaders, governments, and companies to better address child sexual exploitation online – which was subsequently endorsed by Pope Francis. CBIS is now part of a subroup of experts working to roll out the Declaration and will report to the Vatican on progress. Beginning in 2018 ,we will be organizing an advisory committee of investors that specialize in children’s human rights, to draft expectations for the technology sector to better protect children from the digital threats of exploitation, grooming, and trafficking online.

In May 2017, CBIS’ Tracey Rembert and Shaska Chirinos met with Chicago Police Department detectives to learn more about how internet technology is used to both assist and deter law enforcement in identifying child sex traffickers. We are also interviewing leading nonprofits like Thorn, The Technology Coalition, the ACLU and Unicef to understand how the many pieces of technology, privacy law, and online sex abuse connect. We will use this information to work with our focus companies to implement best practices for oversight and disclosure, and specific policies that better identify and prevent child sexual abuse online.

In the second quarter of 2017, Apple responded about its Guidelines for App Developers. The tech giant has long disallowed pornography and included some language prohibiting physical harm to users, including kids.  The Guidelines highlight software developers’ responsibilities to refrain from facilitating content that conflicts with Apple’s terms. In September, Apple released an updated set of Guidelines that took an even stronger stance on the topic: “In extreme cases, such as apps that are found to facilitate human trafficking and/or the exploitation of children, appropriate authorities will be notified.” Apple further prohibited developers from using facial recognition software for account authentication if users are under 13; it strengthened its Kids portal requirements, anti-bullying, and anti-violence criteria; and it curtailed more Location Services tracking that can endanger children and facilitate sex grooming.

In 2016, CBIS began to engage Apple on the issue of distribution of pornography. As a leader in the digital world, Apple has a responsibility to ensure that users of their digital store, content sharing, and communication products are property protected. Apple lags industry competitors such as Microsoft, Google, and Facebook, which have championed preventative software to report exploitative images and implemented zero tolerance policies in their code of ethics. CBIS will work with Apple to ensure the company is creating policies designed to protect children online, promoting positive use of information and communication technologies, creating new tools to improve the detection and removal of exploitative content, and reporting annually on progress and challenges. With little disclosure on the topic, Apple was been a difficult company to assess in terms of its policies, programs or commitment to combating illegal porn and child sexual exploitation. The company had no disclosure of policies on the issue, nor partnerships with key anti-exploitation or trafficking groups. After writing the company and having initial discussions with corporate staff, and we were told we are the first investor to raise such issues with the company to date. Apple disclosed one policy to CBIS, but refused to divulge more – Microsoft, Facebook, Kik, and Google (Alphabet) are doing far more. CBIS began building a coalition of Catholic investors to join us in engaging each of our five tech and telecom companies.

In January 2017, CBIS met with management to discuss human trafficking initiatives and establish a rapport with the company. In response to a shareholder proposal filed with United Continental, the company has substantially strengthened its human rights policy. It applies to all 85,000 employees of which 23,000 are flight attendants. CBIS and investors will continue to provide input and resources toward effective implementation of the human rights policy that includes further training to monitor and act on human trafficking activity. Specifically, we are encouraging United to train its flight attendants to identify signs of human trafficking and to disclose the effectiveness of such programs, continue to improve its human rights policies to include stricter requirements on forced labor and child exploitation, and to sign The Code of Conduct for the Protection of Children from Sexual Exploitation.

In 2016, CBIS began to engage United on the issue of human trafficking in the airline sector. Airport personnel are in a unique position to discern possible trafficking situations. As the fourth largest airline in the world, United has the potential to play a vital role in identifying and assisting trafficking victims. While other companies are taking action, United’s reporting does not indicate if the company has developed effective internal controls. United published a human rights policy statement last year that repudiates forced labor, child labor and sexual exploitation and a commitment to cooperate with law enforcement. CBIS will work with United to ensure the company is demonstrating implementation by training flight attendants, developing programs with law enforcement, raising awareness and reporting annually on progress and challenges.

In 2016, CBIS began to engage Thai Union on the issue of human trafficking in the seafood section. Human trafficking abuses in the shrimp supply chain in Thailand have been well documented. As the largest seafood company globally by sales, Thai Union has the ability to have far-reaching impacts in the sector to improve labor standards. CBIS will work with Thai Union to ensure the company is assessing its immediate and extended seafood supply chain for human trafficking.

Thai Union came to CBIS’ office in the third quarter of 2016 to outline its progress to eliminate slave labor from the seafood supply chain in Thailand. The company has taken a number of steps since widely circulated investigations uncovered abusive working conditions at a number of Thai Union suppliers. This external attention has pushed Thai Union to make significant changes in its business operations, including hiring workers directly rather than rely on labor brokers, some of whom charge workers exorbitant fees, promise jobs that never materialize, confiscate identity documents so workers are unable to leave, and often withhold pay. Thai Union is working with a variety of NGOs to provide grievance mechanisms for workers in factories and at sea and is now auditing its shrimp supply chain from vessels to fishmeal plants and farms to ensure suppliers comply with its code against forced labor. Violators of human rights stipulations are immediately terminated.  Thai Union is taking an active role in the Shrimp Sustainable Supply Chain Task Force (which actually covers the whole of seafood, in spite of the name). In addition to corporate representation, government representatives are included and NGOs act as an external advisory body to provide oversight. The Task Force is creating a code of conduct, auditable standards, and a model for monitoring that they will all agree to adhere to. The company also hired a Director of Sustainability who has been given free reign by senior management to implement changes. The company is now one of the leaders in the industry. Since much of its program is in its infancy, CBIS will follow the company’s implementation closely.