Our webinar "Modern slavery and supply chains: how company data can help you identify entities linked to forced labour" featured a discussion with Valerie Farabee, director of operational research and analysis at Liberty Shared. We explored how global data and analysis can help uncover interlinked entities and beneficial owners within the supply chain.
Liberty Shared is an NGO devoted to preventing human trafficking, forced labour and modern slavery. It does this through legal advocacy, technological interventions, and strategic collaborations with NGOs, corporations, third-party databases, financial institutions and regulators around the globe. Valerie Farabee not only answered some of our questions in an interview covering forced labour in the fishing industry, but she also responded to several audience questions following the webinar.
What are some of the other industries, apart from fishing, that have known slavery instances?
Agriculture, construction, the garment industry–just to name a few! Any industry where there is an excess of willing workers and a dearth of regulations is vulnerable to slavery.
Can you tell us something about the financial indicators behind modern slavery?
Depending on the type of case there are a number of different indicators to be used, and depending on whether we are looking at retail or institutional banking. The first indicator: is the price of goods at the source extremely low? So low that it doesn’t make business sense?
In the case of the fishing industry, a recent study showed that fishing would be negatively profitable without government subsidies. So marrying that kind of information with on-the-ground information about the state of each country’s fishery, and adverse media info, could act as indicators.
Are there any successful prosecutions you have been directly involved in?
We are currently involved in some ongoing cases and our Legal Hub has been involved in a number of successful legal maneuverings.
Once you are in possession of information or names on who might be in charge of slavery, would Liberty Shared also file SARs (suspicious activity reports) to FIUs (financial intelligence units)?
We give our information to a number of FIUs. And in the case that civil society has the ability to file a SAR (available in some jurisdictions), we would file one.
Are your research results included in other paid database services used for broad third party due diligence?
Yes. Our results are included in a number of paid databases used daily by the financial sector. We do not charge these databases (or anyone) for this information.
Any chance there are online databases to check for companies who have been convicted or are suspected of modern slavery?
There is not currently an overarching database that contains information on all companies who have been convicted or suspected of forced labour, but there are a few resources you can put together to see what you can find: adverse media searches where you check a companies name against “human trafficking” or “forced labour”.
There’s Brazil’s “dirty list” which lists the names of companies convicted of forced labour in Brazil, and there are a number of civil society resources available through NGOs like Liberty Shared. We hold a list of names of people and companies that have been convicted of forced labour, that we can make available to vetted financial crime professionals.
How do you deal with a complex subsidiary structure?
Very carefully! These are some of our favorite knots to untie. Persistence and creativity are necessary to think around a problem and find that kind of information. It can be difficult, but it is also possible. I like to look at things sideways–approach it from a different perspective and you may be able to find an unexpected resource to give you the information you’re looking for.
You may also be interested in:
- An interview with Kaitlyn Speer, manager, operational research and analysis for Liberty Shared
- Really getting to know your third parties
- Creating clarity around ownership structures
- A-Z guide of compliance and ownership