CCRcorp Sites  

The CCRcorp Network unlocks access to a world of insights, research, guides and information in a range of specialty areas.

Our Sites


A basis for research and practical guidance focusing on federal securities laws, compliance & corporate governance.


An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.


The “one stop” resource for information about responsible executive compensation practices & disclosure.

Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.


Keeping you in-the-know on environmental, social and governance developments

Ed. note: A warning – some of this post may be hard to read, but it shows some of the stark reality of human trafficking. This comes from Matt Friedman, founder and CEO of The Mekong Club. Matt is a global expert on modern slavery and human trafficking, award-winning filmmaker, author and philanthropist. I am fortunate to work with Matt through the Alliance to Stop Slavery and End Trafficking (ASSET). This article below was adapted from a chapter in his book “Where Were You? A Profile in Modern Slavery.

Years ago, I was in Hanoi, and received a call from a local Vietnamese man. He asked if I was Matthew Friedman. I said yes. He then asked if he could meet with me. As a UN official, I used to get these kinds of calls regularly. It was usually someone who wanted to better understand my work. The next day we met in a small café. He was well-dressed and well-educated. In fact, I’d go as far as saying that he was very interesting and pleasant. For an hour, I talked about my work.

When I finished, I asked, “So, what do you do?” Without hesitation, he said,

I’m a human trafficker.

I was shocked.

He went on to state that he always wanted to talk to someone like me and thanked me for my time. While part of me wanted to storm off, I decided instead to continue talking to him. For the next hour, he described how he trafficked women and girls into forced prostitution and sometimes men into forced labor. I was surprised how open he was. He didn’t hold anything back. At one point, he handed me his card and said,

Go ahead and try to catch me. You’ll never be able to. I’m too insulated.

He began by saying my work was a joke. He said, as a criminal, he had the ability to change his approach, if necessary, to keep ahead of the game. He said that in my NGO world, we followed static plans and inflexible procedures. He was right. Because we abide by rules, he said that we’d never win the fight. In his world, they have no rules: they could be unethical, unconventional, unorthodox, and ruthless. He said this is the reason why crime pays. The legal system is too encumbered by processes and procedures that constantly trip it up.  He repeatedly laughed out loud at the things he said. 

He added that NGOs and the UN are not equipped to do counter-trafficking work. He asserted that they don’t understand the criminal world. Without this comprehension, they can do little to affect his business. Greed, he said, is always a much more efficient motivator than the desire to save the world. In his case, the outcome of his work is a handful of cash – tangible and real and offers instant gratification. In my case, the profit was “a person gets helped.” Properly helping a person is anything but quick or easy.

I learned from this encounter how important it is to understand human trafficking from those who know it best – the victims and the criminals. Getting first-hand accounts from criminals gives us detailed insight into systems and procedures used to recruit, initiate, and hold a person in a trafficking situation. This is never easy, but it must be incorporated into the work we do. 

What This Means

So how does this story relate to a company’s situation?  What practical lessons can be learned?  There are three points I’d like to make.

  • First, we need to understand that people who traffic workers are master liars and manipulators.  There is nothing they won’t say or do to cover their tracks to prevent their nefarious actions from being found.  This makes it harder for auditors to collect information from workers about situations they face. With the possibility of punishment hanging over their head, victims will often not speak.  In extreme cases, companies may have to resort to surveillance of a factory complex instead of using a traditional audit. Over the years, auditors have said to me “while the factory looked okay, there seemed to be something that was off.  I looked for it, but couldn’t find it.  When I shared this with the brand, they carried a much deeper investigation that found a massive problem.”
  • Second, many traffickers are told when an audit will take place.  This allows them to move staff around and change dynamics of an audit when it occurs. It is essential that brands include a clause that allows unscheduled audits to take place. As one auditor stated, “I sat at the tea stall outside the factory for three days before I was able to determine the best time to carry out a visit. By doing this, I was able to spot behavior that seemed suspicious. Using this approach helped us to understand what was really happening in this factory. And it wasn’t good.” 
  • Third, one brand I worked with had auditors talk to migrants who returned home to their country. Because those workers did not feel the threat that kept them in place, they were willing to share their experiences in great detail. As one brand manager stated, “we had to get creative to find out what was really happening in that factory. While it was more costly and time consuming [than a typical audit], it helped us to avert a disaster. The past employees revealed the true state of the factory.” 

What You Can Do

The private sector can be a force to be reckoned with if companies work together, share data and resources, rather than operate in siloes that offer perfect opportunities for exploitation to go undetected and underreported. Some companies lack effective and timely data and don’t even share information within departments, let alone between peers. Traffickers know about – and capitalise on – this weakness. To the extent allowable within antitrust/anti-competition laws, companies should put aside competitive differences if there is an opportunity for mutually beneficial shared action. For example, audit data, case studies and intelligence on trafficking trends can be shared. There are many regional and global forums and confidential working groups that facilitate this and can upskill entire industries to work as one.

Companies and consumers alike should also accept and embrace the fact that the criminal world changes and there is no perfect timeless solution to the threats facing global supply chains. Practically speaking, all industries and all countries have human trafficking issues in some form. As a society, we should reward those companies trying new approaches and encourage them to be practical and honest in their disclosures. This will encourage a movement away from rose-tinted sustainability rhetoric and allow companies to focus on tackling root-cause problems that they face rather than live in fear of a negative news article or ESG score that may arise if they look too closely at their operations.

Recognizing the extent to which criminals will cheat, steal and hide their actions, variations on the auditing theme are warranted to uncover the truth.  

Back to all blogs

The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile