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Prepared for course:

GPS SPRING 2019 : “Global Corporate Accountability:
Issues of Governance, Responsibility and NGOs”
Prof Peter Gourevitch

Accountability Case Studies Project
Corporations, NGO and Nonprofits Case Studies Project
No: 19-01

Corporate Behavior Change:
Forced labor in tech supply chains-The Case of GoPro
by Camila Gomez Wills
June 2019

COPYWRITE June 2019:
Do not Copy or quote without citation of the author and location.

Camila Gomez Wills – A53265648 – June 2019
Global Corporate Accountability: Issues of Governance, Responsibility and NGOs
Corporate Behavior Change – Forced labor in tech supply chains – GoPro
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Table of Contents
Abstract................................................................................................................................ 4
Problem Scope .................................................................................................................... 4
Definition and Applicable Regulation .................................................................................. 5
California and UK responses ......................................................................................... 6
OECD guidelines and SDG’s ......................................................................................... 7
Forced Labor in the ICT Sector ........................................................................................ 10
Mining phase ............................................................................................................... 10
Assembly phase: Malaysia case study......................................................................... 12
Private brand responses .............................................................................................. 13
GoPro ................................................................................................................................. 14
Disclosures...................................................................................................................... 15
Relationship with Suppliers .............................................................................................. 16
Human Rights ................................................................................................................. 16
Minerals Sourcing ............................................................................................................ 16
Pressure Points ................................................................................................................. 16
Publicly-Traded Companies: Stock Price and Reporting Requirements ............................ 17
Preempt Regulation and Legal Recourse ......................................................................... 18
Stakeholder Pressure ...................................................................................................... 19
Window of Opportunity for Corporate Change ................................................................ 20
Organizational Change .................................................................................................... 21
Persuasion and Diffusion ................................................................................................. 21
Relevant Benchmark ......................................................................................................... 22
Recommended Actions ..................................................................................................... 23
Audience 1: Shareholders – financial risk......................................................................... 23
Key goal: Conduct risk assessments ........................................................................... 24
Audience 2: regulators – legal risk ................................................................................... 24
Key goal: Blockchain technology for transparency ....................................................... 25
Pros and cons ............................................................................................................. 26
Audience 3: consumers – reputational risk ....................................................................... 30
Key goal: publish supplier lists & join relevant organizations ........................................ 30
Conclusion ......................................................................................................................... 31
References ......................................................................................................................... 32

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Corporate Behavior Change – Forced labor in tech supply chains – GoPro
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Camila Gomez Wills – A53265648 – June 2019
Global Corporate Accountability: Issues of Governance, Responsibility and NGOs
Corporate Behavior Change – Forced labor in tech supply chains – GoPro
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Abstract
Companies that sell electronic goods, such as GoPro, often depend on supply chainsthat span the globe and involve mining, smelting, and assembling components. Forcedlabor is a violation of human rights that can occur in any of these phases and presents alegal, financial, and reputational risk that companies are beginning to address. There are
best practices available to tackle forced labor and GoPro should implement a detailed
timeline for adopting them.
This paper seeks to provide guidelines for changing GoPro’s corporate behavior andeliminating forced labor in its supply chains by a) summarizing applicable regulation andthe overall manner in which forced labor operates in the ICT industry today, b) describing
GoPro and how it compares to peer benchmarks, c) identifying the pressure points andthe window of opportunity to act, and d) reviewing common best practices for this fieldand suggesting a path forward through three key audiences.
Problem Scope
Many people erroneously believe that slavery is part of our collective past. Actually,
modern slavery is one of the fastest growing crimes and one of the most profitable ones(Jones and Winterdyk 2017). It is estimated to affect over 45 million people worldwide(Global Slavery Index 2016) and generates an estimated $150 billion USD in illegal profits
per year (ShareAction 2016).
Said briefly, modern slavery involves the “recruitment, harboring, transportation,
provision, or obtaining of a person for labor or services, through the use of force, fraud,or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage,or slavery” (Department of State 2018). Modern slavery is a broad term that includes sex
trafficking, forced labor, bonded labor, domestic servitude, and child soldiers, among
others. This document focuses on forced and bonded labor in the ICT industry andspecific ways to minimize it.
The following section will describe current regulatory frameworks, how forced labor
operates today, and highlights its incidence in the ICT sector. This will allow us to then
expand on what it is that private actors, particularly GoPro, can do to curtail this problem.

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Corporate Behavior Change – Forced labor in tech supply chains – GoPro
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Definition and Applicable Regulation
The technical definition for forced labor provided by the International Labor
Organization (ILO) is “work that is performed involuntarily and under the menace of any
penalty. It refers to situations in which persons are coerced to work through the use ofviolence or intimidation, or by more subtle means such as manipulated debt, retention ofidentity papers or threats of denunciation to immigration authorities” (ILO 2014a). Forcedlabor goes beyond “bad working conditions”. The severity in the degree of abuse is what
differentiates forced labor from simply bad working conditions. In other words, all formsof forced labor belong to the category of bad working conditions, but definitely not all
working conditions merit being considered as forced labor.
In an effort to help those involved in identifying instances of forced labor, the ILO hascreated a summary of circumstances that can serve to indicate its presence: abuse ofvulnerability, deception, restriction of movement, isolation, physical or sexual violence,
intimidation and threats, retention of identity documents, withholding of wages, debt
bondage, abusive working and living conditions, and excessive overtime (Special Action
Programme to Combat Forced Labour 2012). The presence of one or more of these 11
factors may indicate a forced labor case. Forced labor goes beyond what takes place on
the actual worksite and involves economic, physical, and psychological aspects.
There are not one, but several international conventions and protocols that were
designed to eliminate forced labor. Some of the most widely adopted are: the UN Protocol
to Prevent, Suppress, and Punish Trafficking in Persons; Optional Protocols on theConvention on the Rights of the Child; ILO Convention 29 on Forced Labor; ILO Protocolof 2014 on the Forced Labor Convention; ILO Convention 182 on the Elimination of the
Worst Forms of Child Labor; and ILO Convention 189 on Domestic Workers (Departmentof State 2018; ILO 2014a, 2014b). Many national constitutions consider freedom fromforced labor to be a human right, so regardless of ratification of these international
conventions, this right should be protected at a local level.
At a domestic level, the US has strict requirements for federal contractors that provide
goods and services to the US government which prohibits them from document
withholding, fraudulent recruitment, charging fees for work, and requires the provision of5

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Corporate Behavior Change – Forced labor in tech supply chains – GoPro
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a written contract, among others (Assent 2019a). Furthermore, contractors for the
Department of Defense (GoPro’s drones are allegedly used by the military (Barzani2016)) are subject to stricter requirements and are subject to unannounced supply chain
audits.
Although it is prohibited by national legislations in over 150 countries and has beenaddressed by multiple international protocols, prosecution remains low. In 2017, there
were only 7,045 global convictions for human trafficking related crimes (Department ofState 2018). If we consider that over 45 million people are affected, this number ofconvictions barely reaches 0.001% of the total number of cases.
It is important to note that human trafficking usually goes hand in hand with otherhuman rights violations: theft, abuse, torture, rape, among others (Global Initiative Against
Transnational Organized Crime 2019). The high prevalence of the crime, coupled withlow enforcement, motivates novel approaches for decreasing its incidence and is partiallywhy private actors have been increasingly called upon to take a proactive role ineliminating it. We do not believe that more reports and work recommending enforcementof anti-slavery laws is sufficient to promote effective change.
California and UK responses
Given this lackluster response from a prosecutorial standpoint, some jurisdictions havechosen to focus on requiring companies to proactively disclose their own efforts foreliminating forced labor in their supply chain. If companies are to do business within theboundaries of the jurisdiction, they must comply.
The idea behind these requirements is for the state to share the burden of policing
with the general public: companies are obliged to disclose their policies, and thus an
informed consumer could be in a position to whistle blow or exert pressure and alert
regulators that there is something amiss. This is an example of “fire alarm” forms ofregulatory oversight in which citizens are given the tools to alert legislators of misconduct(McCubbins and Schwartz 1984).
There are two notable examples of specific disclosure requirements for modern
slavery. First, the California Transparency in Supply Chains Act of 2010 requires any
company doing business in California with gross receipts over $100 million USD per year
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Corporate Behavior Change – Forced labor in tech supply chains – GoPro
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to provide a link on its homepage that addresses at least: verification, audits, certification,and international accountability and trainings provided related to forced labor (State ofCalifornia 2014). There are no specified financial penalties for non-compliance; ifanything, the company would receive an injunction from the State Attorney General tocomply (Assent 2019a).
The UK went further and in 2015 enacted national legislation that requires allcompanies with a global annual turnover over £ 36 million GBP to disclose on a direct linkon its website its efforts to address modern slavery in its supply chain. The disclosuremust include the director’s signature and have approval from the board of directors (Ernst& Young 2015). This standard is met by demonstrating a signature of the director on its
policies (documentary evidence) and a note on the approval of the board of directors.
Further compliance could be demonstrated by attaching the board meeting minutes
where this was discussed and the votes that approved it. As an example of the fire alarmoversight previously described, the UK government has explicitly stated that the goal of
the Act is for “stakeholder and consumer pressure to serve as the primary motivation forcompliance” (Assent 2019a). More recently, France has enacted a Duty of Vigilance Law(2017), and Australia began implementing its own version of a Modern Slavery Bill in 2018
(Sakulpitakphon and Casey 2019).
It is in the interest of the company to comply with these regulations for the virtuous
signaling that it gives consumers, non-profits and other stakeholders, and for risk
mitigation purposes of avoiding a scandal in which their lack of compliance is brought tolight. Nonetheless, even if these disclosure requirements are quite broad and general,they often remain unmet.
OECD guidelines and SDG’s
Looking beyond ratified international labor protocols and domestic requirements, theUnited Nations adopted the 2030 Agenda in 2015. At its core are 17 Sustainable
Development Goals that provide a roadmap for stakeholders to prioritize their actions andimprove livelihoods around the world. Of particular relevance for the topic of forced labor
is SDG 8 which promotes “sustained, inclusive, and sustainable economic growth, fulland productive employment and decent work for all” (Global Forum on Responsible
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Global Corporate Accountability: Issues of Governance, Responsibility and NGOs
Corporate Behavior Change – Forced labor in tech supply chains – GoPro
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Business Conduct 2017). Dignified working conditions are also closely related to poverty
reduction (SDG 1), hunger reduction (SDG 2), health (SDG 3), and women’s
empowerment (SDG 5). Having a stable, legal source of income provides individuals andtheir families with the means to satisfy their needs and materialize some complementaryrights. One of the relative advantages of the SDG’s is that they are closely linked to the
traditional framework of human rights (Shift and Business and Sustainable Development
Commission 2016).
Notwithstanding its importance, a recent analysis has found that the greatest gaps inachievement of the SDG’s is precisely in its economic, jobs, and gender elements (OECD2017). We argue that part of this gap can be explained by the generic nature of therecommendations and the difficulties in measuring progress. For example, the ILO
recommends taking “immediate and effective measures to eradicate and end modern
slavery and human trafficking”, implementing international labor standards, and ratifying
international protocols (ILO 2014b).
This level of abstraction has been partially remediated by the OECD, which particularly
for mining, has established clear, detailed, actionable steps for due diligence procedures.
After holding several rounds of consultations with industry leaders, governments from theGreat Lakes Region (from which the majority of minerals for electronics come from), andcivil society, the OECD defined a proactive on-going process for respecting human rights
and avoiding contributing to armed conflict.
Overall, the Guidelines recognize three major phases: identifying circumstances in the
supply chain (from extraction to end product), identifying and assessing risks, andpreventing and mitigating risks. For private actors looking to implement best practices inthis field, the guidelines provide very specific recommendations and an easy to follow
five-step framework that includes establishing strong company management systems communicating the policy and incorporating it into supplier contracts, establishing a chainof custody and traceability system, and a grievance mechanism-, a path for assessing
risks, implementing a strategy to respond to risks, third party audits, and reporting.
Additionally, they have put together a Model Supply Chain Policy that can be easily

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Corporate Behavior Change – Forced labor in tech supply chains – GoPro
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adapted to fit the needs of particular organizations. They also identify reputable sector
initiatives that may be joined.
It is important to recall that the OECD guidelines are voluntary and not legally
enforceable. Nonetheless, there are trade and commercial incentives for doing so:importers to the EU have to prove compliance, the Dodd Frank rule of the US SEC also
requires it, and the London Metal Exchange gave a 2020 deadline for compliance (OECD2016). For businesses, part of the interest in achieving the SDG’s and lifting millions outof poverty is that it can open up over 12$ trillion in markets (OECD Emerging Markets
Sector 2018).
On top of the OECD Guidelines and the UN SDG’s, there is also the so-called “Bali
Process”, a forum for policy dialogue that purports to convene key decisionmakers fromSouth East Asia to identify best practices, share information, and measure progress(Department of State 2018). The efficacy of these “soft”, non-enforceable initiatives has
been put into doubt and some consider that it is unlikely that they will lead to a significant
increase in worker wellbeing (Locke 2013).
Overall, forced labor is an immense problem that affects a significant proportion of theworking population and affects their ability to exercise their rights. This has created a
response that relies on international law conventions, local legislation, and more recently,
disclosure requirements and more general frameworks that link the elimination of forcedlabor with the broader notion of sustainable development. The efficacy of these
instruments has been insufficient to eliminate the problem and private actors are being
called upon to play a more active role. For GoPro, the SDG’s provide a general roadmap
and the OECD Guidance provides concrete steps for moving closer in their direction.
GoPro should rely on the OECD Guidance for its responsible sourcing policies.
Having defined the scope of the problem and current strategies for eliminating it, thefollowing section will describe in further detail how exactly forced labor operates in the
ICT sector. Only by understanding the mechanisms that drive it will we be able torecommend effective, targeted strategies for GoPro to implement.

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Corporate Behavior Change – Forced labor in tech supply chains – GoPro
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Forced Labor in the ICT Sector
Forced labor can take place through either sophisticated organized crime networks, or
through informal loosely knit groups that maintain this practice at a micro level in small
communities (Department of State 2018). Some of the common denominators of forcedlabor in the ICT sector include unlawful passport retention, deceptive recruitment
regarding wages, hours, overtime, and risk level of the job; debt; loss of freedom of
movement; and excessive penalties for leaving the job. Recall that not all bad working
conditions constitute forced labor (see above section on ILO indicators and differences).
The production of electronics is a prime example of the vulnerabilities that make forcedlabor possible: there are complex webs of multiple tiers of suppliers that are responsible
for very specific component parts that require low-skilled and easily replaceable workers
along the process. Often, there are no direct contractual relationships between the final
consumer-facing company and the suppliers downstream. As the director for Human
Rights Watch noted, forced labor is hard to identify: “While a lot of this might look likenormal work, when you consider the position that many of these workers are in, where
they have paid extortionate fees for their jobs, have had to work as long as three years to
pay off that debt, and have no access to personal identification documents or any control
over terms or conditions of work, then this isn’t decent work – it is akin to modern slavery”(Hodal and Kelly 2016).
Mining phase
To begin with, many consumers may not even be aware of the raw materials that go
into the electronics they use daily. Phones, computers, cameras, batteries, etc. contain amix of at least, coltan/tantalum ore, wolframite/tungsten ore, tin, (3T) and gold. These raw
materials are extracted from the ground, transported to a “trading house”, exported(usually to East Asia) to be refined (purifying an impure metal), smelted (heat extractionof a base metal from ore) or alloyed (combined with other metals to avoid corrosion), andthen sold to electronics manufacturers (circuit boards, chips, cell phones, etc.). At therefinery and smelting stage, the industry is highly concentrated, with less than 10companies processing over 80% of the global supply of tin (Lezhnev 2009).

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It is in the extraction, smelting, and processing of these materials that there is a highrisk for forced labor. For example, field research in the Congo identified 866 cases (23%children) of 7 different forms of slavery (forced labor, forced prostitution, bonded work,
child labor, peonage, sexual slavery, forced marriage) in just 3 mine sites (Free the Slaves
and Open Square 2013).
GoPro’s supply chain meets the criteria for being considered at high risk for slavery
and human trafficking: it involves low-skilled labor, offshore manufacturing, long andcomplex supply chains, and operates in high risk countries (CAR, China, Cambodia, etc.)(Assent 2019a). Forced labor in mining contexts has been extensively studied. Broadly
speaking, it can take place directly at the mineral extraction site, through associatedactivities such as sorting, transporting, catering, or processing; through associatedservices (suppliers, purchasers, creditors); and finally within indirect activities associatedwith the mining community (domestic work, sex work) (Hidron and Koepke 2014). The US
Department of Labor publishes a yearly list on goods produced with forced labor; minerals
have appeared on the reports for at least the past ten years.
Part of the difficulty in identifying and curtailing forced labor in mine sites is that these
are usually located in areas with weak state control and presence. Additionally, mining isoften at the intersection of high conflict areas in which armed groups control part of themineral extraction and exploit workers. In the DRC, at least 12 of the 13 main gold mines
were under armed group control in 2009 (Lezhnev 2009). This makes practices like
deceptive or forceful recruitment, exposure to hazardous chemicals, extended work shifts,
debt bondage, wage withholding, or retention of documentation hard to prosecute andquantify (Hidron and Koepke 2014). Furthermore, low security levels can inhibit
necessary investments for developing other industries, driving even more people intomining. These internal migrants then go into immense debt with their “employers” andremain bonded to them (Free the Slaves and Open Square 2013).
Certain best practices have already been identified for the prevention of forced laborin small-scale mining. They rely on OECD guidelines and ILO indicators for prevention
and risk assessments and promote stakeholder mapping to identify potential allies within
the community. For downstream companies like GoPro, sourcing decisions need to be
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aligned with responsible sourcing practices that are certified by third parties (Verite 2013).
The possibility of improved tracing and tracking of raw materials will be further discussed
when describing the specific campaign elements.
Assembly phase: Malaysia case study
Once the raw materials are transformed into something useable for electronics, theformat in which forced labor operates changes slightly. During the assembly phase,forced labor involves a subagent X in a source community that charges the incumbent areferral fee for sending their profile to a larger city. Agent Y in the city then charges
another fee for preparing the documentation and transportation for a future placement ina job in a different region or country. Agent Z collects a third fee, receives the incumbent
in the destination country and links them to a specific placement and company.
Sometimes, Z is responsible for providing housing and accommodation for the workers(Verite 2014).
Given the slice of the market it represents, Malaysia is an excellent case study of theincidence of forced labor in the ICT industry. Production is concentrated in Free Industrial
Zones and ICT exports account for over $15 billion USD, employing over 1 million
workers. Following the simplified model given above, there are 241 local agencies (typeZ) that act like gatekeepers of the jobs and placements (Verite 2014).
A comprehensive report1 on the state of forced labor in the country found that 32% of
the foreign workforce experiences forced labor. An additional 46% are on the thresholdfor being considered under forced labor as they present at least one indicator of forcedlabor (Verite 2014). The factors that lead to the prevalence of this situation areinterconnected: first, the existence of excessive recruitment fees that are often over one
month’s wage lead to indebtedness of the workers (the majority of them need over one
year to pay it off) which then contributes to excessive overtime to try and pay it off quicker
and increases the dependency of the worker on employment agents. Add to the abovethat companies that hire migrant workers have to pay a levy to the Malaysian state which
is customarily passed down to the workers over their first 12-month period. Furthermore,
1

Quantitative and qualitative data collection and analysis of 501 surveys and interviews with locals andmigrant laborers in 2014.

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their work permits depend on that particular employer so if they were to leave that position
in search of a better option, they would owe the levy to that employer and have to leave
the country as they have lost their sponsor (Verite 2014). As this Malaysian example
shows, the prevalence of forced labor in electronics and the high degree of human rights
violations that it entails merit a more effective way of addressing the problem.
Private brand responses
Over the past ten years, there has been a growing call for novel responses to thisproblem, including an increase in corporate involvement in curtailing this crime. This has
to do with the fact that over 90% of forced labor is imposed by private actors and in 2015
71% of companies had “credible reason to believe modern slavery occurs at some stage
in their supply chain” (Assent 2019a). Public entities are also beginning to include theprivate sector more in their own policy design. For example, the Department of State
considers the pillars of an effective strategy against modern slavery to be prosecution(including tracking suspicious financial flows), protection, prevention, and partnerships(vertical across levels of government and horizontal across stakeholders and key
decisionmakers).
Recent research initiatives funded by USAID have set out to identify elements that leadto successful partnerships in this field. First, a company must be assessed to gage its
level of maturity and awareness to engage in these sorts of initiatives (a full maturity
assessment and spectrum rubric is available online) (Sakulpitakphon and Casey 2019).
For example, if a company sees no problem in their supply chain or isn’t willing to takeany corrective action, a partnership will not be effective. Second, trust-building activities
must be proactively engaged in between partners. Third, partnerships must be designed
and developed in a way that is highly context-specific and allows for mutually agreeable
timeframe, impact measurements, and role definitions (Sakulpitakphon and Casey 2019).
At the end of the day, just the existence of a multi-stakeholder partnership is insufficientto guarantee success of the initiative.
As a result of scandals or moments of crisis, many companies have developed theirown private responses to this phenomenon (Locke 2013). Due diligence is now
considered part of the regular costs of doing business and has strong links to risk
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mitigation at a financial, legal, reputational, and operational level (Assent 2019a). Someof the responses include strict codes of conduct for tier 1 -and increasingly tier 2suppliers, third-party audits, and their own reporting mechanisms that allow them to share
progress with stakeholders. Although these private initiatives have been criticized forbeing designed for protecting the brands and not the workers, our contention is that it isfeasible to do both: you can protect the brand’s reputation and market value precisely bysafeguarding the workers. Other companies have joined organizations or initiatives thatprovide industry-wide codes of conduct.
GoPro
Having described the overall problem of forced labor, its regulatory environment, andhow it operates in the ICT sector, the following section will provide a summary of GoPro’s
operations, our target company for corporate behavior change.
GoPro is a California-based technology company that manufactures and sells ruggedwaterproof cameras, accompanying software, and accessories. Their cameras have an
image sensor, a processor, a wide lens, and microphones for audio-recording (Pandian2017). Originally thought of as a camera for surfers, it has since expanded to all forms ofextreme sports, drones, virtual reality, and cloud-based storage (Reuters Editorial 2019).
Two of the features that allowed it to outpace its competition are the versatility with which
it can be mounted on almost any outdoor gear equipment, and the pairing software thatallows it to be easily used live on an Android or iOS device. Recently, GoPro has faced asteep loss in market value that stemmed in part from overly stocked inventories that it
wasn’t able to sell. As was bluntly stated by an analyst, “consumer hardware simply is ahugely difficult business. Sales depend essentially on the replacement cycle” (Martin2019).
As a publicly-traded company (NASDAQ 2019), we chose them as prime targets forthis initiative to change corporate behavior around labor issues because they have a low
stock value that has been recovering slowly from an all-time low less than six months ago(Martin 2019), are not members of relevant multi-stakeholder initiatives, and have quitevague disclosures regarding their supply chains. GoPro is at a critical decision-making
moment for the company: after several years of astronomic growth, the company’s value
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has dropped and there is increasing skepticism on its ability to deliver innovative products
and services in a way that it would be able to remain competitive (Mac 2017).
Additionally, as advantages for this campaign, almost the entirety of GoPro’s captive
audience consists of a young demographic that is outdoor-inclined, and which has shown
signs of being increasingly concerned with environmental stewardship and human rights.
Disclosures
GoPro meets the California Transparency in Supply Chain Act and has a statement
easily accessible on its website. It purports to have a Corporate Social Responsibility
Code of Conduct that abides to ILO and ETI standards and explicitly prohibits underageand forced labor. Furthermore, the company says that it has an internal compliance teamthat is trained to enforce the Code and that if “does not need third parties to conduct
verifications of product supply chains to evaluate and address risks of human trafficking”(GoPro 2017). We disagree that the company does not need third party verification. As
was previously mentioned, a robust due diligence protocol is a crucial element in risk
management. Currently, GoPro is exposed to operational risks (supply chain disruptions),
reputational risks (decreased brand perception by consumers), financial risks (loss ofinvestors and competitive advantage), and legal risk (increased litigation and penalties)(Assent 2019a)
Regarding the UK Modern Slavery Act, GoPro simply states that upon request it shallprovide a statement regarding its efforts regarding human trafficking. This is direly
insufficient and does not meet the minimum requirements set by the UK Modern Slavery
Act. A careful analysis of the financial statements of the company would be necessary tounderstand if they meet the financial turnaround threshold that would make them subject
to the requirement or if they are just preventively including the statement. Currently,
GoPro seems to have the bare minimum necessary on its website and a reactive stancetowards social compliance. Today’s competitive environment require companies,
particularly those with young audiences, to show a proactive posture regarding social andenvironmental sustainability.

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Relationship with Suppliers
The company states that it carries out announced and unannounced audits on its
suppliers and that violations may lead to termination of the contractual relationship. The
company goes on to say that “GoPro is committed to achieving universal ethical trading
standards throughout all parts of its supply chain, and to ensure that the working
conditions in GoPro’s supply chain are safe” (GoPro 2017). There is no indication of how
this is achieved nor is the Supplier Code of Conduct publicly available.
Human Rights
GoPro sets a minimum age of 15 to work in their supply chain and includes an explicit
prohibition of forced labor and trafficking. Notably, GoPro does include a provision that
requires suppliers to cover all recruitment fees over one month’s wages and to only
withhold documents “to the extent reasonably necessary to complete legitimate andadministrative processing” (GoPro 2017). The company also has statements regarding
excessive overtime (maximum 60-hour work weeks), anti-discrimination, immigration
compliance, and freedom of association.
Minerals Sourcing
GoPro partners with the Conflict Free Sourcing Initiative and applies a policy on all
suppliers and subcontractors. All suppliers are required to inquire on the country of origin
on the materials, determine chain of custody, and follow OECD Due Diligence Guidanceon these matters. Although it generally states that the OECD Guidance should be
followed, there is little evidence on how that is being done. We highly recommend that
GoPro follow OECD guidance for mineral extraction and abide to the previously describedfive-step process (OECD 2016). Furthermore, the supply chain policy should more closelyemulate the model provided to ensure comprehensive inclusion of all relevant matters.
Pressure Points
Having described the magnitude of the problem and the ineffectiveness of relying
solely on legal initiatives, we will now analyze how GoPro can be pressured to implement
best practices in responsible sourcing and transparency. The following section will
describe the three main avenues for pressuring the company to change.

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Publicly-Traded Companies: Stock Price and Reporting Requirements
First of all, there is an increased role of investors that are raising the issue of forcedlabor in shareholder meetings and demanding compliance with new regulation(ShareAction 2016). These active investors seek to implement governance changes
within the company that they hold stock in. To do so, they rely on proxy voting, voicing
concerns at annual shareholder meetings, nominating directors, and voting on board
compensation. They include not only large, institutional investors such as pension funds,
but also impact funds, traditional hedge funds, and individual investors (Larcker andTayan 2015).
For investors, human rights violations can be seen through the lens of decreased
productivity of their assets due to delays in the supply chain, penalties, or legal
investigations. Investors will try to minimize these impacts on future revenue streams andnormal company operations. A hit to the company’s reputation can also significantly affectthe market capitalization of a company. This is especially important for consumer facing
firms that face higher scrutiny and may be targeted by investigative reporting on their
supply chains. The growing field of “impact investing” means that investment decisions
will now be subject to more comprehensive risk assessments that evaluate not only
traditional returns, but also human rights monitoring and allegations of violations. A
company’s sustained economic growth in the stock market now requires disclosure ofhuman rights conditions across its supply chains and it is likely that these requirements
will expand and grow more stringent.
Second, specific jurisdictions have begun to include social assessment data for
publicly traded companies. For example, the EU Parliament introduced reporting
requirements of non-financial information (including human rights and environmental
stewardship) for companies with over 500 employees. A 2015 analysis found that 38 of
the largest 50 economies have some form of government corporate disclosure
requirement on environmental and social issues; for some, the disclosures are optionaland for others they are mandatory. Countries with mandatory disclosures tend to farebetter on ESG ratings than those with voluntary disclosures (Principles for Responsible

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Investment 2016). This could be a strong indication for future regulatory developments toimplement a policy that is, at least nominally, obligatory instead of optional.
Some stock exchanges, such as the Shanghai Stock Exchange or the Hong Kong
Stock Exchange also require listed companies to disclose relevant social sustainability
information (BSD Consulting 2016). By 2015, at least 26 stock exchanges have ESG
reporting guidelines, many of which are voluntary or comply-or-explain (Principles for
Responsible Investment 2016). Many countries have both stock-led disclosure guidelinesand government-led guidelines(Hauser Institute for Civil Society 2014). Recognizing thatvoluntary guidelines are only the first step forward, over 100 institutional investors
petitioned the International Organization of Securities Commission to integrate specificsustainability disclosure requirements in listing rules (Lubber 2015). What is still lagging
is enforcement. No evidence was found of a global company being delisted from a stock
exchange for non-compliance to ESG disclosure guidelines. The future will tell if stock
exchanges begin to do so.
Preempt Regulation and Legal Recourse
Even though current reporting requirements are primarily geared towards large
corporations, small organizations are also subject to legal action and prosecution. Thereis a growing trend for lawsuits from survivors of human trafficking, employees, and evenconsumers to seek legal recourse in different forums, including the US and Europe (Malo2017; Vendenberg and Grono 2016). Even though not all of these lawsuits have resulted
in fines or criminal actions against the defendant firms, their appearance and growing
frequency should serve as a warning sign for non-compliant companies.
There are several companies that have been driven to bankruptcy because of forcedlabor allegations and processes (Brickley 2015). For example, a 2015 case led to a $14
million USD fine on a maritime shipping company from Alabama that forced it to close its
doors(Desai 2015). In the US, by 2008, there were at least three other cases of criminal
prosecution of forced labor in the restaurant business and in American Samoa that have
led to millions of dollars of financial restitution for the victims and sometimes prison for
the executives (Southern Poverty Law Center 2008).

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Private codes of conduct and cooperative agreements with industry peers may also
serve a role in preventing more stringent regulation that would set a higher bar. For
example, Canada has already created a specific civil service role for a government official
to ensure Canadian firms operating abroad follow human rights guidelines (Governmentof Canada 2019).
Stakeholder Pressure
Finally, there is growing consumer awareness and importance allocated tosustainability matters. Customers are considered to be primary stakeholders, or those
without whom the business itself would not exist. A review of 77 manufacturing firms
found that consumer pressure does generate change in sustainable processing
management, including supply decisions (Gualandris and Kalchschmidt 2014). Anotherreached similar conclusions: stakeholder pressure can lead to increased sustainability
awareness within a company, clearly stating goals related to sustainability, andimplementation of specific sustainability practices (Luoma and Meixell 2015).
Several supply chain scandals have rocked the technology and electronics sector in
the past decade. One event that remains salient for many were the suicides of 14
confirmed (18 alleged) Foxconn employees in 2010 (Wow and Reply 2017). As a supplierfor Apple, HP, Dell, GoPro (Foxconn owns 9% of GoPro), etc. with over 1.3 million
employees (Merchant 2017), issues within Foxconn are singularly poised to have effects
for several actors around the world (Bapna 2012). Consumers organized alongside
nonprofits and the media (Barboza 2010; Berg 2018; Hefferman 2013; McLaughlin 2010;
Merchant 2017) to bring on quick responses from the brands involved and Foxconn itself.
For example, the day after the scandal broke, Foxconn required all employees to sign arelease of liability for death; after media outcry, the letter was withdrawn (BBC News
2010). Furthermore, within a week the company had doubled its salaries for most of its
Chinese workers (Barboza 2010). Shortly after, Apple and HP announced strict policies
for worker wellbeing in their supply chains; this was at least partially motivated byrepeated calls to boycott the brands both in China and abroad (McLaughlin 2010). Thisis a short, concrete example of the power of consumer and media pressure related tosupply chain problems on a private actor.
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Window of Opportunity for Corporate Change
The three factors described above are the backbone of the campaign to increase
supply chain transparency and implement more effective policies for eliminating forcedlabor at GoPro. Although these may seem obvious, it is important to frame all messages
in such a way that highlights that it is in the interest of the company to meet theserequirements and be a proactive player in this field.
Many efforts to change company behavior have failed. This set of recommendations
relies on recent research from social science norms and behavioral change to apply it tothis context.
First of all, it is important to consider timing. There has been an uptick in media
coverage on sustainability issues and the average consumer (even more so for themillennial consumer base of GoPro) has become increasingly aware of the potential
negative impacts of the manufacturing products we use day to day. In 2012, 70% ofconsumers surveyed were willing to pay a premium of 5% for a sustainable product andless than 10% were willing to pay more than 25% on the premium (Miremadi, Musso, andWeihe 2012). In more far-reaching surveys in 2014, 50% of millennials answered they
were willing to pay more for companies that show a commitment to positive social andenvironmental impact; by 2015, the number had reached 73% (Nielsen 2015). In otherwords, sustainability is now very much a part of the public agenda (Kingdon 1995) and isgetting attention from media, policymakers, and consumers. In general, there are focusing
events or crises that lead some problems to capture the general attention. The Foxconn
suicides or increased coverage of the Facebook data harvesting scandal may have
served as such events.
There is also an economic argument for timing: brands with commitments tosustainability have grown over 4% at the global level (Nielsen 2015). From a strategic
standpoint, this is a good moment for a campaign to get GoPro to implement changes in
its social sustainability policies: there is a focused topic, consumer awareness, media
coverage, technological readiness, and a strong geopolitical climate (Sin 2018).

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Organizational Change
Findings from social norms change can be applied to organizational change. In thiscontext, there are three elements that are helpful for this campaign to be successful: first,
it is important to not present the problem of modern slavery as rampant or widely spread.
Doing so generates the idea that it is somehow normalized to engage in these behaviors
and decreases the agent’s willingness to change (Cialdini 2007; Cialdini et al. 2006;
Cialdini, Reno, and Kallgren 1990; Schultz et al. 2007). Second, it is important to give
GoPro clear examples of how order can be demonstrably achieved; in other words, it isimportant the campaign include salient examples of how GoPro is actively pursuing thechange beyond simply stating that it will change (Kees Keizer, Lindenberg, and Steg2013). Experiments have shown that explicit behaviors are more effective in guiding
perception than abstract messaging (K. Keizer, Lindenberg, and Steg 2008). Third, forthe campaign towards GoPro to be successful, it is crucial that we understand thatdecisionmakers within the company will need to believe that others are already doing
what we are suggesting that they do, and more importantly, that those relevant others(competitors, consumers, regulators, etc.) expect GoPro to do the same (McAdams
2001). This perception of others’ expectations on our behaviors is a first step in generating
an attitudinal change within the C-Suite that precedes an actual behavioral change.
Persuasion and Diffusion
An effective campaign with GoPro will also depend on a good understanding on how
persuasion operates and how ideas are diffused. For GoPro to be willing to change their
behavior in the long-run, as advocates for change we need to be able to communicate
the idea in such a way that the innovation we are proposing (changes in their social
sustainability policies and systems) will allow them to achieve their desired outcome(increase in market value, positive perception among consumer base, better financial andlegal risk management, etc.). In order to do so, Rogers suggests that proponents forchange focus on the relative advantage of our idea over the previous status quo (current
exposure to risk vs. risk management), compatibility with values (as a young company
GoPro needs to be in tune with its consumer base), low complexity involved (step by step
guide and three prioritized audiences), and high observability of the change (results will21

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be visible to stakeholders) (Rogers 2003). Some of the best practices for doing so include
demonstrating that near peers have already adopted our proposed actions, and that
others will perceive the behavior as being correct (Cialdini 2010). These three pressure
points and brief methodological description will be the “how” of the campaign.
The following section will go over the most comprehensive benchmark available forforced labor in the ICT sector and compare the target company’s efforts with saidbaseline. This will be the “what” of the campaign.
Relevant Benchmark
Know the Chain is one of many benchmarking initiatives that aim to provide guidance
and information on the performance of companies in the technology sector. This report
was chosen over others because of the neutrality of its reporting and the transparency
with which the authors state their methodology.
Forty publicly traded companies were chosen for their market capitalization andworkforce leverage to be measured across seven themes that touch on forced labor. The
key findings of the benchmark are: first, a disconnect between public commitments andpolicies and processes to support them, low scores on the themes that have the highest
impact on workers (worker voice and recruitment), a correlation between market size andcapacity to take action, and notably, the fact that the worst offenders are the suppliers of
the big consumer facing firms(Know the Chain 2018). This last finding is crucial; in otherwords, HP, Apple, etc. fair quite well on these scorecards, and even though they
supposedly extend their efforts well beyond their first tier of suppliers, the suppliers
themselves don’t pass muster when measured against the same bar. The analysis allows
us to identify an “average type” for ICT companies that do provide a supplier code of
conduct, have efforts that cascade down their supply chain, provide training for theiremployees, prohibit fees for recruitment, and audit their suppliers. The “average type”
does not assess forced labor risk, train suppliers, implement responsible recruitment
practices, have effective grievance mechanisms, nor disclose their specific remedy
mechanisms. The description of GoPro’s current disclosures and policies seems to fit this“average type”. The seven themes of the benchmark provide the backbone for therecommendations that will be described in greater detail in the following section.
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Recommended Actions
The campaign for driving corporate behavior change in our target company will target
the main vulnerabilities of the production of electronics in the mining phase and in theassembly phase. The messaging of the campaign will focus on three key audiences andthe risks that each of them most care about. At a very minimum, the initial goal of thecampaign is for GoPro’s leadership team repeatedly and convincingly show commitment
to eliminating slavery from the supply chain. This attitude will then allow the company toadequately design, implement, and communicate the three prioritized initiatives described
below.
Audience 1: Shareholders – financial risk
Investors are a key ally for a corporate change campaign because they have a vested
interest in the performance of the company and have a common goal in minimizing risk.
Even though social ratings do not necessarily present a perfect picture of corporate efforts
to address environmental or social concerns, they are a key tool used by investors thatare looking for accurate information that will allow them to evaluate future performance(Chatterji, Levine, and Toffel 2009).
Institutional investors are especially relevant because they are better equipped able todrive change within a company. For example, rule 14a-8 in the US allows them tonominate people to the company’s board of directors. They can also rely on proxy voting
to push for change. The UK has wider powers for investors (P. Gourevitch 2007).
There is growing scrutiny on the behavior of private actors which may affect stock
prices. Supply chain disruptions have been found to be linked to a 9% drop in stock prices(Ernst & Young 2018). Savvy, forward-looking investors are aware of this and should beapproached to support the primary goal of this line of action (Ruggie 2019). There areseveral active campaigns in place addressing wages and forced labor on the supply
chain. Some of them are pressuring upcoming shareholder meetings to vote on theseissues and publicly commit to a timeline for implementation of improvements (Clean
Clothes Campaign 2019).

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Key goal: Conduct risk assessments
The main objective of this line of the campaign is to get investors to pressure GoPro to
conduct human rights risk assessments that are verified by a third party. In order to meet
the best practices established in this area, key findings (both positive and negative),should be publicly available. In the benchmark previously mentioned, less than half of thecompanies included a forced labor risk assessment (Know the Chain 2018). This stepshould include clear definitions of worker remediation practices in case a violation or noncompliance is found. As is the case with most risk management systems, remediation
processes need to be defined before a problem occurs.
Implementing this policy into standard practice would allow the company to become aleader in the field, perform better than its peers in the industry, and prevent financial riskof potential losses in market value. It is also interconnected with reducing regulatory andreputational risk. As previously noted, senior management needs to be involved
throughout the risk assessment process and be aware of the particularities of the industry
and countries that are part of its supply chains. Fortunately, there are already several
tools available for identifying risks related to slavery. One of them is the Slavery andTrafficking Risk Template which provides a detailed questionnaire and tallies points
depending on the industry and country (Assent 2019b). Use of this template would be an
ideal first step for GoPro. Other tools are available through third party consulting firms or
government agencies: the US Department of Labor has an eight-step, free tool for laborcompliance in supply chains that is designed for companies that want to begin to
implement a more robust management system (U.S. Department of Labor 2019).
Audience 2: regulators – legal risk
The second key audience for the campaign is regulators. Several jurisdictions havealready implemented strict disclosure standards, that even if faulty, serve as a guiding
compass of where regulation is headed. Australia is in the midst of implementing its own
version of the UK Modern Slavery Act and Canada has created a new government officesolely for business and human rights issues. Regulators are a captive audience that isinterested in staying attuned to the needs of their constituents and being able to prove24

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commitment to issues that are central to the public agenda. For the target company, preempting stricter regulation and proactively dissuading future lawsuits is of utmost concern.
Litigation has already begun to affect companies in other industries across the globe
and legal recourse has been sought by former employees, consumers, and investors(Mucha 2019). In the UK, legal action has been sought against corporate directors which
may be held personally liable for forced labor in their supply chains (Taylor 2019). As waspreviously stated, GoPro has a complex, non-centralized supply chain that depends on avariety of information networks and for which there is low visibility of the entire process(Deloitte 2017). Currently, each supplier operates a different information system thathinders accurate tracking and opens up space for fraud. Moreover, strong hierarchicaldynamics in both mine sites and assembly lines make it difficult to accurately monitor
working conditions. Blockchain technology can play a part in improving traceability andgrievance mechanisms.
Key goal: Blockchain technology for transparency
The key goal of this line of action is to implement blockchain technology to meet bestpractices in two themes: transparency in mineral sourcing (as Billiton already does formineral analysis (Ernst & Young 2018)), and worker grievances reporting (RCS Global2017). By implementing this technology, the target company will also be able tocircumvent a recurring critique of the current auditing system which relies on overworked
and often poorly trained individuals to collect data that is frequently found to be inaccurate
and not trustworthy. As Locke found, information gathering through inspection and audits
is not enough to bring about systemic change and improve labor conditions (Locke 2013).
Direct contact with workers will partially solve the conflict of interest problem embeddedin the auditing system and will result in more accurate and complete information on thereal day to day operations of a facility.
A. What is blockchain?
From a technical standpoint, what we frequently refer to as blockchain is really a digitalledger of transactions that is not stored in a single place or system and can never bedeleted. Rather, it is stored across various systems owned by different players that caneach validate the information without an intermediary (McQuinn and Castro 2019). This
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makes it nearly impossible for any single actor to corrupt the ledger. An actor has accessto the ledger only if its digital signature matches that of the consensus algorithm of the
network (Deloitte 2017). The consensus algorithm is at the heart of the verification
process of blockchain (the most common one is proof of work and involves members of
the network solving cryptographic exercises that prove their validity in the system).
Broadly speaking, its goal is to ensure that each player that has access to the ledger isactually authorized to do so (CoinBundle Team 2018). When a transaction takes place, it
is shared within the entire network, validated through the consensus algorithm, andsequentially added to the “block” that gives the system its name.
From a social/political standpoint, by eliminating an intermediary, blockchain allows
groups of individuals to cooperate and reach a consensus even if they do not know eachother or don’t trust each other (McQuinn and Castro 2019). Nobody can alter the record
once it’s made, and all players have the same access, all the time. This element makes
blockchain application to supply chains ideal: parties don’t need to know each other, canhave competing interests or incentives, and yet all rely on the same information system
to record their transactions.
Pros and cons
Distributed Ledger Technologies (blockchain) can allow a company to record any eventthat takes place across complex, multi-actor supply chains. The ledger is not owned byanyone in particular and tampering with the records is nearly impossible. One of the coreadvantages of blockchain is the outstanding level of trust it provides: its records aretransparent, secure, and auditable (Deloitte 2017). Additionally, the ledgers areautomatically updated, and all records are immutable. If we bring together blockchain
technology with Internet of Things (IoT), we will be able to collect and aggregate data ina way that is timely, reliable, and at a much broader scale than ever before.
That being said, blockchain is only just now beginning to be used at this scale andthere are still unanswered questions: what is the best way to collect information that is
fed onto the platform? Note that like any technological system, blockchain can’t fix bad
data input. How can we create an untampered link between the physical and digital world?
At which scale should the token be linked (1 oz of gold? 1 shipment of gold?)? How should
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the data be visualized by the consumer? How can this virtual system be integrated withtraditional paper-based supply chain systems? And crucially, how do we engage all partsof the supply chain with a technology that requires harmonized standards?
Recognizing these latent questions, Deloitte recommends that companies begin bytesting out blockchain in their biggest pain points: where would blockchain be of mostvalue to GoPro? We suggest tagging raw materials from point of sale to smelter as a firststep in minimizing contamination with mine sites that may rely on forced labor. There is a
nascent body of research on creating tokens for products that suffer multiple
transformations across the supply chain and would allow manufacturers to guarantee
particular compositions of their goods (Westerkamp, Victor, and Küpper 2018). RCS has
also designed a potential blockchain system from mine to market that identifies key
information points, and the tokens that would make up each block (ie. bill of lading,certificate of mass and grade, provenance, etc.) (RCS Global 2017). Future
developments could include incorporating smart contracts (contracts that areautomatically enforced when the conditions are met: ie the price for the mineral goes up
if it is above x% purity) into the blockchain system.
From a policy standpoint, there are also several unanswered questions including theneutrality of the technology, the stability and certainty of its use, and international
harmonization, among others (McQuinn and Castro 2019). Last, from a purely technicalstandpoint, blockchain technology still requires incredible amounts of computing powerand energy consumption to operate.
B. Mineral sourcing
As previously described, there are severe risks for forced labor in the mining phase of
GoPro’s supply chain. It is crucial to be able to distinguish the exact mine site from which
the minerals are extracted and to be able to prove the chain of custody from mine, tosmelter, to assembly line. Blockchain enables GoPro to have a continuous source of
information that is shared across its partners, permanently accessible, and effectively
raises alarms when there are code of conduct violations or cases of fraud. This technology
can serve as the bridge between stating a policy or code, and actually having the means
to implement it.
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For companies that source raw materials, there are two main challenges in their chainof custody: origin and production methods (RCS Global 2017). The use of blockchain canallow all transactions from mine, to smelter, to assembly to be recorded in high detail: therecord can include quantity, quality, origin, production method, etc. and becomes easily
shareable with downstream actors and stakeholders. This increased level of transparency
is at the cornerstone of heightened assurance and will allow GoPro to meet the
expectations of both regulators and the general public and media. Current chain ofcustody systems struggle to provide material stewardship (who owns what at any given
point of the chain), and guarantee responsible production (RCS Global 2017). Part ofthese challenges stem from disparate control standards that make aggregating
information nearly impossible and from the multiple transformations that the minerals
undergo along the way which make it more difficult to identify precise points of origin.
By creating tokens for the raw materials that include digital fingerprints, blockchain canallow GoPro to materialize its supply chain policies and to be able to effectively guarantee
visibility from mineral extraction to end product. The company would be able to provematerial stewardship and responsible production, and address problems in near real time
were they to occur. This will lead to a greater cycle of trust with its stakeholders, increase
its flexibility and adaptability by being able to more quickly respond to supply chain risks,and better monitor and control its entire chain. For suppliers at the extraction site, they
will be able to record exactly how much they sold, of what grade, when. They will also beable to ensure quality control and trace counterfeiting or fraud from their mine site to thesmelter. For consumers, blockchain means the possibility of verifying compliance andorigin through a trustworthy system. Since the information is encrypted, GoPro canchoose the level of detail that it provides to any given stakeholder group.
C. Worker voice
As identified by Know the Chain, worker voice is the lowest scoring theme of thebenchmark (Know the Chain 2018). Blockchain allows for anonymized and direct
reporting of grievances in a way that protects workers from retaliation and provides
instant, real-time information for decisionmakers in the field. This technology, if correctly28Camila Gomez Wills – A53265648 – June 2019
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designed and implemented, can signify a momentous leap in monitoring worker
conditions regularly and with credible results.
Today, grievance mechanisms are theoretically in place at most major companies but
seldom used. Anonymity may increase their use and the widespread availability of smart
phones may allow for its reach to go deeper into second tier suppliers. Best practices inthis area are the implementation of the WEST Principles which “aim to maximize theimpact of technology-driven efforts to identify and address the risk of abuse andexploitation of workers in global supply chains” (Worker Engagement Supported byTechnology 2019). These principles were born out the realization that emerging
technologies could serve to fill in gaps in human rights assessments, but that there wasa high risk for their misuse which could end up harming workers more than benefitting
them. At their core, they provide a worker-centric methodology for designing themonitoring tool, a safe environment for its deployment, and effective analysis anddecision-making guided by the data collected. If correctly applied, this technology canincrease the base from which feedback is being drawn and can encourage more honesty
than an in person on-site interview. Another advantage is that data processing can include
complex integrity tests that are able to identify if a responder has been coached. Third,
data gathering becomes less costly and more regular.
That being said, there are several cons that need to be considered and addressed
before deployment. First, it is important that workers continue to trust the technology byrealizing change after the feedback has been provided. Second, worker voice may
become a catchall meaningless term if it is solely interpreted as the technology that
supports the tool and can lead to “expectations of a simple tech fix to complex structuralproblems” (Heuty 2019).
All in all, blockchain can provide a trustworthy grievance mechanism that is an integral
part of any remediation process and can enable transparent end-to-end sourcing
traceability. It will not solve all problems in today’s chain of custody landscape, and it
won’t miraculously lead to effective grievance mechanisms. What it can do is slowly
facilitate the transition towards more robust and transparent systems that detect forcedlabor.
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Audience 3: consumers – reputational risk
Consumers are the third leg of the triad on which this campaign stands. They haveincredible leverage to change corporate behavior, especially when they are organizedaround a central topic such as forced labor. Although maybe forced labor does not seem
like a salient issue in the immediate environment of most western consumers, it isimportant to remember that they are the end user of many of the items that are producedwith forced labor at some point or another. For example, G20 nations import over $354
billion worth of at-risk products per year (Dahir 2018). This can be used as the prime
motivating factor to mobilize consumers around this issue.
Key goal: publish supplier lists & join relevant organizations
The key goal of this action line of the campaign is to get GoPro to publish their global
supply lists and join relevant organizations that have shown a credible commitment toeradicating forced labor from the electronics industry. To meet best practices standards
in this theme, supplier lists must be published up to at least the second tier and should
include names, addresses and contact information of all suppliers, smelters and refiners(Know the Chain 2018). To be a leader in traceability, the company may also choose tocollect information and disclose the percent of migrant workers that participates in eachof its facilities. This allows for a better understanding of the proportion of the workers thatbelong to one of the most vulnerable demographics to forced labor.
For example, members of the Responsible Business Alliance (RBA) have a strict
supplier code of conduct and participate in a Supplemental Validated Audit Process thatis specifically designed to address forced labor (Responsible Business Alliance 2019).
Joining the RBA and endorsing their Responsible Labor Initiative would also mean thatthe company is now bound to provide reimbursement to workers for excessive recruitment
fees.
Although non-profits are not identified as being the key audience of any of thesecampaigns, they play a relevant role in setting the agenda for investors, regulators, andconsumers. Activist organizations are also able to agitate for better standards, stimulate
consumers to take action and pressure government to enforce labor regulations (Elliottand Freeman 2003). Furthermore, if credible, they are able to connect with consumers
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through shared values and transparent information gathering (P. A. Gourevitch, Lake, andStein 2012).
Conclusion
Forced labor is a significant problem in the ICT supply chain from mineral extraction toassembly and companies are beginning to respond. GoPro can manage financial, legal
and reputational risk by implementing best practices in conducting risk assessments,using blockchain technology, joining relevant organizational and publishing supplier lists.
These goals can be met by exerting pressure from three key audiences: investors,
regulators, and consumers.

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References

Assent. 2019a. “Human Trafficking, Slavery, and Your Supply Chain.”https://cdn2.hubspot.net/hubfs/525887/PDFs/eBooks/eBook-Human-TraffickingSlavery-And-Your-Supply-Chain-HR-EB-170901.pdf (May 14, 2019).
———. 2019b. “Slavery & Trafficking Risk Template.” http://www.assentcompliance.com(May 30, 2019).
Bapna, Manish. 2012. “Foxconn Scandal Offers Supply Chain Lessons.” Forbes.
https://www.forbes.com/sites/manishbapna/2012/02/29/foxconn-scandal-offerssupply-chain-lessons-2/ (May 30, 2019).
Barboza, David. 2010. “After Foxconn Suicides, Scrutiny for Chinese Plants.” The New
York Times. https://www.nytimes.com/2010/06/07/business/global/07suicide.html(May 30, 2019).
Barzani,
Nooh.
2016.
“GoProRevolutionizes
Military
Operations.”
http://peacockplume.fr/opinion/gopro-revolutionizes-military-operations (May 30,2019).
BBC

News. 2010. “Foxconn Suicides: ‘Workers
https://www.bbc.com/news/10182824 (May 30, 2019).

Feel

Quite

Lonely.’”Berg, Scott W. 2018. “The Human Cost of an IPhone.” Washington Post.
https://www.washingtonpost.com/outlook/the-human-cost-of-aniphone/2018/03/02/5d76555e-0b7e-11e8-8890-372e2047c935_story.html (May30, 2019).
Brickley, Peg. 2015. “Accused of Labor Trafficking, Oil-Rig Repairer Files for Bankruptcy.”
Wall Street Journal. https://www.wsj.com/articles/signal-international-files-forbankruptcy-1436787503 (April 30, 2019).
BSD

Consulting. 2016. “Sustainability Reporting Standards in China.”
http://www.bsdconsulting.com/insights/article/sustainability-reporting-standardsin-china (April 30, 2019).

Chatterji, Aaron K., David I. Levine, and Michael W. Toffel. 2009. “How Well Do Social
Ratings Actually Measure Corporate Social Responsibility?” Journal of Economics& Management Strategy 18(1): 125–69.
Cialdini, Robert B. et al. 2006. “Managing Social Norms for Persuasive Impact.” Social
Influence 1(1): 3–15.
———. 2007. “Descriptive Social Norms as Underappreciated Sources of Social Control.”Psychometrika 72(2): 263–68.
32

Camila Gomez Wills – A53265648 – June 2019
Global Corporate Accountability: Issues of Governance, Responsibility and NGOs
Corporate Behavior Change – Forced labor in tech supply chains – GoPro
COPY RIGHT 2019 NO QUOTATION WITHOUT ATTRIBUTION!!!!!!!!!

———. 2010. Influence: The Psychology of Persuasion. Rev. ed., [Nachdr.]. New York,
NY: Collins.
Cialdini, Robert B., Raymond R. Reno, and Carl A. Kallgren. 1990. “A Focus Theory ofNormative Conduct: Recycling the Concept of Norms to Reduce Littering in Public
Places.” Journal of Personality and Social Psychology 58(6): 1015–26.
Clean

Clothes Campaign. 2019. “Take Action https://turnaroundhm.org/take-action/ (May 1, 2019).

Turn

H&M

Around.”CoinBundle
Team.
2018.
“Consensus
Algorithms.”
CoinBundle.
https://medium.com/coinbundle/consensus-algorithms-dfa4f355259d (June 1,2019).
Dahir, Abdi Latif. 2018. “Africa Is Again the World’s Epicenter of Modern-Day Slavery.”
Quartz Africa. https://qz.com/africa/1333946/global-slavery-index-africa-has-thehighest-rate-of-modern-day-slavery-in-the-world/ (May 1, 2019).
Deloitte. 2017. “Using Blockchain & Internet-of-Things in Supply Chain Traceability.” : 24.
Department of State. 2018. “2018 Trafficking in Persons Report.” : 486.
Desai, Radha. 2015. “Landmark Human Trafficking Case Ends with Bankruptcy for Signal
International,
Inc.”
Human
RightsFirst.
https://www.humanrightsfirst.org/blog/landmark-human-trafficking-case-endsbankruptcy-signal-international-inc (June 5, 2019).
Elliott, Kimberly Ann, and Richard B. Freeman. 2003. Can Labor Standards Improveunder Globalization? Washington, DC: Institute for International Economics.
Ernst & Young. 2015. “The UK Modern Slavery Act 2015.” : 8.
———. 2018. Towards Transparent Supply Chains.
Free the Slaves, and Open Square. 2013. “Enslavement at South Kivu Mining Sites.”
https://www.freetheslaves.net/wp-content/uploads/2015/03/Congos-MiningSlaves-web-130622.pdf (May 30, 2019).
Global Forum on Responsible Business Conduct. 2017. “Contributing to the Sustainable
Development
Goals
through
Responsible
Business
Conduct.”
https://mneguidelines.oecd.org/global-forum/2017-GFRBC-Session-NoteContributing-to-SDGs.pdf (May 29, 2019).
Global Initiative Against Transnational Organized Crime. 2019. The Human Conveyor
Belt Broken. https://globalinitiative.net/the-human-conveyor-belt-broken-2/ (May 8,2019).

33

Camila Gomez Wills – A53265648 – June 2019
Global Corporate Accountability: Issues of Governance, Responsibility and NGOs
Corporate Behavior Change – Forced labor in tech supply chains – GoPro
COPY RIGHT 2019 NO QUOTATION WITHOUT ATTRIBUTION!!!!!!!!!

GlobalSlavery
Index.
2016.
“Findings.”
GlobalSlavery
Index.
https://www.globalslaveryindex.org/2018/findings/highlights/ (April 30, 2019).

GoPro.
2017.
“California
SupplyChain
Transparancy
https://gopro.com/legal/casupplychaindisclosure (May 1, 2019).

Statement.”

Gourevitch, Peter. 2007. “What Do Corporations Owe Citizens?” Society 44(5): 12–18.
Gourevitch, Peter Alexis, David A. Lake, and Janice Gross Stein, eds. 2012. The
Credibility of Transnational NGOs: When Virtue Is Not Enough. Cambridge ; New
York: Cambridge University Press.
Government of Canada, Global Affairs Canada. 2019. “Responsible Business Conduct
Abroad.”GAC.
https://www.international.gc.ca/trade-agreements-accordscommerciaux/topics-domaines/other-autre/faq.aspx?lang=eng (April 30, 2019).
Gualandris, Jury, and Matteo Kalchschmidt. 2014. “Customer Pressure andInnovativeness: Their Role in Sustainable Supply Chain Management.” Journal of
Purchasing and Supply Management 20(2): 92–103.
HauserInstitutefor
Civil
Society.
2014.
https://iri.hks.harvard.edu/csr (June 5, 2019).

“Global

CSR

Disclosure.”Hefferman, Margaret. 2013. “What Happened after the Foxconn Suicides.”https://www.cbsnews.com/news/what-happened-after-the-foxconn-suicides/ (May30, 2019).
Heuty, Antoine. 2019. “Is ‘worker Voice’ Technology More than Just Kabuki Theatre in
the Struggle for Labour Rights?” Business & Human Rights Resource Centre.
https://www.business-humanrights.org/en/is-worker-voice-technology-more-thanjust-kabuki-theatre-in-the-struggle-for-labour-rights (May 1, 2019).
Hidron, Clara, and Ronald Koepke. 2014. “Addressing Forced Labor in Artisanal andSmall Scale Mining (ASM)” eds. Carien Duisterwinkel et al. : 118.
Hodal, Kate, and Annie Kelly. 2016. “Malaysia: Forced Labour Casts Dark Shadow over
Electronics Industry.” The Guardian. https://www.theguardian.com/globaldevelopment/2016/nov/21/malaysia-forced-labour-casts-dark-shadow-overelectronics-industry (April 30, 2019).
ILO. 2014a. “Protocol P029 - Protocol of 2014 to the Forced Labour Convention, 1930.”
https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_IL
O_CODE:P029 (April 30, 2019).
———. 2014b. “Recommendation R203 - Forced Labour (Supplementary Measures)
Recommendation,
2014
(No.
203).”
34

Camila Gomez Wills – A53265648 – June 2019
Global Corporate Accountability: Issues of Governance, Responsibility and NGOs
Corporate Behavior Change – Forced labor in tech supply chains – GoPro
COPY RIGHT 2019 NO QUOTATION WITHOUT ATTRIBUTION!!!!!!!!!

https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO:12100:P12
100_ILO_CODE:R203:NO (April 30, 2019).
Jones, Jackie, and John Winterdyk. 2017. Introduction: Human Trafficking: Challenges
and Opportunities for the 21st Century. Rochester, NY: Social Science Research
Network. SSRN Scholarly Paper. https://papers.ssrn.com/abstract=3081022(November 8, 2018).
Keizer, K., S. Lindenberg, and L. Steg. 2008. “The Spreading of Disorder.” Science322(5908): 1681–85.
Keizer, Kees, Siegwart Lindenberg, and Linda Steg. 2013. “The Importance ofDemonstratively Restoring Order” ed. Luís A. Nunes Amaral. PLoS ONE 8(6):e65137.
Kingdon, John W. 1995. Agendas, Alternatives, and Public Policies. New York: Longman.
Know the Chain. 2018. Information and Communications Technology (ICT) Findings
Report.
https://knowthechain.org/wp-content/plugins/ktcbenchmark/app/public/images/benchmark_reports/KTC-ICT-May2018-Final.pdf(April 26, 2019).
Larcker, David F., and Brian Tayan. 2015. “Investors and Activism.” Stanford Graduate
SchoolofBusiness.
https://www.gsb.stanford.edu/facultyresearch/publications/investors-activism (June 5, 2019).
Lezhnev, Sasha. 2009. “From Mine to Mobile Phone: The Conflict Minerals Supply
Chain.” The Enough Project. https://enoughproject.org/reports/mine-mobile-phone(May 30, 2019).
Locke, Richard M. 2013. The Promise and Limits of Private Power: Promoting Labor
Standards in a Global Economy. Cambridge ; New York: Cambridge University
Press.
Lubber, Mindy. 2015. “How Can We Create a More Sustainable Financial System?” World
Economic Forum. https://www.weforum.org/agenda/2015/09/how-can-we-createa-more-sustainable-financial-system/ (June 5, 2019).
Luoma, Patrice, and Mary J Meixell. 2015. “Stakeholder Pressure in Sustainable Supply
Chain Management: A Systematic Review.” International Journal of PhysicalDistribution & Logistics Management 45(1/2): 69–89.
Mac,

Ryan.
2017.
“The
Sky
Is
FallingFor
GoPro.”
Forbes.
https://www.forbes.com/sites/ryanmac/2017/02/02/behind-recall-gopro-karmadrone/ (May 30, 2019).

35

Camila Gomez Wills – A53265648 – June 2019
Global Corporate Accountability: Issues of Governance, Responsibility and NGOs
Corporate Behavior Change – Forced labor in tech supply chains – GoPro
COPY RIGHT 2019 NO QUOTATION WITHOUT ATTRIBUTION!!!!!!!!!

Malo, Sebastien. 2017. “Retail Giant Costco Wins Dismissal of Prawn Lawsuit over Thai
ForcedLabor.”
Reuters.
https://www.reuters.com/article/us-usa-lawsuitcostco/retail-giant-costco-wins-dismissal-of-prawn-lawsuit-over-thai-forced-laboridUSKBN1592JC (April 30, 2019).
Martin, Vince. 2019. “GoPro Is Making Progress, But GPRO Stock Still Doesn’t Look
Cheap.”
NASDAQ.com.
https://investorplace.com/2019/04/gopro-makingprogress-gpro-stock-cheap/ (May 1, 2019).
McAdams, Richard H. 2001. “Conventions and Norms (Philosophical Aspects).” InInternational Encyclopedia of the Social and Behavioral Sciences, Rochester, NY:
Social Science Research Network. https://papers.ssrn.com/abstract=255444(April 25, 2019).
McCubbins, Mathew D., and Thomas Schwartz. 1984. “Congressional OversightOverlooked: Police Patrols versus Fire Alarms.” American Journal of Political
Science 28(1): 165.
McLaughlin, Kathleen. 2010. “China Suicides: Is Apple Headed for a Consumer
Backlash?” Public Radio International. https://www.pri.org/stories/2010-0528/china-suicides-apple-headed-consumer-backlash (May 30, 2019).
McQuinn, Alan, and Daniel Castro. 2019. A Policymaker’s Guide to Blockchain.
Information
Technology
andInnovation
Foundation.
https://itif.org/publications/2019/04/30/policymakers-guide-blockchain (June 1,2019).
Merchant, Brian. 2017. “Life and Death in Apple’s Forbidden City.” The Observer.
https://www.theguardian.com/technology/2017/jun/18/foxconn-life-deathforbidden-city-longhua-suicide-apple-iphone-brian-merchant-one-device-extract(May 30, 2019).
Miremadi, Mehdi, Christopher Musso, and Ulrich Weihe. 2012. “How Much Will
Consumers Pay to Go Green?” McKinsey. https://www.mckinsey.com/businessfunctions/sustainability/our-insights/how-much-will-consumers-pay-to-go-green(May 31, 2019).
Mucha, Rachel. 2019. “Beware of Poorly Vetted ‘Sustainability Certifications’: Brazil’s
Palm Oil Industry.” http://www.rioonwatch.org/?p=52631 (May 1, 2019).
NASDAQ. 2019. “GoPro, Inc. Class A Common Stock (GPRO).” NASDAQ.com.
https://www.nasdaq.com/symbol/gpro (May 1, 2019).
Nielsen. 2015. “Consumer-Goods’ Brands That Demonstrate Commitment to
Sustainability Outperform Those That Don’t.” http://www.nielsen.com/us/en/press-

36

Camila Gomez Wills – A53265648 – June 2019
Global Corporate Accountability: Issues of Governance, Responsibility and NGOs
Corporate Behavior Change – Forced labor in tech supply chains – GoPro
COPY RIGHT 2019 NO QUOTATION WITHOUT ATTRIBUTION!!!!!!!!!

room/2015/consumer-goods-brands-that-demonstrate-commitment-tosustainability-outperform (May 31, 2019).
OECD. 2016. “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals
fromConflict-Affected
andHigh-Risk
Areas.”
http://www.oecd.org/corporate/mne/mining.htm (April 30, 2019).
———. 2017. “Measuring Distance to the SDG Targets.” http://www.oecd.org/sdd/OECDMeasuring-Distance-to-SDG-Targets.pdf (May 29, 2019).
OECD Emerging Markets Sector. 2018. “Policy Note on Sustainability: Better Businessfor2030.”
https://www.oecd.org/dev/SDG2017_Better_Business_2030_Putting_SDGs_Cor
e_Web.pdf (May 29, 2019).
Pandian, Ananth. 2017. “What Is a GoPro, and What Can These Action Cameras Do?”
Digital Trends. https://www.digitaltrends.com/photography/what-is-a-gopro-actioncamera/ (May 1, 2019).
Principles for Responsible Investment. 2016. “How Effective Are Corporate Disclosure
Regulations?” PRI. https://www.unpri.org/sustainable-markets/how-effective-arecorporate-disclosure-regulations/211.article (June 5, 2019).
RCS Global. 2017. “Blockchain for Traceability in Minerals and Metals Supply Chains.”
https://www.rcsglobal.com/wp-content/uploads/2018/09/ICMM-Blockchain-forTraceability-in-Minerals-and-Metal-Supply-Chains.pdf (April 30, 2019).
Responsible Business Alliance. 2019. “Supplemental Validated Audit Process (SVAP) On
Forced Labor.” http://www.responsiblebusiness.org/vap/svap-on-forced-labor/(April 30, 2019).
Reuters
Editorial.
2019.
“GoProCompany
Profile.”U.S.
https://www.reuters.com/finance/stocks/company-profile/GPRO.O (May 1, 2019).
Rogers, Everett M. 2003. Diffusion of Innovations. New York: Free Press.
http://books.google.com/books?id=4wW5AAAAIAAJ (April 18, 2019).
Ruggie, John. 2019. “ESG Investing: Coming into Its Own—and Not a Moment Too
Soon.” Presented at the Responsible Investment Association of Canada Annual
Conference
KeynoteAddress,
Montreal.
https://www.businesshumanrights.org/sites/default/files/documents/Montreal%20RIA_John%20Ruggie%20speech.pdf (May 1, 2019).
Sakulpitakphon, Patchareeboon, and Anna Casey. 2019. “Five Learnings on Engaging
the Private Sector to Combat Trafficking in Persons.” USAID Asia Learning andAction Brief 2: 22.
37

Camila Gomez Wills – A53265648 – June 2019
Global Corporate Accountability: Issues of Governance, Responsibility and NGOs
Corporate Behavior Change – Forced labor in tech supply chains – GoPro
COPY RIGHT 2019 NO QUOTATION WITHOUT ATTRIBUTION!!!!!!!!!

Schultz, P. Wesley et al. 2007. “The Constructive, Destructive, and Reconstructive Powerof Social Norms.” Psychological Science 18(5): 429–34.
ShareAction. 2016. “Forced Labour: What Investors Need
https://shareaction.org/wp-content/uploads/2016/06/ForcedLabourInvestorBriefing.pdf (April 30, 2019).

toKnow.”

Shift, and Business and Sustainable Development Commission. 2016. “Business, Human
Rights, and the Sustainable Development Goals: Forging a Coherent Strategy.”
https://s3.amazonaws.com/aws-bsdc/BSDC-Biz-HumanRights-SDGs.pdf(May29, 2019).
Sin, Ben. 2018. “GoPro Pulls Production Of U.S.-Bound Hardware Out Of China.” Forbes.
https://www.forbes.com/sites/bensin/2018/12/11/gopro-pulls-production-of-u-sproducts-out-of-china/ (May 1, 2019).
Southern Poverty Law Center. 2008. “Civil Litigation on Behalf of Victims of Human
Trafficking.”
Southern
Poverty
Law
Center.
https://www.splcenter.org/20081130/civil-litigation-behalf-victims-humantrafficking (June 5, 2019).
Special Action Programme to Combat Forced Labour. 2012. ILO Indicators of Forced
Labor. Geneva: International Labor Organization.
State of California. 2014. “The California Transparency in Supply Chains Act.” State ofCalifornia - Department of Justice - Office of the Attorney General.
https://oag.ca.gov/SB657 (March 12, 2019).
Taylor, Lin. 2019. “UK Slave Bosses May Be ‘personally Liable’ for Exploitation ofWorkers.”
Reuters.
https://www.reuters.com/article/us-britain-slavery-rulingidUSKCN1RK25J (May 1, 2019).
U.S. Department of Labor. 2019. “Comply Chain: Business Tools for Labor Compliancein Global Supply Chains.” https://www.dol.gov/general/apps/ilab-comply-chain(May 30, 2019).
Vendenberg, Martina, and Nick Grono. 2016. “Modern-Day Slaves Are Suing theTraffickers.”
https://edition.cnn.com/2016/01/08/opinions/modern-day-slavessuing-traffickers/ (April 30, 2019).
Verite. 2013. “Risks of Forced Labor in Illegal Gold Mining: What Should Companies Do?”
Verité.
https://www.verite.org/risks-of-forced-labor-in-illegal-gold-mining-whatshould-companies-do/ (May 30, 2019).
———. 2014. “Forced Labor in the Production of Electronic Goods in Malaysia.”
https://www.verite.org/wp38

Camila Gomez Wills – A53265648 – June 2019
Global Corporate Accountability: Issues of Governance, Responsibility and NGOs
Corporate Behavior Change – Forced labor in tech supply chains – GoPro
COPY RIGHT 2019 NO QUOTATION WITHOUT ATTRIBUTION!!!!!!!!!

content/uploads/2016/11/VeriteForcedLaborMalaysianElectronics2014.pdf (April
30, 2019).
Westerkamp, Martin, Friedhelm Victor, and Axel Küpper. 2018. “Blockchain-Based
Supply Chain Traceability: Token Recipes Model Manufacturing Processes.”arXiv:1810.09843 [cs]. http://arxiv.org/abs/1810.09843 (June 1, 2019).
Worker Engagement Supported by Technology.
https://westprinciples.org/about/ (April 30, 2019).

2019.

“West

Principles.”Wow, James: 22 05 2018 at 3:09 pm, and even with all those regulations stuff like thisstill happens Incredible Reply. 2017. “Blame the Supplier: A Roundup of Recent
SupplyChain
Scandals.”
Spend
Matters.
http://spendmatters.com/2017/07/21/blame-supplier-roundup-recent-supplychain-scandals/ (May 30, 2019).

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