"It's important to use this new contract language both with new suppliers and also for renewals," Markus said.

Compliance should also take the lead on any mandatory forced labour reporting requirements and disclosure statements, according to Funk.

"One of the problems we've seen over the past ten years is that this issue has been handled by human resources, or corporate social responsibility — which meant that lawyers had either no or very limited involvement in draft disclosures, and that's a huge problem," Markus said. "You want compliance to handle this issue because the last thing a company wants is a letter from an anti-trafficking advocacy group saying, 'We've reviewed your disclosure and see they are noncompliant, and we are going to start a campaign against you.'"

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