Modern slavery risks permeate the entire social media value chain, from the sourcing of raw materials such as cobalt.26 Against worker exploitation in data labeling27 overseas data centers,28 And then to the digital platform itself.
The international community recognizes the need to protect human rights in the digital age.29 In 2011, the United Nations Guiding Principles on Business and Human Rights (UNGPs) established a “corporate responsibility to respect” and require businesses to (a) avoid causing or contributing to adverse human rights impacts through their activities; and seeks to address such issues. (b) Strive to prevent or reduce adverse human rights impacts that are directly related to our business, products or services through our business relationships, even if we do not ourselves contribute to those impacts.30 As a result, social media companies are obligated to respond to any damages they cause or contribute to, including damages caused by third parties using their platforms.31 Despite this, little is being done to protect social media users from the risks of modern slavery. The current Modern Slavery Act (MSA) in the UK and Australia requires certain companies to report on the risks of modern slavery in their operations and supply chains.32 However, social media companies are not required to report how they tackle modern slavery on their digital platforms.33 Additionally, some companies that have significant influence in the UK and Australia but have no operations in either country do not need to report. Gaps in the application of the MSA allow social media companies to avoid liability for potential violations related to their platforms.
2023 Walk Free Evaluation Statement34 Published by 10 companies under the UK and Australian MSA. These companies cover 10 social media platforms and 2 electronic stores that distribute social media applications.35 Our assessment found that social media companies do not adequately report on modern slavery within their direct operations and supply chains.36 In our most recent statement (as at 28 February 2023), no business complied with all minimum requirements under Australian regulations.37 or UK MSA.38 Supply chains are opaque. While all the companies had some form of modern slavery policy, only his four companies had policies that extended beyond the first tier of the supply chain. Five companies reported carrying out risk assessment and risk management activities, and these same companies also identified risks of modern slavery, but only one identified potential incidents of modern slavery. He only had two companies. This suggests that these companies should do more to proactively identify risks and remediate forced labor when it occurs.
Figure 1: Addressing modern slavery risks on social media platforms
In addition to the MSA requirements, we also considered statements to understand how well companies address modern slavery risks on their social media platforms. Currently, companies are not required to report on these aspects under their MSA, but we wanted to understand whether companies are effectively addressing known risks beyond compliance.
Half of the statements evaluated had specific disclosures related to modern slavery risks on their platforms. Four companies reported that they have modern slavery policies in place related to social media, including policies against apps, content, and conduct that promote human trafficking, child exploitation, and human exploitation. Additionally, only three of his companies reported activities to detect modern slavery on social media, including the use of image matching techniques and mechanisms that allow users to report slavery-related content.
One company reported making information about support services available to all users, but no other preventive measures were reported. Some companies evaluated reported having policies in place against sexually explicit advertising, but there are known risks and concerns that key management companies may be paying too much for promotion or advertising. However, no companies reported that they were evaluating advertisements depicting modern slavery. There are no reports of modern slavery considerations being included in product design or development, and such efforts are important to address risks before they impact vulnerable end users.
Concerningly, only four companies reported remediation strategies for incidents identified on social media, including cooperation with law enforcement and removal of content, user accounts, and apps. It was. Without further action to investigate and eliminate the source of the risk, content removal simply replaces the risk. Multi-stakeholder collaboration is essential to raising industry standards, increasing transparency and effectively eliminating the risks of modern slavery.39 The three companies recognized reports on social media about their participation in industry collaborations to combat modern slavery.Techniques to combat human trafficking40 and the Technology Coalition,41 For example, we represent industry efforts to combat online human trafficking and child sexual exploitation. More targeted efforts are needed to combat modern slavery in all its forms on social media.
Our assessment of statements published by social media companies shows that companies need to do more to understand how modern slavery manifests online and to address the risks of modern slavery that occur. It has been shown that there is. Currently, social media companies with more than 4.5 billion active users worldwide have great influence all over the world.42 There is an urgent need to stop criminals from operating with impunity and stop modern slavery from spreading online.
Recommendations
For government
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Introduce mandatory human rights due diligence laws similar to France’s duty of vigilance laws.43 It requires companies and other organizations to conduct due diligence to proactively identify and remediate forced labor risks, and covers the entire value chain, including end users.
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Strengthen existing MSAs to encourage social media companies (including those with significant user bases in Australia and the UK, regardless of their annual revenue) to report on how they are tackling modern slavery on their platforms; Require detailed guidance to be published to support implementation.44
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Work with other governments to strengthen governance and accountability frameworks for social media companies. Such a framework should take into account the ever-evolving nature of digital technologies and ensure sufficient geographic coverage.
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All legislative and policy responses to regulate online digital spaces must consider potential unintended consequences, such as lifting protections for sex workers, and address the risks of human rights and modern slavery on social media. Include people with lived experience in discussions about how to deal with this.45
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Ensure that all legislative and policy responses are research-based and developed in consultation with survivors, social media experts, and anti-slavery stakeholders.
For social media companies
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Develop and publish clear and specific policies to detect, prevent and redress modern slavery risks across value chains, including social media platforms.
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Conduct due diligence, including implementing and reporting measures to systematically detect modern slavery on our platform. These efforts include dedicated monitoring for indicators of modern slavery, as well as enabling users to report modern slavery and local support providers to safely and securely contact users at risk. It should also include a mechanism for46
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on our platform by removing violating content and accounts, providing transparent reporting on content moderation, cooperating with law enforcement (while protecting privacy and human rights), and referring those affected to support services. Provide effective remediation for incidents that occur.
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We actively prevent modern slavery risks on social media by checking job advertisements and social media business pages, increasing risk awareness and promoting anti-slavery hotlines.47 We provide identity verification options for all users and require mandatory modern slavery training for product and third-party software developers.
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Participate in industry collaboration to raise industry standards for preventing, identifying and mitigating the risks of modern slavery. These collaborations must include consultation with survivors and anti-slavery experts.