Mary Mikhaeel, an associate in Covington's Business and Human Rights Practice, was quoted in an International Bar Association article, "The Evolution of Modern Slavery Legislation," which examines the rapidly evolving global regulatory landscape surrounding forced labor, modern slavery, and supply chain due diligence requirements.
The article explores legislative developments in the UK, EU, and U.S., as well as the challenges multinational companies face in complying with an increasing number of forced labor and human rights frameworks. Mary discussed the complexities created by differing regulatory approaches across jurisdictions, including differences between U.S., EU, and other emerging legal regimes. She also highlighted the importance of supply chain transparency, risk assessments, and building compliance programs that can adapt to varying requirements while remaining grounded in broader human rights due diligence principles.
The article reported that companies are increasingly grappling with overlapping obligations under regimes such as the Uyghur Forced Labor Prevention Act (UFLPA), EU forced labor measures, and emerging national laws addressing supply chain transparency and human rights due diligence.
"There is some distinction between the UFLPA and EU regulations, and if you have two prominent forced-labour regulations with different scopes, how can companies build one system around that?" Mary said. "And now it's not two, now it's maybe an undefined number so how do companies deal with this?"
Mary also emphasized the importance of supply chain transparency and risk-based compliance programs as foundational elements of an effective response to modern slavery and forced labor risks.
"You have to understand your supply chain, do a related risk assessment and identify, categorise and rank risks," Mary said.
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