EVENTS

Building Credible Forced Labor Import Prohibitions: Lessons from the U.S. Experience

Governments facing forced labor-related trade pressure — including USTR Section 301 investigations — are increasingly expected to enact and enforce credible forced labor trade enforcement frameworks, often without clear direction or support. Better Trade Collective and the Tendai Initiative are convening a practical webinar on June 25 from 8-9:15am ET drawing on firsthand experience designing, implementing, and enforcing U.S. forced labor enforcement systems, featuring:

• Marcia Eugenio, Better Trade Collective, formerly U.S. Department of Labor (moderator)
• Jen Jahnke, Tendai Initiative, formerly U.S. Customs and Border Protection
• Josh Kagan, Kelley Drye & Warren LLP, formerly U.S. Trade Representative
• Annick Febrey, Better Trade Collective, formerly U.S Department of Labor
• Michael Pennant-Jones, T-Evolve Limited

Panelists will explore what governments should consider when designing or strengthening their own enforcement approaches, including how to build credible frameworks, avoid unintended economic and labor impacts, engage effectively with trading partners and industry, and ensure that worker protection and remediation remain central to implementation. Drawing on both successes and persistent challenges from the U.S. experience to highlight what comprehensive, worker-centered approaches require in practice.

About the Panelists:

Marcia Eugenio has more than three decades of experience advancing international labor standards, forced labor enforcement, and supply chain due diligence. As Director of the Office of Child Labor, Forced Labor, and Human Trafficking in the U.S. Department of Labor’s Bureau of International Labor Affairs, she led global initiatives across more than 100 countries, helped oversee up to $900 million in strategic investments, and provided expert guidance to the Forced Labor Enforcement Task Force on UFLPA implementation. Marcia has worked with governments, companies, and stakeholders to strengthen forced labor prevention and responsible sourcing frameworks.

Josh Kagan is an international trade attorney with Kelley Drye & Warren LLP, based in Washington, DC.  His helps clients comply with and navigate forced labor trade laws, including the UFLPA and Section 307 of the Tariff Act of 1930.  Josh works with clients to: conduct enhanced supply chain due diligence to identify suppliers at risk of UFLPA detention; clear shipments detained under the UFLPA and assess the likelihood that future shipments would be released based on traceability analysis; and develop and file Section 307 petitions with US CBP identifying the presence of ILO forced labor indicators in a particular facility.  Prior to joining Kelley Drye, Josh led the USTR Labor Office as the Assistant USTR for Labor Affairs and served in a leadership role in USDOL ILAB as Deputy Director of the Office of Trade and Labor Affairs.

Jen Jahnke specializes in designing and implementing Forced Labor Import Prohibitions (FLIP) . She worked at CBP Forced Labor Division and as a government contractor supporting FLIP implementation. Jen advises private sector clients on preventing, identifying and remedying forced labor in global supply chains. Jen is the Founder and Executive Director of The Tendai Initiative.

Annick Febrey has more than 20 years of experience advancing forced labor prevention and supply chain due diligence, with deep expertise in U.S. trade enforcement and international labor standards. As Deputy Director at the U.S. Department of Labor’s Bureau of International Labor Affairs, she led the Department’s implementation of the Uyghur Forced Labor Prevention Act and contributed to the development of CBP’s Withhold Release Order and Finding Modifications Guide. Annick has worked with governments, NGOs, and industry to strengthen forced labor enforcement frameworks and responsible sourcing practices.

Michael Pennant-Jones has over 25 years’ experience advising private sector clients on complex global business and human rights issues. Michael led the remediation strategy that supported the forced labor WRO trade modification for Sime Darby Plantations. Michael has a strong record of working with brands and suppliers to take global frameworks, such as the ILO forced labor indicators, and apply them to their Human Rights Due Diligence (HRDD) programs.