Overview

Green and Spiegel, LLC, is pleased to announce the creation of the International Supply Chain Initiative. In partnership with Laurel Bellows, founding principal of The Bellows Law Group, P.C., the International Supply Chain Initiative provides guidance to multinational corporations with regard to anti-human trafficking and supply chain management.

It is well known that human rights issues within supply chains have increasingly drawn the ire of legislators and members of the public alike, with disastrous incidents (such as the 2013 Rana Plaza collapse in Bangladesh) as well as increasing press coverage of related practices, serving to highlight ongoing problems within virtually all areas of the global marketplace. Driven by the demand for cheap goods, services and labor, companies have often looked for ways to increase production and decrease employment costs. This has led to problematic supply chain management practices, with multinational organizations turning to less desirable offshore labor forces that engage in such practices.

Businesses which proactively work to adopt anti-trafficking and forced labor measures stand to benefit tremendously by “future proofing” their operations against regulations, as well as mitigating potential current and future liability and damages.

Through our two-track offering, the International Supply Chain Initiative can not only assist your company in the creation of policy and training materials, but can also provide liability assessment and mitigation services with respect to anti-human trafficking initiatives. Your company will be provided with the ability to fulfill its legal obligations regarding anti-trafficking and supply chain management, while simultaneously demonstrating to consumers and global communities its standing as a responsible corporate citizen.

Policy and Training: 

  • Craft a detailed policy explicitly prohibiting the use of trafficked labor and child labor within Company operations.
  • Require first-tier suppliers a similar policy (as a condition of supplier contract), with terms designed to eliminate unethical or illegal labor practices, as well as specifically protect the Company.
  • Provide training to employees in key positions to identify and prevent human trafficking, child labor, and similar unethical practices.

Completion of the Policy and Training Module will result in a compliance certification from the International Supply Chain Initiative.

Transparency:

  • Comply with relevant state, federal, and international reporting requirements regarding labor policies and related workforce and supplier integrity efforts.
  • Publicly release relevant reports and other details regarding these efforts.

Risk Assessment:

  • Engage in the continued and ongoing evaluation of company and first-tier supplier operations to ensure the integrity of the global workforce and identify any existing (or potential) violations of policies regarding trafficking and child labor.
  • Retaining the services of a credible and independent third-party auditor in order to review operations, detail any existing or potential violations, and practices.
  • Identify areas of particular risk for violations in the future.
  • Actively monitor supply chain operations.

Mitigation and Remediation:

  • Structure operations in a manner which minimizes direct exposure (supplier indemnification, prevention policies, credible internal auditing).
  • Create mechanisms to address the core issue (where and how the labor violation occurred), as well as providing appropriate compensation or other victim services.
  • Identifying and addressing core internal and supplier issues which contributed to the occurrence of the violation.
  • Provide remedial training to Company employees and relevant first-tier supplier personnel.

Completion of the Assessment and Remediation Track will result in a compliance certification from the International Supply Chain Initiative.

People

Laurel Bellows

Laurel Bellows

Business Lawyer

Laurel Bellows, founding principal of The Bellows Law Group, P.C. is an internationally recognized business lawyer, whose law firm offers strategic business counseling and litigation services to entrepreneurs and companies of all sizes, including large corporations. She has extensive experience counseling senior executives and corporations in the United States and globally on employment matters, including employment and severance agreements, executive compensation, workplace disputes, and business conduct standards. Laurel counsel’s corporations relating to anti-trafficking, risk assessment, supply chain and recruiting policies, and cybersecurity. Her firm litigates zealously and efficiently on behalf of employers.

Laurel is the former President of the nearly 400,000-member American Bar Association and former President of the Chicago Bar Association. Laurel is Past President of the International Women’s Forum Chicago, and is a Global Board member of the International Women’s Forum. She served on Minister Gordon Brown’s Global Citizenship Commission to update the United Nations Universal Declaration of Human Rights.

Jonathan Grode

Jonathan Grode

Immigration Lawyer

Jonathan Grode directs the Immigration Law practice for the United States offices (Philadelphia, PA, Providence, RI, and Vail, CO) of Green and Spiegel LLC. Jonathan has worked continuously in the U.S. business immigration law field since 1999 and has amassed considerable experience obtaining non-immigrant and immigrant visas for new company start-ups, professional workers, artists and entertainers, athletes, physicians, and scientific researchers. In addition, Jonathan has significant experience dealing with Department of Labor and Department of Homeland Security enforcement actions as well as with EB-5 Investor filings.

Jonathan has been at the forefront of the progressive effort for anti-human trafficking employment regulations through his leadership on the American Bar Association Labor and Employment Law Section Human Trafficking Task Force, and most recently as the ABA Labor and Employment Law Section’s Liaison to the Commission on Immigration. He has been a panelist and moderator on immigration law topics for numerous organizations, including the American Bar Association, Greater Philadelphia Chamber of Commerce, French Chamber of Commerce and Industry, and the American Immigration Lawyers Association, Philadelphia Chapter. He also writes regularly for industry publications and academic journals, and is an Adjunct Faculty Member at Temple University’s Beasley School of Law where he teaches Business Immigration Law, Advising Global Corporations, and Law Practice Management.

David Spaulding

David Spaulding

Compliance and Regulatory Practice Counsel

David Spaulding is the Compliance and Regulatory Practice Counsel at Green and Spiegel’s Philadelphia office. Prior to joining Green and Spiegel, David served twenty-three years as an immigration officer. Experience ranging from border, airport, and seaport inspections, through benefits examination and adjudication, and investigations gives him insights into immigration enforcement not common among private practice immigration attorneys. From 2006 through 2019, David was an investigator with the Office of Fraud Detection and National Security (FDNS) within USCIS and he supervised FDNS operations in Pennsylvania, Delaware, and West Virginia from 2012 through 2019. As a USCIS supervisor and manager, he directly oversaw USCIS’ site visit programs and fraud investigations and has direct experience with USCIS policy and program management. David was the National Fraud Branch Chief during a long-term detail in 2014, during which he oversaw the crafting and initial implementation of the Site Visit Protocols on which the present Site Visit Program is grafted.

Green and Spiegel seeks to help companies navigate complex and dynamic compliance and regulatory environments and David is ideally positioned to help clients apply forward-thinking and honed investment in meeting those obligations. David’s approach is proactive, working with healthcare, manufacturing, hospitality, and information technology companies to assess compliance, improve system integrity, and set up the kinds of policies and procedures that make government inspections simple, affordable, and minimally intrusive.

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