Nairobi, Kenya, June 2022. A “Fake Alert” is posted on a fictitious Kenya government job offer on the internet. When unemployment soared during the COVID-19 pandemic scam recruitment Facebook accounts, groups and pages with more than 184,000 followers targeted people in Kenya, exposing them to vulnerability of modern slavery. Photo Credit: Tony KARUMBA / AFP. Getty Images.
Global Slavery Index / Spotlight

Anti-social: Modern slavery on social media

While social media has enabled unprecedented levels of global connectivity and delivered many socio-economic benefits,1 greater connectivity has also brought new risks, with consequences that transcend the digital world. There is mounting evidence social media is used to facilitate modern slavery,2 with perpetrators able to simultaneously target multiple people in different geographic locations, access their personal information, and exploit vulnerabilities while shielded by online anonymity.3

At the same time, rapid technological advancements have outpaced the development of regulatory frameworks, resulting in a lack of effective governance and accountability that enables modern slavery risks to flourish online.

The facilitation of forced commercial sexual exploitation (FCSE) of adults and children using social media is well documented.4 Social media users may be recruited through deceptive job advertisements or targeted outreach using chat features, typically under the guise of building a relationship.5 In June 2021, for example, 11 people were arrested for trafficking women and girls from Bangladesh to India for sexual exploitation after luring them via TikTok with the promise of work.6 Following recruitment, social media may be used to track victims’ locations, control their movements, and to record, advertise, and distribute FCSE material.7 In 2023, shareholders launched litigation against Meta, arguing that the company’s leadership and board failed to protect shareholder interests by purportedly turning “a blind eye” to widespread evidence of sex trafficking and child sexual exploitation on Facebook and Instagram.8 Some measures intended to curb FCSE online have also exacerbated risks. For example, legislation introduced in the United States in 2017 to combat sex trafficking online reportedly increased the vulnerability of sex workers.9 In effect, the law placed greater pressure on platforms to censor users, thereby removing safer spaces for sex workers to communicate and reduce their risk of harm, while increasing their risk of violence and poverty.10

Less is known about how social media impacts forced labour;11 however, increasing use of social media to search for employment and the growing perception of it as a reliable source of information has created new opportunities for exploitation.12 Fraudulent recruiters and traffickers may target potential victims via social media business pages,13 recruitment advertisements,14 and direct outreach on social media platforms.15 Key word searches of some popular video-sharing platforms reveal the presence of unverified accounts posing as government-approved recruitment agencies which poses significant risks. Traffickers may also use social media to lure victims onto end-to-end encrypted platforms, such as WhatsApp,16 where oversight by law enforcement for prevention and evidence collection is both legally and technically difficult.17

Harrowing accounts of trafficking for labour exploitation and domestic servitude via social media have emerged in recent years. In 2021, leaked Facebook documents revealed that Instagram and Facebook were used to recruit migrant workers from low-income countries via deceptive job advertisements and traffic them to the Gulf Cooperation Council countries for domestic servitude and forced sex work.18 This followed a 2019 investigation which found that migrant domestic workers employed under the kafala system in Kuwait and Saudi Arabia were bought and sold via Instagram and other applications listed by Google Play and the Apple App Store.19 Instagram’s algorithm reportedly promoted hashtags used to advertise domestic workers on the platform.20

While it is clear that social media exacerbates modern slavery risks, it can also provide an avenue for vulnerable users and survivors to share their experiences and access support.21 In 2021, for example, a Kenyan woman who was exploited while working as a cleaner in Saudi Arabia reported receiving assistance from an international organisation after posting about her situation on Facebook.22 She was also recruited via Facebook, and claimed that the platform saw her into and out of the situation.23 Migrant domestic workers experiencing abuse and mistreatment in the Gulf have also used Facebook and TikTok to share their experiences, ask for information, and raise awareness.24 While this has reportedly helped domestic workers connect with other workers on the platforms, without the necessary safeguards in place, domestic workers can be exposed to further harms such as re-trafficking by exploitative recruiters who are also active on the platforms, employer retaliation, and even deportation.25

Modern slavery risks permeate the entire social media value chain — from sourcing raw materials, such as cobalt,26 to the exploitation of workers in data labelling27 and overseas data centres,28 and into the digital platforms themselves.

The international community has recognised the need to safeguard human rights in the digital era.29 In 2011, the United Nations Guiding Principles on Business and Human Rights (UNGPs) established the “corporate responsibility to respect,” which requires businesses, to (a) avoid causing or contributing to adverse human rights impacts through their own activities and to address such impacts when they occur, and (b) seek to prevent or mitigate adverse human rights impacts that are directly linked to their operations, products, or services by their business relationships, even if they themselves have not contributed to those impacts.30 As a result, social media companies have a duty to respond to any harm they cause or contributed to, including harm caused by a third party using their platform.31 Despite this, little is being done to protect social media users from modern slavery risks. Under current Modern Slavery Acts (MSAs) in the UK and Australia, certain companies are required to report on modern slavery risks in their operations and supply chains,32 however there is no requirement for social media companies to report on how they are addressing modern slavery on their digital platforms.33 Further, several companies with significant reach in the UK and Australia, but with no operations in either country, are not required to report. Gaps in the application of MSAs allow social media companies to evade responsibility for potential violations linked to their platforms.

In 2023, Walk Free assessed statements34 published under UK and Australian MSAs by 10 companies. These companies cover 10 social media platforms and two e-stores distributing social media applications.35 Our assessment found that social media companies are not doing enough to report on modern slavery within their direct operations or supply chains.36 In their most recent statements (current as of 28 February 2023), no company complied with all minimum requirements under the Australian37 or UK MSAs.38 Supply chains are opaque: while all companies had some form of modern slavery policy, only four had a policy that extended beyond the first tier of their supply chain. Although five companies reported conducting risk assessments and risk management activities, with these same companies also identifying modern slavery risks, only two disclosed potential incidents of modern slavery. This suggests these companies should be doing more to actively identify risks and remediate incidents of forced labour where they occur.

Figure 1: Addressing modern slavery risk on social media platforms

Beyond requirements in the MSAs, we also reviewed the statements to understand how well companies are engaging with modern slavery risks on their social media platforms. While companies are not presently required to report on these aspects under the MSAs, we wanted to understand if companies were going beyond compliance to effectively engage with known risks.

Half of the statements assessed made specific disclosures relating to modern slavery risks on their platforms. Four companies reported having modern slavery policies relating to social media, including policies against apps, content, and behaviours that facilitate human trafficking, child exploitation, and human exploitation. Further, only three companies reported activities to detect modern slavery on social media, including through use of image matching technology and mechanisms allowing users to report slavery-related content.

One company reported making information on support services available for all users, however no other prevention measures were reported. Some of the companies assessed reported having policies against sexually explicit advertisements, however none reported assessing advertisements for indicators of modern slavery, despite known risks and the significant control companies have over paid promotions and advertisements. None reported including modern slavery considerations into product design and development, where such efforts are crucial to addressing risks before impacting vulnerable end users.

Concerningly, only four companies reported remediation strategies for incidents identified on social media: measures included cooperation with law enforcement and removal of content, user accounts, or apps. Without further action to investigate and remove the source of risk, content removal merely displaces risk. Multi-stakeholder cooperation is vital to lifting industry standards, fostering greater transparency, and ensuring that modern slavery risks are effectively removed.39 Three companies assessed reported participation in industry collaborations seeking to combat modern slavery on social media. Tech Against Trafficking40 and the Tech Coalition,41 for example, represent industry initiatives to combat human trafficking and child sexual exploitation online. More targeted efforts must be made to combat all forms of modern slavery that manifest on social media.

An assessment of statements released by social media companies shows that they must take more action to understand how modern slavery manifests online and to address the modern slavery risks that occur. Social media companies, with more than 4.5 billion users now active across the globe, have enormous influence worldwide.42 There is an urgent need for them to stop perpetrators from operating with impunity and to prevent modern slavery from flourishing online.

Recommendations

For governments

  1. Introduce mandatory human rights due diligence laws, similar to the French Duty of Vigilance law,43 which require businesses and other organisations to conduct due diligence to proactively identify and remediate forced labour risks and which cover the entire value chain including end-users.

  2. Strengthen existing MSAs to require social media companies to report on how they are addressing modern slavery on their platforms (including companies with a significant user base in Australia and/or the UK, regardless of annual revenue) and to issue detailed guidance to support implementation.44

  3. Cooperate with other governments to strengthen governance and accountability frameworks for social media companies. Such frameworks must consider the constantly evolving nature of digital technologies and ensure sufficient geographic coverage.

  4. Consider potential unintended consequences, such as the removal of safeguards for sex workers, in all legislative and policy responses to regulate online digital spaces, and include those with lived experience in any consultations regarding addressing human rights and modern slavery risks on social media.45

  5. Ensure all legislative and policy responses are informed by research and developed in consultation with survivors, social media experts, and anti-slavery stakeholders.

For social media companies

  1. Develop and publish clear and specific policies to detect, prevent, and remedy modern slavery risks across the entire value chain, including their social media platforms.

  2. Conduct due diligence, including implementing and reporting on measures to systematically detect modern slavery on their platforms. These efforts should include dedicated monitoring for indicators of modern slavery, as well as mechanisms for users to report modern slavery and for local support providers to reach at-risk users safely and securely.46

  3. Provide effective remediation for incidents that occur on their platforms through removing violating content and accounts, providing transparent reporting on content moderation, cooperating with law enforcement (while safeguarding privacy and human rights), and referring affected persons to support services.

  4. Actively prevent modern slavery risks on social media through verifying recruitment advertisements and social media business pages, targeting awareness-raising on risks, promoting anti-slavery hotlines,47 providing identity verification options for all users, and requiring compulsory modern slavery training for product and third-party software developers.

  5. Engage in industry collaborations to lift industry standards for preventing, identifying, and mitigating modern slavery risks. These collaborations must involve consultation with survivors and anti-slavery experts.

Endnotes

1See for example: Report of the Secretary-General 2020, Roadmap for Digital Cooperation, United Nations. Available from: https://www.un.org/en/content/digital-cooperation-roadmap/assets/pdf/Roadmap_for_Digital_Cooperation_EN.pdf. [20 May 2022]; Sarangi, A, Amor, W, Co, ELF, Javed, S, Usmani, S & Rashid, A 2022, Social Media Reinvented: ‘Can Social Media Help Tackle the Post-Pandemic Mental Health Onslaught?’, Cureus, vol. 14, no. 1. DOI:10.7759/cureus.21070. [25 August 2022]; Department of Economic and Social Affairs 2021, Leveraging digital technologies for social inclusion, United Nations. Available from: https://www.un.org/development/desa/dspd/wp-content/uploads/sites/22/2021/02/PB_92-1.pdf. [25 August 2022]; Page-Tan, C 2021, ‘Bonding, bridging, and linking social capital and social media use: How hyperlocal social media platforms serve as a conduit to access and activate bridging and linking ties in a time of crisis’, Natural Hazards, vol. 105, no. 2, pp. 2219-2240. DOI:DOI:10.1007/s11069-020-04397-8. [25 August 2022]; Rosen, AO, Holmes, AL, Balluerka, N, Hidalgo, MD, Gorostiaga, A, et al. 2022, ‘Is Social Media a New Type of Social Support? Social Media Use in Spain during the COVID-19 Pandemic: A Mixed Methods Study’, International Journal of Environmental Research and Public Health, vol. 19, no. 7, p. 3952. DOI:10.3390/ijerph19073952. [25 August 2022]; Lin, Y & Kant, S 2021, ‘Using Social Media for Citizen Participation: Contexts, Empowerment, and Inclusion’, Sustainability, vol. 13, no. 12, p. 6635. DOI:10.3390/su13126635. [25 August 2022].
2United Nations Office on Drugs and Crime 2020, Global Report on Trafficking in Persons, United Nations, p. 15. Available from: https://www.unodc.org/documents/data-and-analysis/tip/2021/GLOTiP_2020_15jan_web.pdf. [9 February 2022]; Brown, E 2022, ‘Dozens Of Teenage Girls Trafficked In UK Modern Slavery First’, Unilad, 10 February. Available from: https://www.unilad.co.uk/news/dozens-of-teenage-girls-trafficked-in-uk-modern-slavery-first-20220210. [23 February 2022]; 2016, ‘Babies for sale: 101 East investigates Malaysia’s underground baby trade’, Al Jazeera. Available from: https://interactive.aljazeera.com/aje/2016/malaysia-babies-for-sale-101-east/index.html. [23 February 2022]; 2016, ‘Babies for sale: The investigation’, Al Jazeera. Available from: https://interactive.aljazeera.com/aje/2016/malaysia-babies-for-sale-101-east/investigation.html. [23 February 2022]; Ward, O 2018, ‘Babies for sale: ASEAN’s insidious underground baby market’, ASEAN Today, 19 October. Available from: https://www.aseantoday.com/2018/10/babies-for-sale-aseans-insidious-underground-baby-market/. [23 February 2022]; 2021, ‘Melaka cops bust Instagram baby-selling ring, nab 14 suspects’, The Vibes, 20 December. Available from: https://www.thevibes.com/articles/news/50115/melaka-cops-bust-instagram-baby-selling-ring-nab-14-suspects. [23 February 2022]; Polaris 2018, On-Ramps, Intersections and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking. Available from: https://polarisproject.org/wp-content/uploads/2018/08/A-Roadmap-for-Systems-and-Industries-to-Prevent-and-Disrupt-Human-Trafficking-Social-Media.pdf. [9 February 2022]; Nicola, AD, Baratto, G & Martini, E 2017, Surf and Sound: The Role of the Internet in People Smuggling and Human Trafficking, eCrime Research Reports. Available from: https://www.academia.edu/34645738/Surf_and_Sound_The_role_of_the_Internet_in_people_smuggling_and_human_trafficking?pop_sutd=false. [24 February 2022]; Office of the Special Representative and Co-ordinator for Combating Trafficking in Human Beings & Tech Against Trafficking 2020, Leveraging innovation to fight trafficking in human beings: A comprehensive analysis of technology tools, Organization for Security and Co-operation in Europe. Available from: https://www.osce.org/files/f/documents/9/6/455206_1.pdf. [24 February 2022]; Pinnell, O & Kelly, J 2019, ‘Slave markets found on Instagram and other apps’, BBC News, 31 October. Available from: https://www.bbc.com/news/technology-50228549. [9 February 2022]; Scheck, J, Purnell, N & Horwitz, J 2021, ‘Facebook Employees Flag Drug Cartels and Human Traffickers. The Company’s Response is Weak, Documents Show’, The Wall Street Journal, 16 September. Available from: https://www.wsj.com/articles/facebook-drug-cartels-human-traffickers-response-is-weak-documents-11631812953. [9 February 2022]; Nortajuddin, A 2020, ‘ASEAN’s Black Market Babies’, The ASEAN Post, 2 March. Available from: https://theaseanpost.com/article/aseans-black-market-babies. [11 July 2022]; Save the Children 2021, ‘Save the Children fears trafficking and abuse amid social media pleas to adopt India’s covid orphans’, 7 May. Available from: https://www.savethechildren.net/news/save-children-fears-trafficking-and-abuse-amid-social-media-pleas-adopt-india%E2%80%99s-covid-orphans. [25 July 2022]; Taskin, B 2021, ‘Beware of traffickers: Social media posts seeking adoption for ‘Covid orphans’ raise concern’, The Print, 15 May. Available from: https://theprint.in/india/beware-of-traffickers-social-media-posts-seeking-adoption-for-covid-orphans-raise-concern/658695/. [25 July 2022]; Gebeily, M 2022, ‘Iraq’s Yazidis want Big Tech held to account over Islamic State crimes’, Reuters, 17 February. Available from: https://www.reuters.com/article/socialmedia-yazidis-rights-idUSL8N2UC1U8. [4 August 2022].
3United Nations Office on Drugs and Crime 2020, Global Report on Trafficking in Persons, United Nations, pp. 15 & 19. Available from: https://www.unodc.org/documents/data-and-analysis/tip/2021/GLOTiP_2020_15jan_web.pdf. [9 February 2022]; Working Group on Trafficking in Persons 2021, Successful strategies for addressing the use of technology to facilitate trafficking in persons and to prevent and investigate trafficking in persons: Background paper prepared by the Secretariat CTOC/COP/WG.4/2021/2, United Nations Conference of the Parties to the United Nations Convention against Transnational Organized Crime. Available from: https://www.unodc.org/documents/treaties/WG_TiP_2021/CTOC_COP_WG.4_2021_2/ctoc_cop_wg.4_2021_2_E.pdf. [24 February 2022].
4Polaris 2018, On-Ramps, Intersections and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking. Available from: https://polarisproject.org/wp-content/uploads/2018/08/A-Roadmap-for-Systems-and-Industries-to-Prevent-and-Disrupt-Human-Trafficking-Social-Media.pdf. [9 February 2022]; Mekong Club 2019, How Technology Fuels Trafficking and Exploitation in Asia and the Pacific, p. 8. Available from: https://respect.international/wp-content/uploads/2019/06/How-Technology-Fuels-Trafficking-and-Exploitation-in-Asia-and-the-Pacific.pdf. [11 July 2022]; Lane, L, Gray, A & Rodolph, A 2021, 2021 Federal Human Trafficking Report, Human Trafficking Institute, p. 39. Available from: https://traffickinginstitute.org/wp-content/uploads/2022/06/2021-Federal-Human-Trafficking-Report-Web.pdf. [11 July 2022]; Thorn 2015, A report on the use of technology to recruit, groom and sell domestic minor sex trafficking victims. Available from: https://www.thorn.org/wp-content/uploads/2015/02/Survivor_Survey_r5.pdf. [11 July 2022]; Thorn 2018, Survivor Insights: The Role of Technology in Domestic Minor Sex Trafficking. Available from: https://www.thorn.org/wp-content/uploads/2019/12/Thorn_Survivor_Insights_090519.pdf. [11 July 2022]; International Justice Mission 2020, Online Sexual Exploitation of Children in the Philippines: Analysis and Recommendations for Governments, Industry, and Civil Society. Available from: https://ijmstoragelive.blob.core.windows.net/ijmna/documents/studies/Final-Public-Full-Report-5_20_2020.pdf. [11 July 2022]; United Nations Office on Drugs and Crime 2020, Global Report on Trafficking in Persons 2020, pp. 119-128. Available from: https://www.unodc.org/documents/data-and-analysis/tip/2021/GLOTiP_2020_15jan_web.pdf. [11 July 2022]; R v ML & Ors (2019) Cr S 63/19. Available from: https://sherloc.unodc.org/cld/en/case-law-doc/cybercrimecrimetype/syc/2020/r_v_ml_ors_cr_s_6319.html. [5 April 2023]; 2021, ‘Bangladesh trafficking gang lured girls using TikTok: Police’, Al Jazeera, 9 June. Available from: https://www.aljazeera.com/news/2021/6/9/bangladesh-trafficking-gang-lured-girls-using-tiktok-police. [11 July 2022]; Gebeily, M 2022, ‘Iraq’s Yazidis want Big Tech held to account over Islamic State crimes’, Reuters, 17 February. Available from: https://www.reuters.com/article/socialmedia-yazidis-rights-idUSL8N2UC1U8. [4 August 2022].
5United Nations Office on Drugs and Crime 2020, Global Report on Trafficking in Persons 2020, pp. 119-128. Available from: https://www.unodc.org/documents/data-and-analysis/tip/2021/GLOTiP_2020_15jan_web.pdf. [11 July 2022]; Polaris 2018, On-Ramps, Intersections and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking, p. 19. Available from: https://polarisproject.org/wp-content/uploads/2018/08/A-Roadmap-for-Systems-and-Industries-to-Prevent-and-Disrupt-Human-Trafficking-Social-Media.pdf. [9 February 2022]; Lane, L, Gray, A & Rodolph, A 2021, 2021 Federal Human Trafficking Report, Human Trafficking Institute, p. 39. Available from: https://traffickinginstitute.org/wp-content/uploads/2022/06/2021-Federal-Human-Trafficking-Report-Web.pdf. [11 July 2022]; Moloney, A 2020, ‘Colombia makes arrests in sex trafficking plot that lured women to China’, Thomson Reuters Foundation, 8 September. Available from: https://news.trust.org/item/20200908210357-adkqg/?utm_campaign=trafficking&utm_medium=newsletter&utm_source=mainListing&utm_content=link3&utm_contentItemId=20200908210357-adkqg. [9 September 2022].
6Janjua, H 2022, ‘Trapped via TikTok: Bangladeshi Girls Trafficked To India Are Facing Brutal Violence’, Pulitzer Center, 2 June. Available from: https://pulitzercenter.org/stories/trapped-tiktok-bangladeshi-girls-trafficked-india-are-facing-brutal-violence. [19 July 2022]; 2021, ‘Bangladesh trafficking gang lured girls using TikTok: Police’, Al Jazeera, 9 June. Available from: https://www.aljazeera.com/news/2021/6/9/bangladesh-trafficking-gang-lured-girls-using-tiktok-police. [11 July 2022].
7United Nations Office on Drugs and Crime 2020, Global Report on Trafficking in Persons 2020, pp. 119-128. Available from: https://www.unodc.org/documents/data-and-analysis/tip/2021/GLOTiP_2020_15jan_web.pdf. [11 July 2022]; Polaris 2018, On-Ramps, Intersections and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking. Available from: https://polarisproject.org/wp-content/uploads/2018/08/A-Roadmap-for-Systems-and-Industries-to-Prevent-and-Disrupt-Human-Trafficking-Social-Media.pdf. [9 February 2022]; Mekong Club 2019, How Technology Fuels Trafficking and Exploitation in Asia and the Pacific, p. 8. Available from: https://respect.international/wp-content/uploads/2019/06/How-Technology-Fuels-Trafficking-and-Exploitation-in-Asia-and-the-Pacific.pdf. [11 July 2022]; Thorn 2015, A report on the use of technology to recruit, groom and sell domestic minor sex trafficking victims. Available from: https://www.thorn.org/wp-content/uploads/2015/02/Survivor_Survey_r5.pdf. [11 July 2022]; International Justice Mission 2020, Online Sexual Exploitation of Children in the Philippines: Analysis and Recommendations for Governments, Industry, and Civil Society. Available from: https://ijmstoragelive.blob.core.windows.net/ijmna/documents/studies/Final-Public-Full-Report-5_20_2020.pdf. [11 July 2022].
8Leonard, M 2023, ‘Zuckerberg, Meta Leaders Face Human Trafficking Allegations (3)’, Bloomberg Law, 22 March. Available from: https://news.bloomberglaw.com/esg/zuckerberg-meta-leaders-face-trafficking-exploitation-claims. [4 April 2023]; Stempel, J 2023, ‘Zuckerberg, Meta are sued for failing to address sex trafficking, child exploitation,’ Reuters. Available from: https://www.reuters.com/legal/zuckerberg-meta-are-sued-failing-address-sex-trafficking-child-exploitation-2023-03-21/. [4 April 2023].
9Government Accountability Office 2021, Sex Trafficking: Online Platforms and Federal Prosecutions, Government of the United States. Available from: https://www.gao.gov/assets/gao-21-385.pdf. [11 July 2022]; Blunt, D & Wolf, A 2020, Erased: The Impact of FOSTA-SESTA, Hacking//Hustling, pp. 9-12. Available from: https://hackinghustling.org/wp-content/uploads/2020/01/HackingHustling-Erased.pdf. [11 July 2022]; Allow States and Victims to Fight Online Sex Trafficking Act, 2017 (No. 115-164) (United States); Stop Enabling Sex Traffickers Act, 2017 (United States)
10As above.
11Volodko, A, Cockbain, E & Kleinberg, B 2020, ‘‘Spotting the signs’ of trafficking recruitment online: exploring the characteristics of advertisements targeted at migrant job-seekers’, Trends in Organized Crime, vol. 23, pp. 7-35. Available from: https://link.springer.com/article/10.1007/s12117-019-09376-5. [22 February 2022]; Latonero, M, Wex, B & Dank, M 2015, Technology and Labor Trafficking in a Network Society: General Overview, Emerging Innovations, and Philippines Case Study, USC Centre on Communication Leadership & Policy. Available from: https://cpb-us-e1.wpmucdn.com/sites.usc.edu/dist/2/672/files/2015/10/USC_Tech-and-Labor-Trafficking_Feb2015.pdf. [22 February 2022]; Anti-Slavery International 2018, The Role of the Internet in Trafficking for Labour Exploitation. Available from: https://www.antislavery.org/wp-content/uploads/2018/07/FINE-Tune-project-internet_and_labour_trafficking.pdf. [24 February 2022]; Fundamental Principles and Rights at Work Branch 2021, Use of digital technology in the recruitment of migrant workers, International Labour Organization. Available from: https://www.ilo.org/wcmsp5/groups/public/—ed_norm/—ipec/documents/publication/wcms_831814.pdf?mc_cid=0a1a2ad396&mc_eid=daa26391d2. [4 March 2022].
12Latonero, M, Wex, B & Dank, M 2015, Technology and Labor Trafficking in a Network Society: General Overview, Emerging Innovations, and Philippines Case Study, USC Centre on Communication Leadership & Policy, p. 26. Available from: https://cpb-us-e1.wpmucdn.com/sites.usc.edu/dist/2/672/files/2015/10/USC_Tech-and-Labor-Trafficking_Feb2015.pdf. [22 February 2022]; Fundamental Principles and Rights at Work Branch 2021, Use of digital technology in the recruitment of migrant workers, International Labour Organization. Available from: https://www.ilo.org/wcmsp5/groups/public/—ed_norm/—ipec/documents/publication/wcms_831814.pdf?mc_cid=0a1a2ad396&mc_eid=daa26391d2. [4 March 2022].
13Polaris 2018, On-Ramps, Intersections and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking. Available from: https://polarisproject.org/wp-content/uploads/2018/08/A-Roadmap-for-Systems-and-Industries-to-Prevent-and-Disrupt-Human-Trafficking-Social-Media.pdf. [9 February 2022]; Nicola, AD, Baratto, G & Martini, E 2017, Surf and Sound: The Role of the Internet in People Smuggling and Human Trafficking, eCrime Research Reports, p. 45. Available from: https://www.academia.edu/34645738/Surf_and_Sound_The_role_of_the_Internet_in_people_smuggling_and_human_trafficking?pop_sutd=false. [24 February 2022].
14Anti-Slavery International 2018, The Role of the Internet in Trafficking for Labour Exploitation. Available from: https://www.antislavery.org/wp-content/uploads/2018/07/FINE-Tune-project-internet_and_labour_trafficking.pdf. [24 February 2022].
15The Five Corridors Project 2021, Nepal to Kuwait and Qatar: Fair recruitment in review, FairSquare Projects, p. 19. Available from: https://fivecorridorsproject.org/uploads/C2_3_Nepal_Kuwait_Qatar-report.pdf. [10 November 2021]; Anti-Slavery International 2018, The Role of the Internet in Trafficking for Labour Exploitation. Available from: https://www.antislavery.org/wp-content/uploads/2018/07/FINE-Tune-project-internet_and_labour_trafficking.pdf. [24 February 2022]; Latonero, M, Wex, B & Dank, M 2015, Technology and Labor Trafficking in a Network Society: General Overview, Emerging Innovations, and Philippines Case Study, USC Centre on Communication Leadership & Policy, p. 266. Available from: https://cpb-us-e1.wpmucdn.com/sites.usc.edu/dist/2/672/files/2015/10/USC_Tech-and-Labor-Trafficking_Feb2015.pdf. [22 February 2022].
16Polaris 2018, On-Ramps, Intersections and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking, p. 22. Available from: https://polarisproject.org/wp-content/uploads/2018/08/A-Roadmap-for-Systems-and-Industries-to-Prevent-and-Disrupt-Human-Trafficking-Social-Media.pdf. [9 February 2022].
17Uren, T 2022, The future of assistance to law enforcement in an end-to-end encrypted world, Australian Strategic Policy Institute, pp. 1-22. Available from: https://ad-aspi.s3.ap-southeast-2.amazonaws.com/2022-02/End-to-end%20encrypted%20world.pdf?VersionId=EedYmkFPZOe3lAU1uem_sThKGPu9prVs. [19 July 2022].
18Scheck, J, Purnell, N & Horwitz, J 2021, ‘Facebook Employees Flag Drug Cartels and Human Traffickers. The Company’s Response is Weak, Documents Show’, The Wall Street Journal, 16 September. Available from: https://www.wsj.com/articles/facebook-drug-cartels-human-traffickers-response-is-weak-documents-11631812953. [9 February 2022].
19Pinnell, O & Kelly, J 2019, ‘Slave markets found on Instagram and other apps’, BBC News, 31 October. Available from: https://www.bbc.com/news/technology-50228549. [9 February 2022].
20As above.
21Polaris 2018, On-Ramps, Intersections and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking. Available from: https://polarisproject.org/wp-content/uploads/2018/08/A-Roadmap-for-Systems-and-Industries-to-Prevent-and-Disrupt-Human-Trafficking-Social-Media.pdf. [9 February 2022]; Latonero, M, Wex, B & Dank, M 2015, Technology and Labor Trafficking in a Network Society: General Overview, Emerging Innovations, and Philippines Case Study, USC Centre on Communication Leadership & Policy, p. 11. Available from: https://cpb-us-e1.wpmucdn.com/sites.usc.edu/dist/2/672/files/2015/10/USC_Tech-and-Labor-Trafficking_Feb2015.pdf. [22 February 2022]; Scheck, J, Purnell, N & Horwitz, J 2021, ‘Facebook Employees Flag Drug Cartels and Human Traffickers. The Company’s Response is Weak, Documents Show’, The Wall Street Journal, 16 September. Available from: https://www.wsj.com/articles/facebook-drug-cartels-human-traffickers-response-is-weak-documents-11631812953. [9 February 2022]; Donovan, L 2021, ‘Domestic Workers in Gulf Countries Vent Woes on TikTok’, The Fuller Project, 26 April. Available from: https://fullerproject.org/story/domestic-workers-in-gulf-countries-vent-woes-on-tiktok/. [9 February 2022].
22Scheck, J, Purnell, N & Horwitz, J 2021, ‘Facebook Employees Flag Drug Cartels and Human Traffickers. The Company’s Response is Weak, Documents Show’, The Wall Street Journal, 16 September. Available from: https://www.wsj.com/articles/facebook-drug-cartels-human-traffickers-response-is-weak-documents-11631812953. [9 February 2022].
23As above.
24Personal communication; Donovan, L 2021, ‘Domestic Workers in Gulf Countries Vent Woes on TikTok’, The Fuller Project, 26 April. Available from: https://fullerproject.org/story/domestic-workers-in-gulf-countries-vent-woes-on-tiktok/. [9 February 2022].
25As above.
26Sovacool, B 2021, ‘When subterranean slavery supports sustainability transitions? power, patriarchy, and child labor in artisanal Congolese cobalt mining’, The Extractive Industries and Society, vol. 8, no. 1, pp. 271-293. Available from: https://doi.org/10.1016/j.exis.2020.11.018. [16 June 2022]; Callaway, A 2018, Powering Down Corruption: Tackling Transparency and Human Rights Risks from Congos Cobalt Mines to Global Supply Chains, The Enough Project. Available from: https://enoughproject.org/reports/powering-down-corruption. [17 June 2022].
27Hao, K & Hernandez, AP 2022, ‘How the AI industry profits from catastrophe’, MIT Technology Review, 20 April. Available from: https://www.technologyreview.com/2022/04/20/1050392/ai-industry-appen-scale-data-labels/. [4 August 2022]; Wakefield, J 2021, ‘AI: Ghost workers demand to be seen and heard’, BBC News, 28 March. Available from: https://www.bbc.com/news/technology-56414491. [4 August 2022].
28Mersie, A 2022, ‘Content moderator in Kenya sues Meta over working conditions’, Reuters, 10 May. Available from: https://www.reuters.com/technology/content-moderator-kenya-sues-meta-over-working-conditions-2022-05-10/. [4 August 2022].
29Report of the Secretary-General 2020, Roadmap for Digital Cooperation, United Nations, p. 4. Available from: https://www.un.org/en/content/digital-cooperation-roadmap/assets/pdf/Roadmap_for_Digital_Cooperation_EN.pdf. [20 May 2022]; Committee on the Elimination of Discrimination against Women 2020, General recommendation No. 38 (2020) on trafficking in women and girls in the context of global migration CEDAW/C/GC/38, United Nations, p. 14. Available from: https://reliefweb.int/attachments/50e9a140-16e7-3d3a-847f-05b9174c8c5b/CEDAW_C_GC_38_9278_E.pdf. [13 June 2022]; Report of the UN Secretary-General’s High-level Panel on Digital Cooperation 2019, the age of digital interdependence, United Nations. Available from: https://www.un.org/en/pdfs/DigitalCooperation-report-for%20web.pdf. [20 May 2022]; Office of the High Commissioner for Human Rights 2022, OHCHR and business and human rights: B-Tech Project, United Nations. Available from: https://www.ohchr.org/en/business-and-human-rights/b-tech-project. [20 May 2022]; Office of the High Commissioner for Human Rights 2019, UN Human Rights Business and Human Rights in Technology Project (B-Tech): Overview and Scope, United Nations. Available from: https://www.ohchr.org/sites/default/files/Documents/Issues/Business/B-Tech/B_Tech_Project_revised_scoping_final.pdf. [20 May 2022]; Office of the High Commissioner for Human Rights 2020, The UN Guiding Principles in the Age of Technology: A B-Tech Foundational Paper, United Nations. Available from: https://www.ohchr.org/sites/default/files/Documents/Issues/Business/B-Tech/introduction-ungp-age-technology.pdf. [20 May 2022].
30United Nations Office of the High Commissioner for Human Rights 2011, Guiding Principles on Business and Human Rights: Implementing the United Nations Protect, Respect and Remedy Framework HR/PUB/11/04, pp. 14-15. Available from: https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshr_en.pdf. [27 February 2022].
31United Nations Office of the High Commissioner for Human Rights 2020, Taking Action to Address Human Rights Risks Related to End-Use: A B-Tech Foundational Paper, United Nations, p. 1. Available from: https://www.ohchr.org/sites/default/files/Documents/Issues/Business/B-Tech/taking-action-address-human-rights-risks.pdf. [22 July 2022]; United Nations Office of the High Commissioner for Human Rights 2020, Addressing Business Model Related Human Rights Risks: A B-Tech Foundational Paper, United Nations, p. 5. Available from: https://www.ohchr.org/sites/default/files/Documents/Issues/Business/B-Tech/B_Tech_Foundational_Paper.pdf. [25 July 2022]; Farthing, S, Howell, J, Lecchi, K, Paleologos, Z, Saintilan, P & Santow, E 2021, Human Rights and Technology, Australian Human Rights Commission. Available from: https://tech.humanrights.gov.au/sites/default/files/2021-05/AHRC_RightsTech_2021_Final_Report.pdf. [22 July 2022].
32Modern Slavery Act, 2015 (United Kingdom) ; Modern Slavery Act, 2018 (Australia Cmlth)
33Guidance issued under section 54(9) of the UK MSA does not explicitly require companies to report on modern slavery risks linked to their products or services. Meanwhile, the Australian MSA guidance explicitly states companies are not obligated to report on risks relating to customers. Home Office 2017, Transparency in supply chains: a practical guide, Government of the United Kingdom, p. 32. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1040283/Transparency_in_Supply_Chains_A_Practical_Guide_2017_final.pdf. [11 July 2022]; Australian Border Force n.d., Commonwealth Modern Slavery Act 2018: Guidance for Reporting Entities, pp. 33-34. Available from: https://www.homeaffairs.gov.au/criminal-justice/files/modern-slavery-reporting-entities.pdf. [27 February 2022].
34We were able to identify and assess 27 statements produced by 10 reporting entities from 2018 to 2022, covering 10 social media platforms, with two companies also distributing social media applications. Eighteen out of 27 statements explicitly mentioned at least one social media platform (or stores distributing social media platforms) under their control.
35For the purposes of the assessment, ‘social media’ refers to computer and Internet-based technologies that facilitate sharing of user-generated content through virtual networks via computer or smartphone.
36Of the most recent statements published for each reporting entity assessed, one was published for financial year 2020, six were published for financial year 2021, and three were published for financial year 2022. Four statements were produced under the UK MSA, three were produced under the Australian MSA, and two were produced under both.
37Statements falling under the scope of the Australian MSA are required to have their statement approved by a principal governing body and signed by a responsible member; and must fulfil six mandatory reporting criteria (excluding mandatory criterion seven: any other relevant information), namely: identify the reporting entity and describe its structure, operations and supply chains (mandatory criteria one and two); describe the risks of modern slavery practices in the operations and supply chains of the reporting entity and any entities the reporting entity owns or controls (mandatory criterion three); describe the actions taken by the reporting entity and any entities that the reporting entity owns or controls to assess and address these risks, including due diligence and remediation processes (mandatory criterion four); describe how the reporting entity assesses the effectiveness of actions being taken to assess and address modern slavery risks (mandatory criterion five); and describe the process of consultation with any entities the reporting entity owns or controls (mandatory criterion six). Australian Border Force n.d., Commonwealth Modern Slavery Act 2018: Guidance for Reporting Entities, pp. 33-34. Available from: https://www.homeaffairs.gov.au/criminal-justice/files/modern-slavery-reporting-entities.pdf. [27 February 2022]. For a comparison on minimum requirements and guidance under the UK and Australian MSA, see also: Walk Free & WikiRate 2022, Beyond compliance in the garment industry: Assessing UK and Australian Modern Slavery Act statements produced by the garment industry and its investors, Minderoo Foundation, p. 33. Available from: https://cdn.walkfree.org/content/uploads/2022/02/22150956/Walk-Free-Beyond-Compliance-Garment-Industry.pdf. [19 July 2022].
38Statements falling under the scope of the UK MSA are required to: update their statement every year; publish their statement on the homepage of their website; obtain approval from the board of directors (or equivalent management body); and obtain sign off from a director (or equivalent or designated member) Home Office 2017, Transparency in supply chains: a practical guide, Government of the United Kingdom, pp. 20-21. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1040283/Transparency_in_Supply_Chains_A_Practical_Guide_2017_final.pdf. [11 July 2022]. For a comparison on minimum requirements and guidance under the UK and Australian MSA, see also: Walk Free & WikiRate 2022, Beyond compliance in the garment industry: Assessing UK and Australian Modern Slavery Act statements produced by the garment industry and its investors, Minderoo Foundation, p. 33. Available from: https://cdn.walkfree.org/content/uploads/2022/02/22150956/Walk-Free-Beyond-Compliance-Garment-Industry.pdf. [19 July 2022].
39Surf and Sound n.d., Surf and Sound: Improving and sharing knowledge on the Internet role in the human trafficking process. Available from: http://www.surfandsound.eu/?page_id=763. [15 July 2022].
40BSR 2022, Collaborative initiatives: Tech Against Trafficking. Available from: https://www.bsr.org/en/collaboration/groups/tech-against-trafficking#:~:text=Tech%20Against%20Trafficking%20is%20a,eradicate%20human%20trafficking%20using%20technology. [27 May 2022].
41Tech Coalition 2022, Tech Coalition. Available from: https://www.technologycoalition.org/. [27 May 2022].
42As of January 2023. Social media users may not represent unique individuals. Kemp, S 2022, Digital 2022: Global Overview Report, Datareportal. Available from: https://datareportal.com/reports/digital-2023-global-overview-report. [17 March 2023].
43For example, the 2017 French Duty of Vigilance Act and 2021 German Act on Corporate Due Diligence Obligations in Supply Chains, which entered into force on 1 January 2023.
44Australian Border Force n.d., Commonwealth Modern Slavery Act 2018: Guidance for Reporting Entities, pp. 33-34. Available from: https://www.homeaffairs.gov.au/criminal-justice/files/modern-slavery-reporting-entities.pdf. [27 February 2022]; Home Office 2017, Transparency in supply chains: a practical guide, Government of the United Kingdom, p. 32. Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1040283/Transparency_in_Supply_Chains_A_Practical_Guide_2017_final.pdf. [11 July 2022].
45For a discussion of the unintended negative impacts of the United States Fight Online Sex Trafficking Act and Stop Enabling Sex Traffickers Act (FOSTA-SESTA) 2018, see: Blunt, D & Wolf, A 2020, Erased: The Impact of FOSTA-SESTA, Hacking//Hustling, pp. 9-12. Available from: https://hackinghustling.org/wp-content/uploads/2020/01/HackingHustling-Erased.pdf. [11 July 2022].
46Polaris 2018, On-Ramps, Intersections and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking. Available from: https://polarisproject.org/wp-content/uploads/2018/08/A-Roadmap-for-Systems-and-Industries-to-Prevent-and-Disrupt-Human-Trafficking-Social-Media.pdf. [9 February 2022].
47As above.
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