The Global Slavery Index 2023

Spotlights 4 

​Anti-Social: Modern Slavery on Social Media (Part 2)
Modern slavery risks permeate the entire social media value chain — from sourcing raw materials, such as cobalt, to the exploitation of workers in data labelling and overseas data centres, and into the digital platforms themselves. 
 
The international community has recognised the need to safeguard human rights in the digital era. 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. 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. 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,however there is no requirement for social media companies to report on how they are addressing modern slavery on their digital platforms. 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 statements published under UK and Australian MSAs by 10 companies. These companies cover 10 social media platforms and two e-stores distributing social media applications. Our assessment found that social media companies are not doing enough to report on modern slavery within their direct operations or supply chains. In their most recent statements (current as of 28 February 2023), no company complied with all minimum requirements under the Australian or UK MSAs. 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. 
 
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 Trafficking and the Tech Coalition, 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. There is an urgent need for them to stop perpetrators from operating with impunity and to prevent modern slavery from flourishing online.
 
Walk Free 2023. Global Slavery Index 2023. Minderoo Foundation Ltd. Australia.