How TruthMark covers supply-chain forced labor

The Berkeley Protocol on Digital Open Source Investigations (Principle 1: Do No Harm; Principle 6: Ethical Evidence Use) is load-bearing for this module. Supply-chain accountability data is uniquely sensitive:

• False allegations damage workers and brands alike. An aggregator that flattens a UFLPA detention into a company-wide “forced labor” verdict misrepresents both. CBP detains shipments under a rebuttable presumption; many are released after evidence is provided.
• Country-good pairs ≠ company indictments. DOL ILAB's lists name countries and goods (e.g., “cotton from Turkmenistan”), not specific brands. Re-targeting those onto particular companies without enforcement evidence is speculation.
• SEC disclosures are filer-supplied. 10-K disclosures about supply-chain risk vary in candor. The absence of a UFLPA mention in a filing does not mean a clean supply chain; it may mean the company hasn't been audited.

We don't aggregate. We point you at the federal regulator that has the authoritative record and the legal disclaimers attached.

U.S. supply-chain forced-labor accountability sits primarily at the federal level by design. Imports are federal jurisdiction. SEC disclosure rules are federal. Federal contractor compliance is federal. The seven federal sources on the Supply Chain homepage cover the bulk of enforceable accountability:

• DOL ILAB List of Goods + List of Products (E.O. 13126) — country/good pairs ILAB has reason to believe involve child or forced labor; the second list also drives federal-contractor certification.
• CBP UFLPA enforcement — rebuttable-presumption framework on imports tied to the Xinjiang Uyghur Autonomous Region; the UFLPA Entity List names sanctioned producers.
• SEC EDGAR full-text search — surface 10-K, 10-Q, 8-K disclosures that mention “forced labor”, “UFLPA”, “Xinjiang”, or supply-chain audit language. The closest thing to a company-level lookup, but it returns filings — not scoring.
• DOJ HTPU + National Worker Exploitation Task Force — federal prosecution coordination for involuntary servitude, peonage, and labor-trafficking offenses.
• FTC “Made in USA” / supply-chain-claim guidance — federal hook on deceptive marketing about provenance and ethical sourcing.

Two fundamentally different categories of public information that users routinely conflate:

• Corporate transparency disclosures (CA Transparency in Supply Chains Act; SEC 10-K supply-chain risk sections; UK Modern Slavery Act statements) are self-reportedby the company. They tell you what the company says it's doing, not what enforcement has found.
• Enforcement action databases (CBP UFLPA detentions and Entity List, DOJ press releases, state-AG prosecution records) are regulator-determined. They tell you what enforcement has actually done.

Both belong in a complete picture. Treating either as the other produces misleading conclusions. Our directory surfaces both categories side by side and explains, per resource, which it is.

A few well-known NGOs (Polaris Project, National Human Trafficking Hotline, Stop the Traffik, Walk Free Foundation, Verité) maintain extensive supply-chain and trafficking databases. Their social-services work is essential — and we link to them individually from elsewhere on TruthMark when appropriate. But we don't aggregate them into this module because:

• Editorial framing varies. Each NGO has methodological choices that make their data hard to compare side-by-side or with government records.
• Government enforcement is the authoritative test. CBP detentions, DOJ prosecutions, and FTC enforcement actions are the records that carry legal weight. NGO reports inform public discourse; they don't establish accountability.
• Same rule as Public Employees. We don't link to NGO labor databases there either (Transparent California, Mackinac Center, etc.). Consistent policy across modules.

State coverage of supply-chain accountability is uneven and mostly focused on prosecution of trafficking offenses. A small number of states have enacted standalone supply-chain transparency laws:

• California — TISCA (SB 657, 2010) requires retailers/manufacturers over $100M worldwide gross receipts to publish anti-slavery disclosures. The CA AG hosts the resource guide; California does not centrally index every covered company's disclosure.
• State human-trafficking task forces in most states are joint federal-state-local; the state lead varies (state AG, state police, governor's office). Honest gaps: ID, ME, MD, ND, RI, SD, VT, WV, WY have no dedicated AG trafficking page; we link to the AG root.
• Three felony-AG states — Alaska, Delaware, Rhode Island — where the state AG prosecutes all felonies including all human-trafficking cases.
• Territories— generally lack dedicated trafficking units. Federal HSI and the U.S. Attorney's Office handle. We link to both the territorial AG/DOJ and the relevant USAO joint task force where one exists (Marianas Task Force for Guam + CNMI; District of Puerto Rico for PR; District of the Virgin Islands for USVI).

Hard rule for this module: we never characterize specific companies. We don't maintain a TruthMark list of “worst offenders”, we don't score brands, we don't re-target government enforcement actions onto a different company's SEO surface. The closest we come to a company-level signal is the SEC EDGAR full-text search — which surfaces what the company itself filed, where they themselves chose the words. The user does the interpretation.

• Whether a specific brand “uses forced labor.” That's a legal conclusion that requires investigation. We surface what regulators publish; you decide.
• Pending CBP detentions. CBP releases shipment-level detention data in aggregate statistics, not real-time per-shipment. The Entity List names sanctioned producers but is updated periodically.
• Closed federal investigations without prosecutions. DOJ and DOL HTPU close some investigations without public action; those don't appear in our deep-links.
• Tier-2 and -3 supplier visibility. Most public disclosures cover direct (tier-1) suppliers only. Forced labor in upstream sub-suppliers often goes undetected.