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Slavery is a Business Risk – New ICC Policy

Feb 27, 2025 | Article, Ethical Business

ICC Policy Cover

Slavery is a Business Risk: What the ICC’s New Policy Means for Companies and Consumers

(written by Sally Irwin)

Modern slavery isn’t just a human rights issue—it’s a business risk. This new policy has teeth.

In December 2024, the International Criminal Court (ICC) released its Policy on the Crime of Slavery. Importantly it is reinforcing its commitment to prosecuting those responsible for forced labour, human trafficking, and exploitation. This policy isn’t just about criminal justice Specifically, it has serious implications for businesses, supply chains, and consumer responsibility.

If your business has global operations, sources materials internationally, or engages with high-risk industries, this policy matters to you.

Here’s what you need to know:

What is the ICC’s Policy on Slavery?

The ICC’s new policy establishes slavery as a severe international crime under its jurisdiction. As a result, it is making it clear that individuals — including business executives, suppliers, and enablers — can be prosecuted for facilitating modern slavery.

How This is Developed in the Policy:

  • recognises slavery as a standalone crime, not just part of human trafficking.
  • expands legal accountability to those who benefit financially from forced labour.
  • strengthens enforcement strategies, prioritising victim-centred justice. (and The Freedom Hub loves this!)
  • aligns with international human rights frameworks like the UN Guiding Principles on Business and Human Rights. (UNGPs)

Why Businesses Should Pay Attention

Failure to comply with ethical labour practices is no longer just a reputational risk. Specifically, it can now have criminal consequences. While we have always tried to encourage businesses to take on human rights willingly, this does level the playing field for those who exploit people for profit.

The ICC’s stance puts pressure on businesses to actively eliminate forced labour from their supply chains and operations.

Key Legal Implications for Businesses:

  • Executives and suppliers can be held criminally liable for knowingly profiting from forced labour.
  • Due diligence failures can lead to investigations and legal consequences.
  • Complicity in slavery-related crimes could result in financial penalties, asset seizures, or imprisonment.
  • Companies operating in high-risk industries (fashion, agriculture, mining, construction) are under increased scrutiny.
  • Governments may adopt stricter regulations, aligning with ICC’s policy in corporate accountability laws.

What This Means for Ethical Business & Consumer Responsibility

As a result, companies that do take proactive measures to combat modern slavery will be ahead of the curve. In addition, they don’t risk criminal liability, reputational damage, and loss of consumer trust.

For Businesses: Implement robust human rights due diligence, increase supply chain transparency, and ensure ethical sourcing policies align with global standards.

For Consumers: Demand greater accountability from brands, support fair trade initiatives, and make purchasing decisions that prioritize ethical labour practices.

For Policymakers & Activists: Push for stronger corporate responsibility laws, advocate for victim-centred policies, and collaborate with global watchdogs.

The Freedom Hub’s Stand: Leading the Fight Against Modern Slavery

At The Freedom Hub, we believe businesses should be part of the solution, not the problem.

The ICC’s new policy is a wake-up call for industries worldwide to take action, implement ethical labour practices, and protect vulnerable workers.

If you want to ensure your business is compliant and ethically sound then have a conversation with us. Small changes can build a future where no one profits from slavery and we love helping businesses, both large and small work towards lifting humanity in business.

 

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