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Uyghur Forced Labor Prevention Act (UFLPA) compliance checklist

The Uyghur Forced Labor Prevention Act (UFLPA) is a law that was enacted in 2020 to prevent the import of goods made using forced labor in the Xinjiang Uyghur Autonomous Region of China. The law requires brands to take steps to ensure that their supply chains are free of forced labor.

To comply with the UFLPA, a brand should consider the following checklist:

  1. Review your supply chain: Identify all suppliers and sub-suppliers that are located in or source from the Xinjiang region.

  2. Implement a risk assessment process: Conduct a thorough assessment of the risk of forced labor in your supply chain, including by conducting site visits and audits of your suppliers and sub-suppliers in the Xinjiang region.

  3. Develop and implement a plan to address identified risks: Based on the results of your risk assessment, develop a plan to address any identified risks of forced labor, including by implementing measures such as strengthening worker protections and implementing reporting and monitoring mechanisms.

  4. Train your employees and suppliers: Provide training to your employees and suppliers on the UFLPA and the risks of forced labor, and how to identify and prevent it.

  5. Monitor and verify compliance: Regularly monitor and verify that your suppliers and sub-suppliers are complying with the UFLPA and other relevant laws and regulations. This may include conducting additional site visits and audits, as well as implementing reporting and monitoring mechanisms.

  6. Document and maintain records: Keep detailed records of your compliance efforts, including records of your risk assessment, plan to address identified risks, training programs, and monitoring and verification activities. This will help to demonstrate your compliance with the UFLPA if it is ever questioned.

  7. Stay up-to-date on developments: The UFLPA is a new law, and it is likely that additional guidance and regulations will be issued over time. Be sure to stay up-to-date on these developments and adjust your compliance efforts accordingly.

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