AGENCY SUBMISSIONS
CAL regularly files petitions with federal government agencies to provide evidence of human rights violations in global supply chains. CAL has submitted filings to U.S. Customs and Border Protection, the Federal Trade Commission, the Department of Justice, the State Department, the Treasury Department, and foreign regulatory agencies, among others. Though government processes can be slow and opaque, sometimes they result in a win—such as the 2024 Withhold Release Order against doTERRA’s (now former) frankincense supplier, Asli Maydi. CAL continues to use every legal tool available to pursue justice for communities impacted by corporate impunity around the globe.
Past filings
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In November 2024, CAL and the Southern Shrimp Alliance co-filed a formal complaint with the Federal Trade Commission (FTC), requesting action against false or deceptive advertising- or marketing-related activities by the Best Aquaculture Practices (BAP) certification scheme, operated by the Global Seafood Alliance (GSA), as well as the many brands and retailers that use and rely on the BAP seal to sell their farmed shrimp products. The petition demonstrates that BAP certification represents Indian shrimp products as safe, responsible, and ethically farmed seafood despite CAL’s findings on the use of exploitative labor practices–including forced labor–as well as the widespread presence of banned antibiotics and environmentally damaging practices.
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In October 2024, on behalf of 30 cocoa farmers, Corporate Accountability Lab (CAL), Civic Response, and the University of Ghana School of Law submitted a grievance to the Ghana Cocoa Board (COCOBOD)’s grievance and redress mechanism, focused on issues that have long been present in the cocoa sector and urging the agency to take immediate action to address them. These issues include increasing the Farm Gate price of cocoa, mandating traceable and transparent cocoa supply chains, better regulations on the sale and use of pesticides, addressing deforestation and the impacts of climate change, and enforcing monitoring and remediation systems for hazardous child labor in the sector.
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In February 2023, CAL and the Horn of Africa Charity Organisation (HOACO) submitted evidence of forced labor to the U.S. Customs and Border Protection agency, in reference to Somaliland frankincense supplier Asli Maydi’s supply chain. CAL and HOACO investigated Asli Maydi and found that for several years, the supplier company’s owner Barkhad Hassan, Asli Maydi, and essential oils company doTERRA have abused and exploited frankincense harvesters, sorters, and harvesting communities within Somaliland. Asli Maydi is the primary exporter of frankincense resin harvested in the Somaliland and Puntland regions of Somalia. The company, at the behest of its owner Hassan, withheld payments from harvesters and wages from sorters; created dangerous working conditions for sorters, who are primarily women; and used threats and intimidation, including physical and sexual violence, to maintain their dominant market position. Despite being aware of conditions amounting to forced labor, the Utah-based corporation doTERRA continued to source this resin through Asli Maydi to produce and sell essential oils to a primarily U.S. market. In November 2024, Customs and Border Protection issued a Withhold Release Order (or import ban) against Asli Maydi, finding credible evidence of five indicators of forced labor within its supply chain: deception, withholding of wages, abusive working conditions, threats and intimidation, and physical violence. To date, doTERRA has not compensated any of those harmed.
