Key Insights:

• • • Regional collaboration and international partnerships are essential for combating transnational human trafficking, with Nigeria’s cooperation with neighboring countries and support from organizations like ICMPD are vital for cross-border intelligence sharing and victim protection.

    • A multidisciplinary approach to combatting human trafficking, like the one in Nigeria, results in the best approach for measurable success.

    • Prevention through education is crucial, as demonstrated by targeted school programs like STEAP that reach approximately 100,000 students across five Nigerian states to build awareness and resilience among vulnerable youth before exploitation occurs.

Human trafficking, along with many other cross-border crimes, is a highly complex issue, and it has been one of the fastest-growing, more lucrative shadow industries globally for trafficking syndicates. Owing to its multi-issue dimensions, human trafficking is a challenge to tackle head-on, but the Nigerian government has been showing success in numbers.

Since 2003, at least 25,550 victims of human trafficking and more than 2,050 survivors of violence have been rescued by Nigeria’s . The agency also secured a total of 755 convictions, highlighting its commitment to protecting vulnerable populations in the country and holding perpetrators accountable, including those acting across borders. Last year alone, NAPTIP investigated 698 cases, including 333 related to sex trafficking and 172 to labor trafficking.

Beyond what these numbers show, NAPTIP has become a model in Africa as a one-stop agency for all issues of human trafficking — ranging from case investigation, prosecuting offenders, raising awareness on the risks, and providing protection and assistance to victims and survivors. To date, NAPTIP has also been operating 14 shelters across its 34 regional offices across Nigeria, providing safe havens and comprehensive support services to 1,587 victims in the last year alone.

Multidisciplinary agency in Nigeria key for success

Nigeria signed the United Nations’ Convention Against Transnational Organized Crime and the Palermo Protocol in 2000. In 2003, its Parliament enacted the Trafficking in Persons (Prohibition) Law Enforcement and Administration Act (TIPPLEA), and NAPTIP was concurrently born.

As a multidisciplinary agency, NAPTIP works closely with other law enforcement agencies, as well as judiciary, civil society, and international partners to disrupt trafficking networks. Through legal reforms, victim support, increased enforcement, and grassroots-level advocacy, NAPTIP has focused on taking down trafficking networks that target vulnerable populations, especially children and youth.

Join us for a free online Webinar: World Day Against Trafficking in Persons to learn more about the complexities of human trafficking, the impact on victims, and effective strategies for prevention and intervention

In 2015 the TIPPLEA was re-configured into the Trafficking in Persons (Prohibition) Enforcement and Administration Act (TIPPEA) to tackle newly emerging trafficking trends, strengthen the law by removing the option for trafficking offenders to pay fines, and provide a benchmark for sentencing offenders via other laws. Since then, the , an international research and policy institute, has been a key supporter of NAPTIP’s operations with a focus on prevention, protection, and capacity development. Through its implementing role of European Union-funded project of the , ICMPD has been collaborating with NAPTIP and other in-country partners to:

• • • integrate human trafficking issues into the curricula of Basic and Senior Secondary Schools, as well as into the minimum standards of Colleges of Education in the country;
    • develop teacher’s guides and provide training of trainers for Colleges of Education; and
    • produce training curriculum for NAPTIP personnel and training manuals for the agency’s trainers.

By 2020, the partnership expanded across Nigeria’s neighbors in the region. Through a bilateral accord, NAPTIP collaborated with its Niger counterpart to deal with trafficking through joint operations, including public awareness campaigns and exchange of intelligence. With ICMPD’s support, this partnership has been providing support to victims of human trafficking in-country, and for the return of rescued Nigerian victims from its northern neighbor.

“ICMPD has been an ally in our counter-trafficking engagements in Nigeria,” says . “They have supported us in developing policy documents, in deepening our awareness-raising (especially in schools), and in various activities to protect and assist victims and survivors of trafficking. Above all, we are enjoying a lot of collaboration with some of our neighboring West African countries through their support.”

Awareness, education & collaboration with neighbors helps prevention

As in many other trans-national crimes, human trafficking preys on the vulnerable, especially on young people. Hence, one of the flagship projects of ICMPD’s support to NAPTIP is the , funded by the Government of the Netherlands. It raises awareness among school-age children and their communities and fosters collaboration with civil society organizations to equip the students in recognizing the risks of trafficking. It also helps them avoid such risks, promote safe behaviors, and create a protective environment that reduces their own vulnerabilities before exploitation can occur.

Part of this is the joint ICMPD-NAPTIP Vanguards in 250 schools across the five Nigerian states of Benue, Delta, Edo, Enugu, and Ogun, targeting approximately 100,000 students. In addition to STEAP activities, the Vanguard enables them to become peer educators, helping them become better informed, more vigilant, and resilient advocates in preventing trafficking in their schools and communities.

Beyond STEAP, the Nigerian government works more broadly on anti-trafficking efforts through the . Also funded by the Dutch Government and implemented by ICMPD, TIPVAP looks to address human trafficking by upscaling capacity of the investigators and prosecutors, establishing effective victim referral systems, and raising public awareness. The initiative also improves the investigation and prosecution of cases, and ensures victims receive timely, coordinated support including legal aid and protection services — and its community outreach enjoins communities to recognize and report these crimes.

“Addressing the diverse social, economic, and legal factors that drive human trafficking particularly by reaching children and youth, who are among the most vulnerable is a key pillar of our collaboration with NAPTIP in Nigeria and across the wider West African region,” says a spokesperson for STEAP at ICMPD. “By supporting NAPTIP’s efforts, ICMPD is able to apply its technical expertise and unique perspective on migration to meaningful, practical work. We remain firmly committed to partnering with the Nigerian government in this vital endeavor.”

Given its strategic location in the West African region, Nigeria is well-positioned to foster cross-border cooperation and intelligence sharing, while harmonizing victim-protection legal frameworks to keep people safe from trafficking. As it continues to implement its National Action Plan on Human Trafficking, the joint efforts of NAPTIP and ICMPD remain crucial in addressing the evolving challenges of human trafficking and ensuring the protection of vulnerable populations.

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Of particular importance is the ongoing evolution of the erosion of the rule of law around the world. This fact alone creates risk exposure, especially in governance and assessment of legal risks, for companies’ chief legal officer (CLO) or general counsel (GCs), who act as the guardians of the company when it comes to legal, reputational, or ethical risks as well as other types of risk.

Erosion in the rule of law

Sean West, co-founder of and author of the newsletter, recently points out that the World Justice Project has framed the current status of the rule of law as “in recession” around the world, a .

For companies, the implication of this decay is that the assumptions in how the practice of law operates are no longer certain, according to West. “From an in-house point of view, we see CLOs getting pulled very much into the political planning and fray of their companies,” he says, adding that the disappearance of the norms in the roles that lawyers and the judiciary play are causing a seismic influence in the risk environment for companies. “This could leave companies to underestimate the risk that they face in certain places.”

For example, the companies that lawyers represent — whether they work as in-house counsel or external legal advisers — are subject to the effects of political climates, which can affect their share prices and business strategies to different extents. If lawyers only considers the legal aspects narrowly, they might miss out on identifying certain opportunities and hazards. Indeed, a company might win a legal battle but face unexpected political fallout as a result.

Further, legal professionals might judge a situation to be of low risk by not factoring in the wider political context, which is especially relevant given the numerous global elections happening this year. “The way that things have always been in a particular region or economy may not be the way that they are six months from now when a more populist or a new government comes in,” West explains.

Interrelated risks create integrated approaches

The lack of certainty in international affairs and how it could impact companies is one of many challenges for CLOs and GCs in the risk landscape. Add in the technological shifts and fragmentation of regulatory regimes, and the overall risk environment gets murky fast. “We can’t just talk about things like international affairs or artificial intelligence or environmental, social and governance issues as if their independent events,” West says. “They’re happening in a context that creates friction.”

Law firms — especially as technology elevates the standard for delivering value-added services to their clients — must consider the evolving needs of their customers to stay competitive. Indeed, being proactive on behalf of their clients is going to be worth a lot more than spending an extra dozen hours or so. Ongoing conflicts in the Middle East, for example, can disrupt companies’ supply chains, resulting in various legal complexities, from withdrawing operations from affected regions to revising agreements or justifying unmet commitments.

For law firms doing business with clients in these circumstances, the task of understanding the initial causes of these supply issues is crucial for identifying key strategic or competitive opportunities for the businesses. GCs are increasingly involved in these discussions, although they may not always have the collective expertise from their deputies and team members who may or may not be skilled in this specific type of analytical work, West adds.

Guidance for CLOs and GCs to address governance gaps

West advises that GCs and CLOs review their companies’ strategic plans and determine the Top 5 priorities that are critical for their companies’ success. Then, in collaboration with cross-functional peers, they should analyze how politics can disrupt or enable these priorities. They then are in a better position to make an assessment through the lenses of both risk and opportunity, simply by answering two questions:

• • • What is the company really trying to achieve today based on my knowledge as an manager of risk, whether it be legal, reputational, financial, or something else?
    • What are the different ways in which the politics of a region could manifest itself and disrupt the company by triggering the type of risk for which I am responsible?

West explains that it is then necessary for the group to build some scenarios around the potential events and identify what their companies’ proper responses would be. Working collectively as a group — when the group is not in the heat of a crisis — to build out plans for how each function would operate should the scenario develop enables effective decision-making around the best action when a crisis does hit.

Also equally important is the development of functional plans. For risk management leaders, it is important to understand what their companies’ mitigating actions would be in advance of any crisis. Going one step further, one best practice is embedding these discussions in their companies’ enterprise risk management governance and processes and to gather with peers a few times a year to review scenarios and plans, while keeping the values front and center to determine effective responses.

The decay in the rule of law is just one of many dynamic complexities in today’s risk environment in which companies are operating. It is critical for GCs and CLOs to gather with their peers regularly to assess and re-assess how the operating context is changing and then tweaking their risk mitigation response plans appropriately as a key part of ongoing governance to ensure their companies’ sustainability and success.

The United Nations SDGs call for multilateral action to address social, economic, and environmental sustainability. Political shifts and the economic impacts of the COVID-19 pandemic have delayed broad realization of these goals across the US. In this vacuum, California has moved itself to the forefront, and is now joined by several other states, counties, and municipal governments that are forging their own paths toward implementation.

California’s embrace of SDGs

Progress toward implementation of the 17 SDGs adopted by the UN in 2015 has stalled dramatically. As of 2023, the that progress had “stalled or reversed” for 30% of its SDG goals, with the pandemic, escalating climate crisis, and war in Ukraine noted as the primary reasons. Implementation toward some goals, such as working toward zero hunger, , as efforts to meet growing food demand hinder the goal of reduced greenhouse gas emissions.

In the UK, Prime Minister Rishi Sunak faced criticism for for climate-related goals. Delays in phasing out the sale of new combustion engine vehicles and gas boilers, coupled with a failure to meet emissions targets have attracted negative business attention. Resistance to green policies is , however, as political and labor movements in Italy, Poland, Germany, and the Netherlands have applied political pressure to slow or reverse requirements on building energy-efficient, combustion engine cars; nitrogen pollution on farms; reliance on fossil fuels; and oil and gas heating.

By contrast, the State of California — the world’s fifth-largest economy — has taken a progressive approach toward SDG implementation. The has established far-reaching goals of dramatically reducing greenhouse gas emissions, substantially reducing in fossil fuel demands, and making significant gains in reducing smog-forming pollution, with an overall aim of reaching carbon neutrality by 2045. More recently, dedicated $180 billion in multisource funding toward electrical grid capacity that will help provide clean energy, safe drinking water, and modernized transportation infrastructure.

Reporting requirements for businesses

In 2023, the State of California passed requiring mandatory emissions reporting from more than 15,000 business entities. The reporting requirements compel businesses with certain revenue minimums to report on their direct greenhouse gas emissions, (known as Scope 1); emissions from their purchased energy (Scope 2), and additional climate-related financial risks beginning in 2026. The most controversial reporting requirement, that of emissions from downstream vendors and suppliers (Scope 3) will not be needed until 2027.

Legal challenges have arisen in federal court with a lawsuit from the U.S. Chamber of Commerce, arguing that Senate Bills 253 and 261 violate the First Amendment of the Constitution by “compelling speech” from business entities. Additionally, Scope 3 reporting itself has been targeted as it would require supplier companies outside of California, and perhaps outside the US, to provide reporting to impacted California businesses.

Just this month, the adopted their own business reporting guidelines, closely resembling California’s, for most publicly traded companies. The require affected companies to disclose climate related risks, costs of severe weather events and natural conditions, climate-related targets or goals material to their business, processes adopted by the company to identify climate-related risks, and Board of Director oversights on these risks. The final proposal dropped the controversial Scope 3, which has been adopted but delayed in the State of California.

The SEC has noted that nearly 40% of affected companies already report on these measures, just not in any standardized fashion. Their argument is that such reporting , but provides investors with clear, consistent, comparable, and decision-useful information to guide investment decisions.

States and cities follow California’s lead

While political aims delay broad national or international implementation of SDGs, states and cities are following California’s lead in individual implementation efforts. The State of Hawai’i, which is (as an island state) particularly susceptible to climate risk, has its own that is publicly available. Several large to midsize US cities and counties also have set up their own forward goals, plans, and dashboards for sustainability, environmental services, and economic health.

The City of Los Angeles, for example, has a ; and New York City was one of the first to pioneer and direct reporting to the UN on SDG implementation. The City of Boston implemented its own nearly a decade prior to the development of SDGs internationally and has for emissions and energy efficiency in buildings. Smaller entities with similar implementation strategies include ; ; and

According to the , California shares its goals for carbon-free electricity with 14 other US states and territories. Many states with said goals fall on the left-leaning side of the political spectrum, but as an example of a traditional red state that is also aggressively pursuing a shift to clean energy sources. Texas relies heavily on coal and natural gas use which makes the state a high carbon-intensive power system, but state leaders are clearly predicting rapid growth in both solar development and offshore wind power generation.