A/HRC/35/37 duties imposed under the Modern Slavery Act can be enforced in civil proceedings undertaken by the authorities. 20. Both Acts, while considered legislative breakthroughs in developing business accountability for non-financial obligations, are nonetheless not exempt from criticism. The Modern Slavery Act has been criticized for allowing United Kingdom-based companies to hide their supply chains as long as the goods they produce do not enter the United Kingdom, and the California Transparency in Supply Chains Act is considered insufficient, as it requires companies only to report their efforts with no regard for the quality of the effectiveness of the measures taken to eliminate trafficking in persons from their supply chains. In 2015, the Special Rapporteur on contemporary forms of slavery, including its causes and consequences presented a report to the Human Rights Council (A/HRC/30/35) in which those two domestic efforts were further analysed. 21. Feedback generated from consultations held with multi-stakeholder initiatives and private sector representatives indicated that while this type of legislation represents a good starting point for most companies and facilitates the mainstreaming of transparency efforts in smaller companies, more transparency is needed. In addition, private sector stakeholders consulted agreed on the need for stronger normative frameworks at the State level that would establish, based on international standards, clear expectations for businesses regarding their obligations to respect workers’ rights and to protect workers from labour abuses. Stronger normative frameworks would not only help businesses to ensure that their suppliers are bound to the same level of commitment regarding the elimination of trafficking in persons and respect for workers’ rights, but would also help to guarantee an even playing field for those who conduct their operations in accordance with those standards. 22. In 2012, an executive order aimed at strengthening protections against trafficking in persons in federal contracts was signed in the United States. The new amendments to the Federal Acquisition Regulation include further due diligence measures in respect of contractors and address key risk indicators, such as the use of unethical recruitment practices, in particular by prohibiting contractors from charging recruitment fees to workers and from denying employees access to their personal documents. 23. In addition to national legislative frameworks on the accountability of businesses and the effective transposition of international standards to national labour codes, the existence of national policy and legislative frameworks in other areas also plays an important role in tackling and reducing trafficking in persons and forced labour. While not directly addressing the issue of trafficking in persons, measures such as those to regulate recruitment are crucial in reducing risk factors. Indeed, in 2014 the Special Rapporteur on the human rights of migrants dedicated part of his report to the Human Rights Council (A/HRC/26/35) to the issue of recruitment in the context of labour exploitation of migrants. 24. Unfortunately, the regulation of labour recruiters and elimination of unethical recruitment practices are far from homogenous at a global scale and the level of ratification of the ILO Private Employment Agencies Convention, 1997 (No. 181) is low. Some national jurisdictions do not regulate the activities of labour recruiters, allowing a flourishing “informalization” of the industry and permitting practices such as the payment of recruitment fees by jobseekers. Furthermore, in some jurisdictions, workers contracted through employment agencies are not offered the same level of social protection as direct employees, creating a second class of workers and exacerbating the potential negative impact of the lack of regularization of this sector. 25. Regarding recruitment regulation, the ILO launched in September 2016 the nonbinding ILO general principles and operational guidelines for fair recruitment, in which it is reiterated that recruitment should take place in a way that respects, protects and fulfils internationally recognized human rights, including those expressed in international labour standards, such as prevention and elimination of forced labour. The guidelines enshrine principles related to the prohibition of recruitment fees, transparency in the terms and conditions of employment, the prohibition against confiscating workers’ identity documents, and contracts, among others. Another initiative, the International Recruitment Integrity System (IRIS) was launched by IOM in 2014. IRIS is a multi-stakeholder 6