A/HRC/35/37 including auditing, a capacity-building programme for businesses, including for suppliers, and alternative stakeholder engagement activities. As mentioned above, standards and an assurance programme alone are not sufficient to embed the standards into a company’s business model. Thus, many multi-stakeholder initiatives and industry coalitions develop, in parallel, capacity-building programmes and other awareness-raising activities for their stakeholders to help promote the standards and their implementation. 2. How is trafficking in persons codified in voluntary standards? 37. Corporate codes of conduct and the voluntary standards set by multi-stakeholder initiatives and industry coalitions typically include a reference to trafficking in persons or forced labour. The trafficking in persons, or forced labour, standard is normally based on international human rights instruments and labour standards. However, the reference is often limited to a mere prohibition of the use of forced labour or trafficking in persons and is not further developed into specific indicators to help identify risk practices and define what forced labour or trafficking in persons may look like in practice. 38. As mentioned above, unethical recruitment practices and how they represent a risk of forced labour and trafficking in persons are not widely acknowledged within the private sector or among the stakeholders that participate in the standard-setting process. While some initiatives, such as the Ethical Trading Initiative or Social Accountability International, were created to uphold a strong labour rights component, others, such as the Marine Stewardship Council, were established primarily with an environmental focus. As a result, the level of sophistication in developing indicators that can effectively account for companies’ risk practices in this area varies from one initiative to another. The differences among initiatives regarding their original motivation may not only have an impact in the standard-setting and revision process but may also affect a multi-stakeholder initiative’s success in establishing an assurance programme that effectively monitors businesses compliance with a trafficking standard. 39. Budget constraints imposed by client companies and limitations in audit protocols with respect to worker interviews, including the practical challenges of interviewing migrant workers from diverse cultural and linguistic backgrounds, are also key concerns. Given the low levels of awareness among clients about trafficking and forced labour risks and a lack of systems for assessing recruitment and migration practices, the level of detection of trafficking in persons and forced labour cases remains low. An underlying problem identified through the dialogue with the auditing industry is the absence of representatives of that industry at standard-setting negotiations within multi-stakeholder initiatives. As a result, such negotiations can produce auditing protocols that are not effective or practical. 40. The evaluation of the competence of the auditors is also a key concern. The level of understanding of the complexities of detecting trafficking in persons, forced labour and other types of labour exploitation varies among those in the industry. The skills required to, among other things, interview workers, and an auditor’s comprehensive understanding of the specific vulnerabilities of categories of workers, such as migrant or contract workers, are indispensable to ensuring adequate evaluations of a company’s performance on indicators related to trafficking in persons. Unfortunately, one single team of auditors is often charged with the evaluation of the complete set of indicators, including those on other issues, such as deforestation or corruption. It is unlikely that auditors with expertise in environmental concerns would have also the same level of experience in evaluating corporate practices that represent risk indicators of trafficking in persons or forced labour, especially considering the subtle ways in which such practices may be concealed and the fact that workers themselves may be unaware of the wrongfulness of corporate practices that are perceived as common businesses practices, such as compulsory overtime or the payment of recruitment fees. 3. Criticism of voluntary standards and concerns about their effectiveness in detecting and addressing trafficking in persons 41. Voluntary standards and certification schemes are the object of criticism by some in the labour rights movement, particularly trade unions, which have claimed that such 9