North Korean forced labour and sanctions

For many years North Korea has exported people abroad. These workers are widely recognised to be victims of forced labour. In response, the United Nations Security Council ordered that all North Korean workers be returned home by 22nd December 2019. The United States, European Union and multiple other countries maintain sanctions that limit trade with the North Korean regime. Notably, the US imposed sanctions on two companies suspected of employing North Korean labour in Russia in November 2020.[1]

While there are credible reports of North Korean labourers working in many countries, it is in the Chinese border city Dandong that they are most heavily concentrated. In October 2020 Nikkei Asia reported that “the number of… North Koreans is estimated to reach tens of thousands in Dandong alone. By working in defiance of the U.N. sanctions, they provide Pyongyang with crucial foreign currency income… There are over 100 factories in Dandong that hire North Korean workers... They make a range of products from clothing and electronics to processed seafood.”[2]

Linked companies

The British newspaper, The Guardian, recently reported [3] that Dandong Huayang Textiles and Garments Co Ltd (DHTG) appear to be employing large numbers of North Korean forced labourers at its factories. The newspaper further identified that DHTG was supplying Personal Protective Equipment (PPE) to various clients in Europe, the United States and South Africa- including British firm Unispace Global Ltd. 

DHTG produces a wide variety of garments in addition to PPE. Import Key,[4] a compiler of US Customs records, identifies that the following companies have received goods from DHTG in the last twelve months:

  • Between LLC 
  • Mango USA Inc [5]
  • Poof Apparel Corp 
  • Reitmans Canada Ltd 
  • Summit Retail Solutions Inc 

Action

We are not in a position to ascertain whether any of the goods supplied to the above-named companies by DHTG were made by forced labour. None the less, we strongly encourage companies to assess their supply chains for these organisations and Unispace. In the eventuality that you identify any of the companies, you should engage with them to ascertain whether the goods supplied to you were ultimately procured from DHTG. You should confirm what due diligence they have conducted to ensure that the goods supplied were not made by forced labour. 

If your company has purchased directly from DHTG you should ascertain whether forced labour was used in the production of goods supplied by engaging with DHTG and their workers. Consistent with the United Nations Guiding Principles on Business and Human Rights, you should help remedy any abuses your company has contributed to. 

We further recommend that companies engage with all their suppliers to identify if any North Korean labourers are present in their supply chains. Any goods produced in the Chinese border provinces of Liaoning (where Dandong is located) and Jilin should be prioritised for due diligence. 

In sum, any good produced by North Korean persons -inside or outside of the country- should be regarded as the fruits of forced labour, a form of modern slavery. Furthermore, it is likely that any such good may be subject to international sanctions.

Please contact us if you require support, guidance or advice.

[1] https://www.reuters.com/article/us-usa-northkorea-sanctions-idUSKBN27Z2G7

[2] https://asia.nikkei.com/Spotlight/N-Korea-at-crossroads/Stranded-North-Koreans-in-China-keep-earning-for-homeland

[3] https://www.theguardian.com/global-development/2020/nov/20/uk-sourced-ppe-from-factories-secretly-using-north-korean-slave-labour

[4] https://importkey.com/company/DANDONG%20HUAYANG%20TEXTILES/supplier/DANDONG%20HUAYANG%20TEXTILES%20AND

[5] Note, we understand that this company is not a part of Punto Fa, S.L. or its ‘Mango’ fashion brand.