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JONES DAY TALKS®: Jones Day’s Anti-Human Trafficking Initiative: Health Care Supply Chains and Forced Labor

As part of Jones Day’s continuing work against global human trafficking, the Firm actively supports the American Hospital Association (AHA)’s Hospitals Against Violence initiative and HEAL Trafficking (Health, Education, Advocacy, Linkage). A recent special convening hosted in Jones Day's Chicago Office, Forced Labor in Health Care Supply Chains: What Hospital Leaders Need to Knowfocused specifically on health care supply chain issues and how they may interact with forced labor. The event provided practical information and resources to health care providers fighting human trafficking.

Jones Day’s Taylor Goodspeed is joined by Laura Castellanos (AHA), Hanni Stoklosa, MD (HEAL Trafficking), and Laura Kowalczyk (Association for Health Care Resource & Materials Management (AHRMM)) in a candid conversation about the information shared at the convening and Jones Day's continued pro bono efforts in this space.

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A full transcript follows below:

Dave Dalton:

Jones Day's continuing contributions to the global battle against human trafficking are well documented. Today's conversation will review specifically what the firm is doing relating to labor trafficking in the healthcare industry and its supply chains. We've assembled an impressive panel to discuss a recent Jones Day White Paper on the topic, and also to reflect on a recently held convening, and finally to talk about the resources currently available to hospital leaders and the areas which require additional development to fight human trafficking and forced labor. I'm Dave Dalton. You're listening to JONES DAY TALKS®.

Hanni Stoklosa, MD, is executive director of HEAL Trafficking. That's Health, Education, Advocacy, Linkage. She's an emergency physician at Brigham and Women's Hospital with appointments at Harvard Medical School, Harvard's T.H. Chan School of Public Health and the Harvard Humanitarian Initiative. She has advised the US Department of Health and Human Services, Department of Labor and the National Academy of Medicine on issues of human trafficking. She's also testified as an expert witness multiple times before the US Congress.

Laura Kowalczyk is vice president of supply chain and support services for UAB Medicine in Birmingham, Alabama. She is responsible for strategic direction of UAB Medicine's end-to-end supply chain, and she chairs the Association for Healthcare Resource and Materials Management advisory Board. Laura holds a law degree and a master's in public health administration.

Laura Castellanos is an associate director at the American Hospital Association. She leads the association's Hospitals Against Violence initiative where her directives include facilitating a c-suite advisory group, developing strategic partnerships, leading operational and strategic plans, and executing multiple communications and social media plans.

And finally, Taylor Goodspeed is a New York based Jones Day lawyer focusing on regulatory compliance and civil litigation matters involving the healthcare industry. Taylor maintains an active pro bono practice serving on Jones Day's anti-human trafficking committee, and on the American Hospital Association's human trafficking advisory committee. She has also presented widely on the firm's pro bono anti-trafficking efforts. Taylor is currently serving her second term as a member of the Women's Leadership Council for the American Health Law Association.

Thank you so much for being here, all four of you. Thanks for coming by.

Taylor Goodspeed:

Thank you, Dave.

Laura Kowalczyk:

Thank you.

Laura Castellanos:

Thanks, Dave.

Dave Dalton:

Let's kick this off. Let's go straight to Taylor Goodspeed. Taylor, we're going to talk about the convening back in November, the forced labor in healthcare supply chains convening. What was the motivation for pulling that together? How'd that come about?

Taylor Goodspeed:

I just wanted to highlight the title, What Hospital Leaders Need To Know. And through our work with the American Hospital Association and HEAL Trafficking, we recognize an acute need to highlight the issue of labor trafficking in the healthcare supply chain. And this would apply both for goods, good extended products, made or utilizing forced labor as well as services. Those who are forced to perform care in illegal conditions, often with little to no pay. And labor trafficking can be underemphasized in the discussion of human trafficking more broadly, or it can be misunderstood to occur wholly entirely outside of the United States.

And previous work done by our coalition had really focused on the role that individual providers and institutions as major touchpoints with victims of human trafficking can play in the fight against human trafficking as a whole. That form of fighting human trafficking may be more familiar to many in the healthcare system. We have released a number of resources on the provider side over time, including hosting a convening in Washington, D.C. a few years ago in March 2018, and to raise awareness to fight human trafficking as a public health issue. In addition, throughout 2021, Jones Day co-sponsored virtual convenings on expanding hospital leadership in the fight against human trafficking. This particular convening focusing on labor trafficking in the healthcare supply chain was a natural outgrowth of that previous work.

Dave Dalton:

Taylor, as I think about it... And Jones Day has done so much work in this space, anti-human trafficking, and it's been consistent and it's been impactful and it's been important, but healthcare supply chain of all things. That never would've dawned on me that this could have been a focus area. How long has the firm been attending to healthcare, specifically when it comes to anti-human trafficking needs?

Taylor Goodspeed:

I think this dated back, right, when I was saying that that 2018 convening, that was the first time that we really kind of tried to raise awareness to advance the role of hospitals, other healthcare providers in fighting it as a public health issue from the provider side, given with their interactions with victims of human trafficking. It's been a couple years now, I'm recognizing, and we've had the great honor and pleasure to work alongside the American Hospital Association, HEAL Trafficking through our various events over... Since really 2017, 2018.

Dave Dalton:

Let's go over to Laura Castellanos. Talk to me a little bit about your perceptions of the November event. Talk about how you reacted, what you liked, what you saw. Give us some of your impressions.

Laura Castellanos:

Absolutely. Thanks, Dave. And I'll just start where Taylor finished and that's... This was a natural outgrowth of the work that we've been doing together in partnership with Jones Day and HEAL Trafficking. It was important for us to really rely on our partners to understand where the needs and where the gaps perhaps were in regards to how we informed the healthcare field. So it was actually through our partnerships, through our work in understanding that they wanted to learn more, we all needed to understand what the field was experiencing. The American Hospital Association engages our members in these discussions, and later on you'll hear from heart of the AHA, which is our AHRMM colleagues, our supply chain professionals, and engaging those professionals in these solutions as well.

So my takeaway from the convening was we are a very strong community. We really rely on each other to understand more around the issue. So we're just glad that this partnership creates spaces, it creates dialogues that then inform the tools and the resources that impacts lives. It save lives. So it's just been wonderful to see how far we've come, and it's wonderful to know that we continue these efforts.

Dave Dalton:

Absolutely. Let's go back to Taylor for a second. Taylor, when you and I were preparing for this, you talked about it being an extension of pro bono and the hours that Jones Day lawyers put into this project. Talk about how different practices worked on this. I guess the mechanics of pulling off an event like that convening. How did the firm get this done behind the scenes?

Taylor Goodspeed:

Well, I always have to thank the number of different associates who work across different offices who worked to make this a success. And I will also note that in connection with this convening, Jones Day also published a white paper that kind of advanced certain topics. And so not only did we have the event itself, which I would call out Dana Molt, Theresa Cross, and a number of other associates locally in the Chicago office, but also a number of healthcare associates and others worked to help on that white paper as a publication alongside it. It just shows you the commitment across practice groups, offices to our pro bono efforts across the firm.

Dave Dalton:

Sure. And you mentioned that white paper, and there will be a link to that white paper. And Taylor, back to your point, I guess you look at the white paper, you look at other events, you look at events we've had at offices across the Jones Day system, this convening was not a one-off. This is something the firm has been persistent and taken very seriously for years. So I think all the hard work that you and your team have done behind the scenes is to be commended. Let's shift focus a little bit. We're going to talk to Laura Kowalczyk, who we introduced you to a minute ago. She's a healthcare leader and board member at the Association for Healthcare Resources and Materials Management. Talk about your motivation and your organization's motivation for having you there, Laura.

Laura Kowalczyk:

Well, I'll talk first about my own personal motivation and having spent some years in a legal role in a different setting, but having sex trafficking really touch on some pro bono work I did myself, I've always been interested in this topic. But I will tell you recently the University of Alabama, Birmingham here where I am and I'm a healthcare supply chain leader, was asked by the World Games to host both the supply chain and medical side of those games. And I will tell you, there's a very robust education and discussion around forced labor really relative to those games. And so when this topic came up and my peers over on the AHRMM board and staff reached out to me and said, "Hey, would you be interested in attending this discussion?" I thought, wow, absolutely. This is in my own backyard. This topic hits what I've been doing for over 20 years in healthcare supply chain.

And I have to admit to you that my awareness level really was not... And clearly after the convening, was not at the level that it needed to be, particularly in my role over a very large healthcare supply chain here in the southeast region. So I also, as a member of the AHRMM board, just felt that it was important if... That is a great vehicle for getting this messaging out to a very large contingency of healthcare supply chain leaders from all sectors of the industry, whether it's manufacturing suppliers, distributors, group purchasing. We convene together once a year, and I'm excited that this topic is going to be out there for all of our members to start learning and becoming more aware, and we need a discussion on what we need to do in our frontline worlds to help address this issue across our supply chains.

Dave Dalton:

Sure. Sure. Laura, I've done several podcasts, anti-human trafficking, and I've been involved in some of the publications as well. And I've got to admit, my first reaction was, "Really? We're still dealing with this?" And I know that sounds naive, it certainly does now, but are you disappointed that this is still such a front burner issue after all the... I mean, people have known about this, I've known about it since I was a kid. Are we making progress, Laura?

Laura Kowalczyk:

I don't know that I can answer whether we're making progress. The other individuals that are on the call might be better to answer that question. But what I will say to you is what a eye-opening experience to have this discussion at the convening. And I want to point out that we did have a very, very impressive woman who was a victim come speak to us, and it was tremendously impactful to me. And to think that my role in the supply chain really does not have this in the forefront of our consideration, particularly I will say post pandemic and what we experienced just in how and the ways that we had to get PPE and other supplies and continue, quite frankly, in this supply disruption. I really have to tell you that I'm saddened to say that I too needed a good healthy education on this. So I've got to believe, and after talking to a number of my peers after the convening, we all need to have some discussion more about how we can put this again in the forefront of our procurement sourcing as we go forward.

Dave Dalton:

Sure. Sure. Laura, one more thing, then we'll move over to Hanni Stoklosa for a second. You said you were at an event where you heard a victim, someone who's been rescued from the situation, but what was that like hearing firsthand what she went through?

Laura Kowalczyk:

Well, for me it was very... We know these things occur, but when you hear it from the individual who's the actual victim and the detail that she spoke to us about... And actually her circumstances were such that I don't know that we even think of trafficking in the realm, in the labor realm that she was involved in. And I just have to mention, it's well known in our healthcare world that we have had to bring in many travelers and other contract employees into our health systems just to keep them running during and post... Really more post Covid. And honestly, we were looking, at my facility, at bringing in international travelers, and I will tell you, as a result of some of the allegations against one particular company for this type of trafficking, we immediately halted that involvement with that company.

So her impact for me was, it seems so subtle. You've got to pay attention. And if you listen to her... And we're all in healthcare here, we may not be frontline clinicians, but if we listen, we will hear it. And hers was really insidious and subtle, but thank goodness for an individual who just saw that something appeared to be off and spoke up.

Dave Dalton:

Absolutely. And of course. Let's move over to Hanni Stoklosa for a second. Hanni, thank you again for being here today. I wanted to talk about takeaways from the November convening. What were some of your takeaways or what you came away with in terms of, "That made a difference? I learned something." What was key for you after the event, Hanni?

Hanni Stoklosa:

How long do you have?

Dave Dalton:

Oh, I'm on East Coast time. I forgot where you guys are, but now that was sort of a little too open-ended, wasn't it? But maybe you could hit some high points for us.

Hanni Stoklosa:

My pleasure. I left feeling both inspired and ignited, is how I would characterize it. Inspired seeing the diversity of expertise that we were able to bring to the table to really speak into the issue of forced labor and supply chains, including as Laura mentioned, Angela Guzmán and legal colleagues, colleagues from the federal government, healthcare executives, and recognizing that there is nothing that we cannot together tackle. And it really requires that multidisciplinary perspective because there is a lot of work to do. We talked about the context and the history of our work together, American Hospital Association and Jones Day, and also just environmentally HEAL is hearing from our network that those that are champions in health systems need the resources that we were talking about and that we are also co-creating together. December 2021, the White House released their national action plan to combat human trafficking, which includes specifically the need to address forced labor in supply chains.

And that's another piece in sort of the greater environmental context where health systems are waking up to this issue. For me, an underlining, one of the things that Taylor led with many times when people think about forced labor in supply chains, that sounds like we're talking about goods, like we're talking about the things that go into a Foley catheter or the linens in a health system, but rarely do we think about the people and the recruitment processes, whether they're from third parties, et cetera, as part of that. And so having that balance in the conversation was one of the things that was vital and underlined, and it was so powerful to hear from Angela Guzmán. She is a trafficking survivor and had been forced to work as an assistant in an elder care facility. There was actually just today released by the Office of Trafficking in Persons a memo on federal cases involving forced labor of health professionals.

And so her situation there mirrors what we see among forced labor of doctors, physical therapists, clinical research assistants, and other care providers. So that was thing number one, really making sure that we're having the conversation that covers goods and services. And then what we heard from healthcare leaders, those that are doing the supply chain work, is that they need more tools and resources to do the work. They're figuring out as they go along. We're looking to other industries to understand best practices as we're all learning together and just really thinking about that in the context of all of the other things that are happening in the healthcare environment, whether we're talking about the strains on human resources that Laura mentioned from the COVID-19 pandemic and in the current status of labor in healthcare and managing other costs that health systems are balancing along with compliance so that we're doing the right thing.

And then I'll just add, there were a number of cases that we heard of as we're thinking about goods that are brought into the country and concerns about forced labor happening in the supply chains overseas. But we also know that forced labor can happen in domestic healthcare supply chains as well. So there was a quote from one of the participants where they said that together we can move the marketplace and shift practices to do the right thing, but we need to act together. And that really stuck with me.

Dave Dalton:

Before we go back to Laura Kowalczyk, I have another question for you, Hanni. You said the effort requires more resources. What does that look like? Is it money? Is it tech? Is it personnel? How do you envision that? What's that mean?

Hanni Stoklosa:

So I would say all of the above, first of all, and what we're hearing from healthcare leaders is really practical tools. How do we make sure that we are doing the right thing and also being compliant and not reinventing the wheel? How can we best learn from, as I mentioned, other industries in this process? But this is complicated. There's a lot of layers to supply chains, and it's really hard to understand where sourced goods are coming from in many cases. And so how do we group together and share information so that we're best able to make sure that no one is hurt in our providing of healthcare in the United States, and no one is forced to be in a labor trafficking situation as a result of us caring for patients here in the US?

Dave Dalton:

A lot of layers, as you said, and extraordinarily complicated. Let's go back to Laura Kowalczyk. Your takeaways from the November convening. What sticks out for you?

Laura Kowalczyk:

There are several. I mean, one is just flat out awareness. Hanni just said it. It's not just an international problem. Also, it is clearly happening in the US and may even be happening in our own backyards in our own states. And that was impactful to me. There are also... Again, Hanni referenced it. As a frontline supply chain leader, our goal is always to get the caregiver, like Hanni, what she needs at the frontline most efficiently and effectively to take care of our patients. And so I would not tell you that human trafficking has really come to the forefront of our concerns as we go out and source and negotiate. And since this convening, I have had a lot of very pointed conversations with some of my biggest suppliers and asked them that question, now, what are you doing in your organizations? And when you talk about resources in the healthcare arena, particularly in the supply chain, we look heavily to our distributor partners, our manufacturing partners.

They tend to have margins a little bigger than we do on the hospital side. And so I look to them to say, what are you doing? And by the way, if we begin to mandate in our sourcing material and our contracting that you need to disclose any types of investigations around some of your suppliers... Suppliers, manufacturers, raw material, it's very deep in the upstream that they are capable of doing that. And some of the answers, quite frankly, were surprising to me. Also though, I would tell you that there are definitely many conversations happening and more and more starting to happen. And I think that's why this was so important for me to hear as someone who can attest to what happens frontline in a healthcare supply chain when you're just trying to get your supplies in, versus really stepping back and saying, you know what? Upstream, while I'm down here getting this end product, I need to consider that maybe there was a human being somewhere upstream that was not being treated appropriately and equitably. And how, at my position, do I learn that? And what are the resources available to me?

And Hanni pointed out something very important. We don't have a lot of resources, and so what I did learn from the convening was there are resources for us. We just didn't know how to tap into them, and we need to get that out to our community. And we don't have to reinvent the wheel. I think there are some other organizations out there that are really stepping into the forefront of this. And so we just need to learn from each other and again, go forward in a team thought process and mandate that our industry move in this direction.

Dave Dalton:

Sure. Teamwork, collaboration, communication, working together, all that I'm sure is so vital in a situation like this. And Laura, I've got to tell you, you might have a future in podcasting because you gave me a great segue to our next point I wanted to bring over to Laura Castellanos. There are resources available now that maybe haven't been utilized enough that maybe people aren't aware of, but there are existing resources that the convening identified for hospital leaders to leverage against human trafficking. Can you talk about those for a minute?

Laura Castellanos:

Sure. Absolutely. Great segue, Laura, and for someone who was part of the planning and the work around the convening, it's so heartwarming truly to hear the impact it has had on her personal interest and investment in this work, but also in her practice. So thank you so much, Laura, for sharing. In regards to resource, it has become one of our priorities. It's now a coordinated, multi-pronged approach. Laura also said it, awareness, and that in itself is a substantial book of work. It's something that is ongoing and the awareness across the different spectrums and who is involved in different stakeholders and it looks differently. And also education. What AHA really does well, and we hear this from our members, is the power of convening. It's so important to bring people together to allow these spaces to begin these discussions, to then share these learnings and these resources to then hopefully allow this dialogue to continue and to continue to inform the work that we're doing back to what is already existing in regards to resources.

One of the panels that we had at the convening in November were all the different federal agencies that are doing this work, from the US Customs Border Protection looking at the publishing reports on forced labor and trade violations. And they even have an online allegation filing tool. We know that the Department of Health and Human Services is continuously publishing informational memos, Hanni referenced a report that was just published today. The US Department of State, the US Department of Labor, they're all doing great work, and we will make sure that we share a link of a blog that captures all of these resources and provides the takeaways from the convening as well.

And I'll just finish by saying that how we got here, you just said it, Dave, teamwork. This is all about teamwork and we're learning from each other and we're elevating our voices and coordinating our efforts. And it's just great to see it all laid out so nicely in this podcast. We've just met recently and we've been talking about what the future looks like and we want to continue to get this information out there. And as we continue to learn is also making sure that we keep informing the field.

Dave Dalton:

Sure. Two things, we'll have links to that information you mentioned, Laura. They'll be packaged with the podcast. This goes out so listeners can find that information easily with a link that we'll provide. Second of all, you guys are great. Another wonderful segue. We're talking about next steps, what happens next? Right? Great momentum, the white paper, the November convening, other things that AHA, their partners, Jones Day, we're all doing great, but let's talk about next steps and let's swing back to Taylor Goodspeed. She started this conversation, let's come back to her. Taylor, what's Jones Day thinking about next?

Taylor Goodspeed:

Hanni framed it well, it's of course an interdisciplinary effort. As we are pulling together the white paper, there's going to be a continued need to monitor the legal landscape for developments. Our white paper really looked at legislation, executive action with an overlay of the COVID-19 pandemic, and the landscape continues to change, whether it be in the civil space, criminal enforcement, all of this is informed by the legal framework that continues to change and be modified. Focusing on that is of course going to be a priority moving forward, and this was one of the first conversations on this topic. We anticipate hosting another convening hopefully in the near future and continuing this conversation to make sure that these resources and the conversation continues.

I also would be remiss if I didn't highlight one of the partners integral to the work on these particular projects. One of many, of course, but Bethany Biesenthal, we've had the great pleasure of working with and who was integral to both the convening the white paper. She was actually previously the head of the human trafficking section at the US Attorney's Office. She now serves as Jones Day's lead for global human trafficking related litigation. And I've had the great pleasure to get to work with her and learn from her as we work on these convenings and work on these white papers and being able to kind of monitor the legal landscape over time. So I just wanted to point that out and then her involvement will be critical as we move forward.

Dave Dalton:

Absolutely. And Taylor, you've got a blank check here, so if you ever want to bring her on for a program, maybe early summer or something, if they're developments, we'd love to talk to her. Let's go to Laura Kowalczyk. Rumor has that AHRMM might run a convening later this year, maybe late in the summer. Progress there? Or is that in the early planning stages? What might be happening?

Laura Kowalczyk:

No, we've made a lot of progress. So our AHRMM conference... Call it AHRMM, Dave. Our AHRMM conference is in August of this year in Orlando, Florida. We are planning on really bringing this topic to one of our general sessions. Those are our large sessions. Those are typically the ones where we grab folks in the morning and it's a large... Probably can be upwards of 500 people, depending. So I'm excited. I think we're looking at potentially a panel discussion, which I think I've got the panel sitting right here.

There'll just be a lot of Laura Kowalczyk there also that can contribute even more than I, but really, I'm excited about it. We took this and we ran with it, and we see it as critically important to bring to our membership. So I'm really excited.

Dave Dalton:

Well, that's terrific. I've got to apologize. I've been struggling with AHRMM. I could have just been saying AHRMM, right?

Laura Kowalczyk:

That's right. It's very easy.

Dave Dalton:

I'm sorry. You knew you were in good hands, right?

Laura Kowalczyk:

Yes, I did.

Dave Dalton:

So anyway, so apologize for making it too difficult. Okay, let's go back to Laura. Laura, please talk... I know Human Trafficking Awareness month, every January. What kind of events typically happen or what happens in January every year?

Laura Castellanos:

Absolutely, it... There's a lot going on. All these wonderful organizations, our community really is empowered and voices are rising to really create awareness around this issue. So we see digital campaigns being published from social media digital toolkits, to infographics to new reports, new data to movement, and we take the opportunity to really come together. One of the things that we do at the AHA, and we've done it in partnership with Jones Day and HEAL, is publish our own digital toolkit. And it references a lot of great tools that we've either been a part of co-creating or want to make sure that the field is aware, the things that we do, as well as really making sure that folks are learning from what other hospitals and health systems are doing as we are seeing an increased interest in developing these response programs.

Oftentimes these programs that we're seeing are this one person. It's someone with an interest, with a commitment, and we want to make sure that we're giving them a space to share their stories so we can continue to do that learning. January is an important month for our community, but it doesn't ever stop there. The work is definitely ongoing.

Dave Dalton:

Sure, sure. And I didn't mean to short change ongoing efforts by focusing on January, but I had a note here and I thought I'd better mention so people know because that rolls around every year. We can really shine a spotlight on these such important issues. Let's go back to Hanni. Talk about next steps where you're concerned. What are you looking for next?

Hanni Stoklosa:

What we heard at the convening is the need for resources. And as we've mentioned, there are a lot of resources that healthcare executives may not be aware of and can plug into. And we're going to provide those links. And then also we heard from Taylor about the constantly changing dynamic landscape that we're in and the need for this group to have a finger on that pulse so that we can transmit it to the larger healthcare community. So on behalf of the trifecta of HEAL Trafficking and American Hospital Association and Jones Day, we promise you, we're going to continue to bridge that resource gap between providers and the agencies who fight this issue every day on the national level and continue to raise that vital awareness among providers and the executives at healthcare systems so they can advocate for this needed change in their own supply chain. So really excited for what is to come as we continue to help bridge that gap collectively.

Dave Dalton:

Hanni, well said. I had a note here too, and I think someone brought it up earlier in this conversation, the Biden administration's National Action Plan to Combat Human Trafficking. Is that something that's enforced right now? Is that a proposal? Is that something that's coming, or what can you tell us about that? That sounds about the highest level you can get straight from the White House. What should we know about that?

Hanni Stoklosa:

Well, what's beautiful about it is that it is coming from the highest levels, right? That this is... It's basically stating priorities from the White House, that issues of forced labor and supply chains are of great importance. And what we are seeing is the federal government then really approaching this from multiple federal agency perspective. So our hope is that that will translate to continued engagement on this issue, and we've certainly seen that. And then of course, from within this group, translating what we're seeing from the federal government to healthcare executives.

Dave Dalton:

Hey, great conversation today. What representation to the AHA, HEAL, Jones Day, AHRMM. Great panel. I want to thank everybody. Taylor, thanks for coordinating this. You were great. Laura, Laura, Hanni, you guys are terrific. I said it before, you got a blank check with us anytime. We think this podcast was great. We think it's going to do great in terms of reach, getting your efforts out and known. So thanks so much for spending some time today.

Hanni Stoklosa:

Thank you.

Laura Castellanos:

Thank you.

Laura Kowalczyk:

Thank you.

Taylor Goodspeed:

Thanks, Dave.

Dave Dalton:

Hey, before we sign off, a quick thank you to Jones Day associate Theresa Cross. She did so much of the heavy lifting to get this podcast recording across the finish line, scheduling, coordinating, research, and more. Thanks so much. To learn more about Jones Day's anti-human trafficking work, please visit our pro bono page at jonesday.com. Subscribe at Apple Podcast and other podcast sources. JONES DAY TALKS® is produced by Tom Kondilas. As always, we thank you for listening. I'm Dave Dalton. We'll talk to you next time.

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