Best Buy’s Supplier Code of Conduct says its suppliers must ensure Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Best Buy’s 2021 Environmental Social and Governance Report explains that these principles are aligned with the United Nations Guiding Principles on Business and Human Rights. Nonetheless, Best Buy’s existing standards and disclosures fail to address an issue affecting reputational and financial risks and human rights concerns. Supply chain disruptions are major challenges facing retailers amid the COVID-19 pandemic. Exacerbating this is the fact some of the trucking companies used by retailers may misclassify their drivers as independent contractors rather than employees. Retailers using these companies can be directly liable for those companies’ violations. It is illegal for a company to misclassify workers as self-employed independent contractors if the company controls the manner and means of work, sets hours and wages, and otherwise treats them as employees, who are entitled to a minimum wage, overtime pay protections, and other benefits and rights guaranteed employees under law. The forgone wages amount to wage theft. Misclassification is a significant problem as some trucking companies misclassify drivers hauling goods from U.S. ports. Following an award-winning, investigative series by USA Today, the paper’s editorial board compared exploitive independent contractor arrangements at southern California ports to modern day ... indentured servitude, prompting four U.S. Senators to demand major retailers cut ties with trucking companies showing such a brazen disregard for ... workers’ safety and rights. The southern California ports process 40% of all U.S. shipping container traffic. The California Labor Commissioner’s office has over the past decade awarded more than $50 million to misclassified port drivers. According to a 2014 report by the National Employment Law Project, the Californian port trucking industry is potentially liable for $850 million in wage theft each year from misclassification. (https:// www.nelp.org/ wp-content/uploads/2015/03/Big- Rig-OverhaulMisclassification-Port-Truck-Drivers-Labor-LawEnforcement.pdf) Misclassification risk extends to retailers, given recent Californian legislation. A 2021 law, SB 338, indicates there could be 16,000 misclassified drivers in California’s ports and calls this largely immigrant workforce the last American sharecroppers. The law makes customers of port trucking companies jointly liable for future violations of labor, employment, and health and safety law by a trucking company that the California Labor Commissioner’s office has publicly identified as having previously violated these laws.