In August 2025, Brazil’s labour court ordered Volkswagen to pay over USD $30 million in damages in connection with systematic forced labour at a company farm during the period of Brazil’s dictatorship in the 1970s and 1980s.

VW has indicated they will appeal the decision, stating that it has “consistently defended the principles of human dignity and strictly complied with all applicable labor laws and regulations.”

The court heard that about 300 workers were hired to clear forest and prepare farmland between 1974 and 1986 at a farm in Para state, owned by Volkswagen through a subsidiary. The farm was used for cattle ranching and logging. The workers were hired on irregular contracts that created relations of debt bondage, which forced them to stay on the farm. They worked under surveillance of armed guards, while living in poor housing conditions and receiving insufficient food. No medical care was provided, and malaria was common.

The Labor Prosecutor’s Office launched an investigation in 2019, drawing on documentation that tracked the operations for many years. Based on documentation gathered by a local priest, and witness testimony, prosecutors formally charged Volkswagen in 2024.

Volkswagen faces historic $30 million compensation for Amazon labor abuses in Brazil, Gabriela Sa Pessoa, August 30, 2025

Volkswagen’s Dark History in Brazil, Dirk Kaufman, 16 June 2025

In 1996, the US oil company Unocal was sued in the United States and settled out of court for the alleged use of forced labour organised by the Burmese government prior to the construction of an oil pipeline.

Plaintiffs were a group of Burmese citizens who were allegedly forced to perform labor for the benefit of the Yadana Gas Pipeline Project, in which Unocal was a joint venture partner with the military government. Several of the Doe Plaintiffs also claimed they suffered abuses that included sexual assaults by military officials hired to provide “security” to the pipeline project, as well as forcible dislocation from their homes, and murder.

In their 1996 lawsuit, plaintiffs alleged the deaths of family members, assaults, rapes, forced labor, and the loss of their homes and property at the hands of Burmese military leadership, the State Law and Order Restoration Council (SLORC). On several occasions SLORC soldiers allegedly entered area villages to either force relocation of the residents or to recruit individuals into serving as “porters” for the performance of various menial tasks. Soldiers allegedly arrested, beat or executed individuals who were unwilling or physically unable to perform the assigned tasks, as well as attacking family members of those targeted for forced labor.

The Plaintiffs alleged that the conduct of the SLORC officials and their association with the defendants’ business activities amounted to the following violations of international and national law:

Violation of Racketeer Influenced and Corrupt Organizations (RICO) Act; Forced Labor; Crimes Against Humanity (killing, rape and other torture, beatings, and other assaults); torture; arbitrary arrest and detention; cruel, inhuman, or degrading treatment

These harms were alleged as torts of wrongful death, battery, false imprisonment, assault, intentional infliction of emotional distress, negligent infliction of emotional distress, negligence per se, negligent hiring, negligent supervision.

In December 2004, in a joint statement, the two sides said that Unocal would pay the fifteen plaintiffs an unspecified amount of money and fund programs to improve living conditions for people affected by the pipeline, as well as those “who may have suffered hardships”.

In August 2000, a US court granted Unocal’s motion for summary judgment dismissing all claims against the company. The U.S. Court of Appeals for the Ninth Circuit reversed that decision, finding that plaintiffs had proffered evidence that Unocal and its co-venturers knowingly participated in using forced labor and committing other human rights violations by providing financial and material support to the military security forces, and that these acts were sufficient to constitute “aiding and abetting” under both international and domestic law. On February 12, 2003, the Ninth Circuit vacated the Ninth Circuit Court of Appeals decision, and granted an en banc review. The case was ultimately settled out of court in 2004.

Sources:

Federal Complaint, John Doe I et al v. Unocal Corp et al 6/7/02 BC 237 980 (county of LA Sup Ct.);

John Doe I et al v. Unocal Corp DC Case No. 00-56603; 00-56628 (9th Cir. 2002)

Case summary, Earthrights

In the wake of World War II, courts in the Allied occupation zones prosecuted senior German industrialists for their active participation in a system of forced labour and slavery established to exploit prisoners of war and inmates in concentration camps.

Directors and officers of three companies, Krupp AG, I. G. Farben, and Flick Holding Company faced charges of ‘slave labor’. In practice this meant charges of war crimes and crimes against humanity often based on the same or related facts. The evidence gathered by the prosecution described a vast system of forced labour, both within Germany and throughout the territories it occupied, which was geared towards sustaining the German war economy and at the same time was integrated to the Nazi policy of genocide through work and murder in concentration camps.

The language of the indictments of these companies resembled that used with respect to I. G. Farben, which state the following:

‘It is alleged that they participated in the enslavement and deportation to slave labor of the civilian population of territory under the belligerent occupation or otherwise controlled by Germany; the enslavement of concentration-camp inmates, including Germans; and the use of prisoners of war in war operations and work having a direct relation to war operations. It is further alleged that the enslaved persons were mistreated, terrorized, tortured, and murdered.”

Farben was shown to have a close connection to the use of slave labour, based upon the close relationship between the establishment and operation of the Auschwitz/Birkenau concentration camp and Farben factories established nearby. Prisoners of war were employed in construction work at the Farben and evidence was presented that management actively sought from the Reich Labour Program concentration camp inmates, as well as Russian and Polish forced labourers.

“These workers were not forced on Farben. We are convinced beyond a reasonable doubt that the officials in charge of Farben construction went beyond the necessity created by the pressure of governmental officials and may be justly charged with taking the initiative in planning for and availing themselves of the use of concentration-camp labor.’

Forced labour was widespread and included forced work in German industrial facilities:

“The evidence showed that workers destined for the Reich were sent under guard to Germany, often packed in trains without adequate heat, food, clothing or sanitary facilities. The evidence further showed that the treatment of the labourers in Germany in many cases was brutal and degrading. The evidence relating to the Krupp Works at Essen showed that punishments of the most cruel kind were inflicted on the workers.”

Forced labour was not limited to industrial work:

“In the case of Poles employed on farms in Germany, the employers were given authority to inflict corporal punishment and were ordered, if possible, to house them…in stables, not in their own homes. They were subject to constant supervision by the Gestapo and the SS, and if they attempted to leave their jobs they were sent to correction camps or concentration camps. The concentration camps were also used to increase the supply of labour. Concentration camp commanders were ordered to work their prisoners to the limits of their physical power.”

The Nazi system of forced labour generated a significant amount of bureaucracy. The subsequent tribunal sitting in judgment in the case of U.S.A v. Erhard Milch described the bureaucracy as a cover for exploitative and murderous intent:

“It was sought to disguise the harsh realities of the German Foreign labour policy by the use of specious legal and economic terms, and to make such policy appear as the exercise of conventional labour relations and labour law. The fiction of a‘labour contract’ was frequently resorted to …which implied that foreign workers were given a free choice to work or not to work for the German military industry. This, of course, was purely fictitious, as is shown by the fact that thousands of these ‘contract workers’ jumped from the trains transporting them to Germany and fled into the woods. Does anyone believe that the vast hordes of Slavic Jews who laboured in Germany’s war industries were accorded the rights of contracting parties? They were slaves, nothing less– kidnapped, regimented, herded under armed guards, and worked until they died from disease, hunger, exhaustion. The idea of any Jew being a party to the contract with the Germans was unthinkable to the National Socialists. Jews were considered as outcasts and were completely at the mercy of their oppressors. Exploitation was merely a convenient and profitable means of extermination…” (Trial of Erhard Milch, Case No. 39, Law Reports of Trials of War Criminals, Vol. 7 at 27 (United States Military Tribunal, 17 April 1947)

At the International Military Tribunal (IMT) and subsequent trials, as well as at the trials of Japanese war criminals in Tokyo, the tribunals used the terms forced labour and slavery interchangeably to refer to the prohibition against forced labour as a war crime and the crime against humanity of ‘enslavement’. However, the legal tests for forced labour and slavery/enslavement are different. The essence of the prohibition against forced labour is whether or not the work had been voluntary or coerced (or the rendering of consent impossible through threat or use of violence or some other form of coercion); whereas the test for enslavement is whether or not a person had been totally denied their liberty, for example that they were engaged in work on conditions that amount to a power of the perpetrator over the victim comparable to a right of ownership.

Two key elements which emerge from these trials two key elements that are the role of forced labour as part of a campaign of attack or systematic violence and coercion deployed against civilians. The second is a concern about the extent to which the labour exploitation is connected to the war operations of the perpetrators.

Sources:

USA v. Karl Krauch, p. 1167; USA v. Karl Krauch et al., Trials of the War Criminals, Before the Nuernberg Military Tribunals Under Control Council Law No. 10, Vols. VII and VIII, October 1946–April 1949 (1952).

“War Crimes of an Economic Nature - Labour Exploitation in War”, War Economies and International Law, Mark B. Taylor (Cambridge, 2021)