Modern Slavery – It’s time to stamp out exploitation

Introduction

In this blog, we cover the basics of modern slavery, including its various forms and how widespread it is globally. We’ll delve into specific stats and laws in the UK, emphasising how they affect businesses, no matter their size. You’ll also find easy-to-follow steps for assessing risks, doing your homework, and crafting a Modern Slavery Statement. Plus, we’ll share a handy checklist to help you spot signs of modern slavery, along with how Alcumus SafeContractor can lend a hand in tackling this issue.

What is modern slavery?

Modern slavery is an alarming crime that directly violates basic human rights. It involves exploiting individuals through various means, such as slavery, child labour, forced marriage, and human trafficking. Essentially, it robs individuals of their freedom for personal or commercial gain. Despite efforts, it remains a significant global challenge, a moral and ethical issue that no one wants to be connected to.

What do the stats reveal?

• 50 million people live in modern slavery
• 28 million people are in forced labour
• Around 10,000 people in the UK are in modern slavery, according to the UK Government
• More than 100,000 people in the UK are in modern slavery, according to slavery experts (ie much more than official figures)

The UK position

Modern slavery is a reality in the UK.

Whether you’re managing a large organisation or a small business, there are important steps you can take to recognise signs of modern slavery and carry out comprehensive due diligence to fight against this exploitation. Many everyday products we purchase, like clothing or food, may have been produced through forced labour, which can be difficult to identify. The UK ranks among the leading destinations for human trafficking and forced labour in Europe. Even if your business operates solely within the UK, it’s possible to be part of a complex global supply chain.

As of 7th March 2024, the National Referral Mechanism (NRM) reported an increase in potential victims of modern slavery, with 17,000 cases referred to the Home Office in 2023, slightly higher than the 16,921 reported in 2022. This marks the highest national number reported since the NRM’s inception in 2009, with British nationals comprising the majority of reported victims in the UK.

Legal Requirements – The Modern Slavery Act 2015

If your annual turnover is £36 million or more, it is a legal obligation to create a Modern Slavery Statement and update and publish it annually on your website. The statement will need to be signed by the most senior individual in your organisation. You also have the option to register your statement with the government registry.

Further details on producing your statement will be provided later in the blog.

Is it just a big business issue?

Taking steps to prevent modern slavery isn’t only important for big businesses. Even If you have a smaller turnover, you will still feel the impact. If you supply goods and/or services to larger businesses, who assess suppliers as part of their modern slavery supply chain compliance, you’ll need to prove that you’re taking all the necessary steps to avoid modern slavery in your operations. This applies even if you’re simply looking to bid for government contracts, as demonstrating your compliance will be compulsory.

Nowadays, businesses often request pre-authorisation checks on suppliers, focusing not only on health and safety but on Modern Slavery and Environmental, Social and Governance (ESG).

Certain banks and investors may inquire about these areas to assess your business before making decisions. Implementing these processes can also showcase your company as a reputable and ethical business.

Where do I start and how can I spot the signs of Modern Slavery?

Trying to navigate compliance obligations can feel overwhelming at times, and it’s understandable if you don’t know where to start.

Whether your business is large or small, conducting a risk assessment is a crucial step before drafting a Modern Slavery Statement, whether it’s a legal requirement or voluntary to do so.

This involves assessing risks within your own business and then delving into the processes to identify potential risks within each of your suppliers. Remember, every business starts somewhere, and taking these steps is a positive move toward ensuring ethical practices in your operations.

Risk Assessment

Geography – Think about the country in which you operate or where your supply chains are located. Are there any specific areas that are known to use forced or child labour? Do these countries have legislation in place to help prevent modern slavery, along with a strong track record of upholding employment rights and health and safety standards?

Product and Service – Are you using raw materials that may be produced in high-risk areas where Modern slavery has been previously highlighted?

Type of Work – Do you mainly deal with professional services, benefiting from regulatory protections and high skill levels? Or are you dealing with hourly paid labour, where specific training or qualifications are not required?

Type of Employment –Are you working in sectors that predominately have employees on permanent contracts and a stable workforce or whether it is a high turnover, causal labour sector.

Type of Industry – For example, modern slavery is continuing to rise among the 2 million people working in construction in the UK. Some industries are more vulnerable to modern slavery, it’s worth understanding the risk of modern slavery in your business sector.

Due Diligence

Once you have identified the types of risks you could encounter, you can then begin to implement due diligence measure to demonstrate that you’ve taken steps to mitigate the risks of modern slavery in your business or supply chain. Here are some factors to consider, but keep in mind this list

isn’t exhaustive and depending on the complexities of your business or supply chains you may need to consider professional assistance.

Checklist of things to look at in your own business and supply chain

• Do all employees and supply chain partners have up to date contracts or agreements in place?
• Are there any signs of excessive working hours or cash in hand payments?
• Are all of your employees and supply chain partners compliant with the National Minimum Wage?
• Are adequate Right to Work Checks in place? A key risk factor here is inconsistencies in documents or unwillingness to show you an original ID document such as a passport could indicate that someone else is controlling their access.
• Do you have an anti-bribery policy in place?
• Do you have a Modern Slavery policy ?
• Do you have a Whistleblowing policy?
• Do you have a code of conduct in place between you and your suppliers?
• Has a senior person in your organisation taken ownership of this compliance area?
• Have policies and actions been adequately communicated to key stakeholders (employees, suppliers, subcontractors and other business partners)?
• Have you trained your employees and supply chain partners in signs to look for and how to report any suspicions?
• Do you know the level of modern slavery risk in your business and supply chains?
• Have you developed a strategy of the steps you will take if modern slavery is identified within your own business or supply chains?
• Do you conduct regular spot-checks on your suppliers or agency workers?
• Do you have appropriate risk management processes with supply chain partners to monitor that the agreed expectations and standards are being complied with?
• Do you update your employment policies regularly and keep up to date with legislation?
• Have you encountered any payroll issues ? E.g. when someone asks for a salary to be paid into someone else’s bank account or if several employees are asking for salary to be paid into the same account number this could be a sign of risk that they are forced labour.

Signs to watch out for in an employee or worker

• Watch out for an employee who always seems to be dropped off at work and collected or several employees sharing an address and being picked up as this could be an indicator that their labour is forced.
• You can also be aware of signs that despite earning money they do not seem to be well nourished or are constantly in the same clothes, they may not have control of their wages and may be housed inadequately.
• Other signs that something is not right is if an employee seems stressed or anxious when asked about family particularly if they are living apart, they may be working because their family have been threatened.

How do I create a Modern Slavery Statement?

Once you’ve identified the sort of risks you’re up against and put in place your plan to tackle those risks the next step would be to draft your Modern Slavery Statement. These statements are usually published on websites, so it’s helpful to check out what others have included before you begin. You can view the Alcumus Statement here. Whilst there isn’t a particular format, Home Office guidance requires your statement to include the following;

• Details of your organisations structure and any supply chains you are involved with
• State the policies in place in relation to Modern slavery and human trafficking
• Explain your due diligence process
• Explain how you risk assessed and how you will manage the mitigation you have put in place
• Detail how you will measure the effectiveness of the polices you have put in place
• Demonstrate how you are training people on modern slavery and human trafficking

Where can I get help with this?

• Alcumus SafeContractor is ready to help with all the tasks mentioned above. Additionally, we partner with organisations like the Supply Chain Sustainability School and Slave Free Alliance, offering various training, workshops, courses, and resources to support your efforts. For any sized business, we can help you create a Modern Slavery statement and policy and communicate this with the whole organisation and supply chain.
• Provide training and workshops to educate and upskill supply partners so they can confidently identify and report any instances of unethical labour practices.
• As a larger organisation ensure you only source and work with compliant contractors and suppliers. Ensure you have full visibility of your supply chain so you can identify partners who are/ who are not compliant.
• As a supplier or contractor gain accreditation or verification to demonstrate your commitment to compliance.

If you are a hiring client and would like to learn more about the Alcumus SafeContractor solution click here.  

Sources:

• Modern slavery in construction is on the rise
• Modern Slavery: NRM and DtN statistics, end of year summary 2023 – GOV.UK (www.gov.uk)
• Modern Slavery: Facts and figures