Tackling Modern Slavery

A recent BBC expose has found several victims of modern slavery working at a McDonald’s chain in Cambridge as well as a factory supplying six major UK supermarkets. This has proved what may have seemed inconceivable to most businesses in this modern-day world to be a real problem, even in the UK. Although some industries are more susceptible to modern slavery exploitation, (i.e. construction, warehouse and manufacturing), it does not mean other industries are safe. No matter the size of your business, if you employ staff, you must remain vigilant when it comes to modern slavery.

Some of the common indicators that may suggest an individual is being exploited by slavery include:

Physical signs displayed by workers

• Seeming malnourished
• Appearing fatigued
• Wearing unsuitable clothing
• Having untreated injuries

Behavioural signs displayed by workers

• Unusually shy and withdrawn
• Reluctant to interact with others
• Hesitant to answer personal questions
• Appearing to be under the control of someone else
• Appearing frightened

Other signs

• Workers sharing the same bank account
• Numerous workers sharing the same address
• Working excessive overtime
• Not appearing to be free to leave or move around their surroundings
• Being transported to and from work, sometimes as part of a large group of workers
• Not having access to their legal documents, such as their ID or passport

That’s not to say that you should automatically assume staff have fallen victim to modern slavery if they are displaying the above signs, but if you do have concerns, steps should be taken to investigate and address them.

You may find that there are no underlying issues, and your worker is just shy or wanting to keep their life private. On the other hand, it could be that the individual is experiencing problems, but they are not related to modern slavery. In the latter instance, these issues tend to become particularly obvious when there’s a change in a workers conduct or appearance, opposed to there being an issue from day one. They should also merit further action to be taken by the employer from a welfare point of view. If, however, you do find reason to believe that an individual is being exploited by modern slavery practices, then you need to be sure that your business takes the appropriate measures to help the individual.

?So, how should you tackle modern slavery concerns?

• Increase awareness within your business; if everyone (especially your line managers who have the most day-to-day interaction with staff) know what to look out for there will be less chance of cases slipping through the net.
• Ensure staff at all levels receive training on ethical employment practices and modern slavery.
• Implement a clear procedure for staff to raise any concerns or report unusual behaviour.
• Conduct right to work checks in person with your staff.
• Use reputable organisations to source staff; if you are using agency workers, you should vet their recruitment practices before engaging their services.
• Comply with Working Time Regulations and keep overtime arrangements under review.
• Pay fair wages.
• Conduct your due diligence on your supply chains to avoid your business being caught in exploitative practices.

If you would like to find out more about how we can support your workplace against modern slavery exploitation, please get in touch on 0161 926 8519 or [email protected]