The National Crime Agency (NCA) has announced that modern slavery in the UK is ‘far more prevalent than previously thought’. However, these estimates reflect only the number of live police investigations. The challenge for businesses will be to ensure their UK operations are not implicated in the ‘tens of thousands’ of cases which the NCA believes remain uninvestigated.
Although modern slavery is often a hidden crime in the UK, there are practical steps that companies can take to ensure that systemic risks do not go unassessed and everyday signs undetected.
A study published recently by Maplecroft found that modern slavery risks had increased in 20 EU countries, including the UK, as a direct result of the increased numbers of vulnerable migrants arriving in search of a better life. Recent high-profile trials have demonstrated how these workers can be exploited and trafficked into jobs at British companies, through legitimate recruitment agencies, without the knowledge of either.
Sports Direct, the UK’s largest sports retailer, was named in three separate modern slavery trials this year, each of which related to different criminal gangs who used recruitment agencies to send Polish victims of trafficking to work at the company’s Shirebrook warehouse, before depriving them of their wages. Speaking little English, they were unable to communicate their situation to others at work, who therefore remained unaware.
After nearly two years at Sports Direct, one victim was transferred by his traffickers to another agency who sent him to work at Hammond Produce, a smaller family-owned business supplying vegetables to UK supermarkets. There he worked 12-hour shifts and walked an hour each way to and from work, leaving him too tired to eat.
These cases show that modern slavery is affecting UK companies both large and small. All British businesses therefore need to ensure that they know how modern slavery operates, can recognise the signs and are taking practical steps to prevent it from happening:
1. Training and awareness-raising – Businesses need to be aware of their modern slavery risks and ensure that their workforce is properly trained to recognise the signs and bring them to management attention. This applies particularly to those with a large workforce comprising migrant or low-skilled employees. Following the trial, Hammond Produce reflected on the signs of modern slavery which went un-noticed: missing lunches, constant demands for overtime, scruffy workers. The company now uses posters in multiple languages around their site, advising staff on how to recognise and report possible labour abuses.
2. Whistleblowing – An effective whistleblowing system would have allowed stakeholders in and around both companies to express their concerns in confidence and without fear of reprisal. Systems like these encourage colleagues, concerned members of the public, or even victims themselves to come forward with essential information if they wish.
3. Multi-lingual terms of employment – Employees are entitled to receive clear contracts of employment with working hours, breaks, pay, rest periods, overtime and leave entitlement that meet international standards expressed in a language they understand. If victims are reminded of their rights in their native language, this may encourage them to speak out about entitlements they are not receiving.
4. Transparent procurement of labour – In both cases, the supply of labour passed through traffickers abroad, to criminal gangs in the UK, to third-party recruitment agencies, before employees even set foot on site, leading to a lack of clarity and a diffusion of responsibility which can allow exploitation to continue unaddressed. Companies should use their buying-power and contracts to ensure they only procure labour from agencies which actively check for and guard against unacceptable employment practices.
It is through practical steps like these, all of which are codified in the GoodCorporation Frameworks on Labour Rights and the Corporate Responsibility to Respect Human Rights, that companies can ensure they are properly protected from this growing problem and proactively engaged in mitigating any risks.
Posted August 2016
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