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Behind Closed Doors – Print – Issue 206 – December 2021 | Article of the Week

Modern slavery is often described as an ‘unseen crime’ because it can be hard to spot. Many of us will have unwittingly come into contact with victims ‘working’ in takeaways, hotels, carwashes and nail bars. The exploitation will be happening in many supply chains and there is a moral imperative for businesses to look into these issues. This is a pressing issue, but it is not a simple task. As a starting point, it is important to think about what modern slavery is.

Modern slavery is often described as an ‘unseen crime’ because it can be hard to spot. Many of us will have unwittingly come into contact with victims ‘working’ in takeaways, hotels, carwashes and nail bars. The exploitation will be happening in many supply chains and there is a moral imperative for businesses to look into these issues. This is a pressing issue, but it is not a simple task. As a starting point, it is important to think about what modern slavery is.

The Metropolitan Police describes modern slavery as “the illegal exploitation of people for personal or commercial gain.” Modern slavery takes many forms including; sexual exploitation, domestic servitude, forced labour and criminal exploitation. Control can be physical, financial or psychological. Forced labour, where victims are forced to work against their will, can happen in many sectors. Victims often work long hours in unpleasant conditions for little or no pay due to the threat of violence against them or their families. Victims may also be controlled by debt bondage, where they are forced to work to pay off a debt. Modern slavery victims can be any gender, race or age and the Modern Slavery Helpline points out, that although victims come from across the population, modern slavery is more prevalent amongst the most vulnerable, minority or socially excluded groups.

Figures from the Office for National Statistics show an increase in victims of modern slavery in the UK. There were 5,144 modern slavery offences recorded by the police in England and Wales in the year ending March 2019, an increase of 51 percent from the previous year. The number of potential victims referred through the UK National Referral Mechanism (NRM) increased by 36 percent to 6,985 in the year ending December 2018. The Modern Slavery Helpline received a 68 percent increase in calls and submissions in the year ending December 2018, compared with the previous year. Greater awareness of modern slavery along with more reporting and improvements in police recording, are likely to have contributed to this increase, since the introduction of the Modern Slavery Acts across the UK in 2015, but it is clear to see this is a growing issue. Spotting the signs of modern slavery is difficult, because it often requires concerted effort over time. Signs can include people being under the control of others and being reluctant to interact, having few personal possessions and wearing the same clothes. Other signs include people lacking personal identification, always being dropped off and collected in the same way and living on site in overcrowded, poor quality accommodation.

Mitigating against modern slavery requires an extensive and ongoing due diligence. Businesses must examine their supply chains, ideally by sending people in person to meet with suppliers. Having a robust risk assessment process to understand the areas at most risk of abuse in the supply chain is essential. Ensuring that suppliers are complying with their legal, financial and social obligations is a good starting point and there are other steps that employers can take in the UK, to verify the strength of their supply chains. This includes amending contracts to require suppliers to comply with specific modern slavery obligations, ensuring these obligations cascade through supply chain contracts and monitoring compliance. Terminating or suspending contracts where there are breaches is a powerful and necessary message to send to suppliers. In complex and high-risk supply chains, it may be worthwhile seeking external, specialist support to carry out assessments.

Not surprisingly, the pandemic has created more risks of modern slavery, particularly in high demand sectors that have had to recruit quickly. The pressures in some areas may mean that recruiters and agencies have not followed stringent checks and processes. In light of this, when reviewing the supply chain, it is important to spot suppliers where there is a significant increase in recruitment of temporary labour and, in such cases, exercise extra due diligence. In all circumstances, if anything is found that is of concern, action must take place. The longer and more complicated a supply chain the greater the risk as margins come under greater pressure. Having risk assessed and acted on the assessment, it is imperative that there are periodic reviews of the assessment to ensure that it remains valid. Questions to consider include, are suppliers following through on their commitments? Are there effective grievance mechanisms in place? In some instances, auditing and monitoring on the ground, by visiting suppliers and meeting their workforce, will be prudent. How frequently specific areas will need to be reviewed will depend on the business sector and the level of risk identified. Staff training is also an important way to mitigate against modern slavery by generating awareness across your organisation of the issue and how to spot the signs.

Where risks are identified, it is important to work with suppliers to mitigate those risks and ensure that the risk does not develop into a problem. There needs to be time bound commitments and clear milestones to be achieved and, if there are weak areas identified in management systems, they should be considered and remedied. It is important that when considering risk, an holistic approach is taken and undue reliance is not placed upon a single magic bullet that will prevent modern slavery. The whole engagement process needs to be considered. Larger businesses – with a turnover of more than £36 million – have an obligation to publish a Modern Slavery Act statement each year, to report on the steps they are taking to eliminate modern slavery. However, all businesses cannot afford to ignore the issue, as consumers become increasingly aware.

Looking to the future, it is clear that we can expect further Government action. In 2019 the Government commenced a consultation on reform to the Modern Slavery Act regime and it published its response to that consultation in September 2020. It commits the Government to “an ambitious package of measures to strengthen and future proof the Modern Slavery Act’s transparency legislation.” This includes requiring Modern Slavery Act statements to cover mandatory areas and will be, as a minimum, the current voluntary areas. The Government will consider how additional topics may be included and it said that it will publish guidance to highlight the importance of transparency, risk-based action and industry level challenges and best practice approaches to reporting. There will be a requirement to publish on a Government portal and there will be a single reporting deadline (30 September). Reporting will be over a defined period (1 April – 31 March). Modern Slavery Act statements will have to include the date of approval by the board and be signed off by a director. For groups, the Modern Slavery Act statements will have to name the entities covered by the Statement. Public Bodies will also be required to report on Modern Slavery. The Government has also indicated that it will consider enforcement options further. The criminals behind modern slavery and human trafficking networks are quick to adapt and exploit the most vulnerable. As such, it is not enough to prepare a modern slavery report once a year and leave it in a drawer. Businesses need to continue to look out for the signs of modern slavery in their supply chains and take action. This issue will not go away soon, but companies can play a key role in helping to tackle it.


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