Modern Slavery in the Workplace

Modern slavery in the workplace – managing the risks should be part of your Environmental, Social, and Governance (ESG) programme.

Modern slavery in the workplace – surely it can't be in my organisation, can it? I’m a legitimate business, and I don’t use slave labour.

In fact, its shockingly easy how this could be possible.

Being honest, how robust are your management and recruitment systems? How well do they perform when matched against someone who makes exploiting vulnerable people their full-time occupation? This should give you pause for thought.

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Slavery is more prevalent today than it has been at any other point in history, with an estimated 40.3 million people in modern slavery globally today. I’d also hazard a guess that many people think that slavery is something that happens in other countries, but not in ours. However, the reality is very different, it’s happening here and now in the UK.

How does modern slavery appear in an organisation?

There are various ways that victims of modern slavery can end up in your organisation or in your supply chains without your knowledge. However, you can be prosecuted under the Modern Slavery Act 2015 even if you don’t know it’s there.

There are several ways in which modern slavery can enter your organisation or supply chain, which include:

  • Through criminal individuals or gangs targeting legitimate business and organisations.
  • Through an organisation’s own supervisors or management controlling the flow of workers into their operations.
  • Through using negligent or criminally complicit labour providers
  • Through a corrupt employee within a legitimate labour provider.

Each of these routes into an organisation provide the exploiter with potential to make money from the exploitation of their victims, and at risk to your organisation, reputation and potentially risk of imprisonment.

How can we stop modern slavery within our organisation?

Managing modern slavery risks should form part of your organisations Environmental, Social, and Governance (ESG) programme.

The more embedded the ESG programme is the greater opportunity you will have to identify the risks and challenges to the organisation and design preventative or mitigating solutions and controls.

To identify risk, you need to understand the nature of modern slavery, then apply risk methodology to your organisation to identify where in your organisation issues may occur.

Identifying modern slavery risks

We know that some industries are more likely to be targeted by exploiters. Industries where wages are low, skill levels are low and there is no requirement to speak the local language.

For example, in the UK we know that higher risks of modern slavery exist in agriculture, manufacturing, construction, and cleaning, whereas higher paid jobs, requiring skill where the worker speaks the local language has a lower risk profile, for example teachers, office workers, doctors, and lawyers.

Another area of risk is location, not only from a global perspective but regionally too. There are hotspots of modern slavery and forced labour globally, for example Uighur exploitation in China.

Hotspots in the UK, for example, is the garment industry in Leicester and the agricultural sector in Lincolnshire.

So, knowing where your sites are and understanding the level of risk for those sites that you have or that are in your supply chain is vital to understanding the risk of modern slavery in your organisation.


The final key area of risk is worker type:

  • What sort of workers are in your organisation and supply chains?
  • Do you employ seasonal or temporary or migrant workers or labour agency workers?
  • Would any of your workers or workers within your supply chain be classed as vulnerable?
  • Could they have dependency issues or mental health issues, or disabilities, or do they have a different religion to the local population, or do they come from difficult circumstances, possibly fleeing conflict, or neglected and dis-advantaged childhoods?

Our modern slavery assessment tool allows you to assess your supply chain, asking compliance questions to apply a risk rating to the supplier, allocating actions and helping you focus on where the risks are in your supply chain.


All these aspects can make people more vulnerable and the more vulnerable a person is the more likely they are to become a victim of exploitation and modern slavery.

Managing modern slavery in the workplace

Having good management systems and processes in place will help you to manage exploiters, whether internally or externally use your organisation to make money for themselves on the back of others misery.

Do you understand what modern slavery is and how it presents?

One key action is to understand modern slavery and raise awareness of modern slavery by training your people, particularly Human Resources and line management or supervisors with day-to-day interaction with workers. Train them how to recognise the signs of modern slavery, how to manage the situations and raise a ‘red flag’ to report it within the organisation and to the authorities.

Ensure any labour providers that you are using are legitimate, have a Gangmaster and Labour Abuse (GLAA) License if required, are audited to ensure they follow all necessary responsible recruitment requirements and have been trained to identify the signs of modern slavery.

Other actions include:

  • Run checks against workers addresses, bank accounts and mobile phone numbers.
  • Are there duplications, if so, what is the reason behind that?
  • When workers arrive at work, how do they arrive
  • Are there signs of controlling behaviours? Are workers acting normally or does something not seem right?
  • When workers are in the canteen, do they have enough food to eat? Do they have only the cheapest food to eat? Do they have mobile phones?

There are many more things that you can do to reduce the risk and prevent modern slavery occurring within your organisation and supply chains.

Our modern slavery awareness course aims to raise awareness of the important issues about modern slavery, identifying potential issues within both the organisation and its supply chain and when and how to raise a ‘Red Flag’.

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As an organisation it’s crucial to commit to tackling hidden labour exploitation, not only because it’s the right thing to do and it’s the law, but because as organisations a robust ESG programme is critical for growth as markets change and our consumers and investors become more demanding around these topics.

Stakeholders, investors, and customers may cease to trade with the organisation or invest in those that are not able to demonstrate that they are addressing and managing these issues proactively and in a systematic way.

Hopefully you are now more aware of the issues and know what you can start to do to protect your organisation from instances of modern slavery.

Ensure that you include modern slavery as part of your ESG programme, educate your organisation on the need to address these risks and commit to tackling it, that way we can help eradicate this vile infringement of human rights and in so doing protect our organisation’s reputation and license to operate.

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