Dr Alicia Kidd
Postdoctoral Researcher
Wilberforce Institute, University of Hull
Dr Kidd is particularly interested in bridging the gap between academia and practice in relation to modern slavery and, alongside her academic post, is the Vice Chair of the Humber Modern Slavery Partnership, a position she has held since 2016. She also works with the Risk Assessment Service at the Wilberforce Institute, which supports businesses in identifying and mitigating risks of labour exploitation in supply chains. The blog below was commissioned by Crimestoppers to coincide with their recent campaign on modern slavery. We have replicated the piece here so that it can be made available to a wider audience.
Modern slavery is a term used to refer to extreme forms of exploitation including sexual exploitation, labour exploitation, domestic servitude, criminal exploitation and even organ harvesting. These crimes affect both adults and children and aren’t limited to gender or nationality. In fact, in 2019 UK nationals constituted the largest single nationality of people referred into the National Referral Mechanism – the UK government’s system for identifying and supporting victims of modern slavery.
Since the introduction of the Modern Slavery Act in 2015, many businesses have become aware of the term ‘modern slavery’, because of the requirement the Act places on businesses. Section 54 of the Modern Slavery Act is the Transparency in Supply Chains clause which, in summary, requires any business which operates (at any level) in the UK with an annual turnover of £36 million or more to produce an annual modern slavery statement which is publicly accessible.
While the compliance rate fluctuates (currently around 79% of companies required to publish a statement have done so), so too does the quality of the reports, which often betray a limited understanding of the crime, how it might affect a business and how best to respond (though it must be noted that the content of the statements is not officially assessed; compliance rests entirely on whether or not a statement is published, regardless of what the statement says).
Labour exploitation is the most common form of modern slavery identified in the UK and it is important that businesses have a good working knowledge of how to protect their supply chains from it. Below are some practical steps that businesses can take to limit risk.
- First of all, when you begin to look for labour exploitation in your supply chain, you should expect to find it. Exploiters will always aim to be at least one step ahead and concerns may not initially be apparent. Those who are being exploited may be reluctant to come forward, so the onus is on you to identify an issue rather than relying on it being brought to your attention.
- While it is important for directors and management to be aware of what modern slavery is and how it presents, especially in regards to developing a high-quality modern slavery statement, they are unlikely to be the ones that come into contact with exploitation within the supply chain. Training should be targeted at the lowest level, to ensure that those who are likely to come into contact with potential victims are aware of what to look for and what they should do if they have concerns.
- You should create safe reporting mechanisms within your organisation so that potential victims, or those that have concerns, have somewhere to ask for support or share information. Guidance on how to report into this mechanism should be readily available to all staff. However, don’t share how you will act on intelligence, as once this information reaches an exploiter, they will find a way to work around it. Consider it a positive when concerns are raised as this means that your reporting mechanism is effective.
- While a ‘zero tolerance’ approach to modern slavery might seem logical, it could actually encourage rather than deter exploitation. Instead of ending a contract with a supplier you have concerns over, provide them with a list of issues they need to fix and a deadline by which these must be done. Only if that date comes and significant progress has not been made should you end the contract. To end the contract at the first concern runs the risk of allowing the exploiter to continue to operate elsewhere and potentially failing to get assistance to the people who need it.
- Provide all staff with information on their rights and entitlements in languages they can access.
- If possible, run regular informal worker interviews with all staff so that you have the chance to speak with workers individually. If this is established as standard practice then it provides the opportunity to have private conversations with staff members without raising alarm bells for exploiters. Getting to know your workers in this way is also a method of demonstrating that you are proactive about due diligence.
If you have concerns about exploitation in your supply chain, the Gangmasters and Labour Abuse Authority (GLAA) may be able to offer assistance. The GLAA exists to protect vulnerable and exploited workers and investigate reports of labour exploitation, human trafficking, forced labour, illegal labour provision and offences that sit under the National Minimum Wage Act and The Employment Agencies Act. You can report a concern to GLAA on 0800 432 0804.
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