Modern Slavery Victim Working in Mines

The 2015 UK Modern Slavery Act Hits Big Brands

It has now been just over a year since the 2015 UK Modern Slavery Act came into effect. Large companies have been investigated, with some business owners seeing the inside of a prison cell. The following examples show the importance of ensuring your company is not associated with modern slavery.

The Not-So-Free Range Eggs

In June 2016 Jaqueline Judge and Darrell Houghton were found guilty of exploiting 6 Lithuanian men and of breaching the Modern Slavery Act. The six men had been trafficked to the UK and required to catch chickens from farms around the country. They were usually not given time to eat proper meals and deprived of appropriate facilities to wash and rest, being required to urinate in bottles and defecate in plastic bags while traveling between jobs. Wages were often withheld, as well as having a salary well under the agricultural minimum wage.

These workers were also intimated by fighting dogs if they ever complained. They were abused by “supervisors” who were employed by the couple to watch over them. One of the workers said “[Our Lithuanian supervisor] Edikas sometimes punished one person and sometimes punished the whole house for one person’s mistake.”

Being a Free Range Eggs provider, the irony of this case is striking. Further, this company distributed eggs to large chains including McDonald’s, Tesco and Asda. For them to be found guilty Modern Slavery charges is a reminder of the importance of verifying a company’s supply chain. Knowing potential red flags to look out for and having an effective reporting procedure in place is now more vital than ever.
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April 1, 2016

Introducing Human Nagware

Because sometimes email is not enough

London — Convincing people to complete their compliance training has always been a challenge. Work deadlines, client pressures and other high priority tasks all contribute to employees neglecting their online courses. However, training on topics such as money laundering, bribery and diversity is mandatory and important.

Due to compliance requirements, firms require that staff complete training, and expensive administrative resources are spent chasing non-compliant individuals. Moreover, low completion rates expose firms to regulatory sanctions.

How Nagware changed compliance

In 2011 VinciWorks improved the state of compliance training forever when it introduced its revolutionary Nagware. With Nagware firms could auto-remind employees to complete training with gently escalating reminder emails.

“Nagware was a game changer”, Howard Finger, VinciWorks’ CEO commented. “Overnight, course completions tripled. Firms were asking us to incorporate Nagware into other processes in order to increase compliance rates. To fulfil that request we developed Policy Tracker for tracking policy compliance and we integrated Nagware into the Risk Management System for control procedures. We are now looking at Nagware for the Breaches Register and the Annual PI Questionnaire.”

Nagware did not go far enough

However, Nagware did not go far enough. In a pilot programme with Local Law LLP to test the efficacy of different Nag regimens, the compliance rate never rose above 75%. Nigel Plaskitt of Local Law summed up the experiment: “We threatened, we cajoled, we sent ominous emails from the managing partner. Nothing seemed to work. There were always 15-20 people who did not complete the mandatory courses.”

The only solution was a human touch

Adam Sinclair, VinciWorks’ Director of Product was tasked with finding a solution. “We hired UX experts, social scientists, you name it; we threw every resource we had at the product. We tried iPhone apps, robo-calling and text-messaging. The best we could achieve was 85% compliance.”
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A large international firm with over 500 lawyers in 11 countries approached VinciWorks with a problem. Its employees are required to complete mandatory AML training every year. To facilitate this requirement, the firm set up easy online access to courses, and sent emails with login details and clear instructions for how to complete the training to everyone at the firm. Yet, despite their efforts to make compliance with this policy easy, course completion rates were alarmingly low.

After 3 months, only 13.6% of the firm had completed the training.

With this completion rate, the firm risked non-compliance with the regulatory requirement to train employees on the regulations and risks related to money laundering.

VinciWorks helped the firm implement the advanced features in the VinciWorks Legal Learning Management System Pro Edition, and after only three months, course completion rates tripled!

CLICK HERE TO SEE HOW WE DID IT: Screen Shot 2015-06-22 at 3.21.02 PM