How Can You Identify Modern Slavery in your Supply Chain?

Modern slavery involves the exploitation of people and can present in many forms, making it difficult to recognise. The term encompasses: dehumanising a person; forcing someone to work against their will; restricting someone’s freedom of movement; treating someone as a commodity or property; defining a person as owned or controlled by another. Human trafficking is the threatening, tricking or coercing of a person into a situation that allows them to be exploited. Victims are sold for financial gain, either within their own country or outside of it. Labour exploitation entails forcing people to work for little or no money. Many human trafficking victims are sold into labour exploitation. Labour exploitation is the most common type of slavery currently in operation within the UK.

The Victims of Labour Exploitation

The victims of labour exploitation are subjected to unacceptable working and living conditions. They are often housed in squalid, unsanitary and overcrowded accommodation. They might constantly be moved from job to job and are forced to work incredibly long hours, sometimes double shifts. Sufferers of labour exploitation are regularly faced with verbal and/or physical abuse. Not only are their workers’ rights violated, but also their basic human rights.

Identifying Modern Slavery in Your Supply Chain

There are many factors which must be considered when assessing whether modern slavery exists in your supply chain. You must always keep your eyes peeled for modern slavery red flags. The location of your suppliers is a vital indicator and a good place to begin. Whilst modern slavery is present the world over, some countries have higher rates than others. The Global Slavery Index highlights high risk countries, for example: India, China, Thailand and Bangladesh, it should be consulted when selecting a supplier.

Secondly, analysis of supplier labour hire practices indicates the respect that employees are treated with. You should observe the treatment of employees during recruitment, employment and contract termination. The following red flags may indicate modern slavery:

Excessive recruitment fees and/or illegally charging workers for health checks.
Misinformation surrounding contract details or no clear written contract provided.
Unnecessary wage deduction or underpayment of workers.
Confiscation of workers passports or limitation of their visas to a single company.
Workers being subjected to inhumane treatment, forced to work excessive hours and/or being subjected to physical or mental abuse.
Undocumented workers being threatened with the authorities if they leave.
Charging workers early termination fees and/or a security fee in order to prevent them leaving employment.
Much like the fact that slavery is present in all countries, it is also present in all industry sectors. It is however, more common in some sectors than others. Seasonal industries are a hotbed of modern slavery due to the temporary nature of work. Similarly, industries that are focused in countries with high rates of modern slavery and consequently linked with higher modern slavery prevalence. Some such industries are:
- Agriculture
- Clothing and footwear manufacture
- Fishing
- Construction
- Manufacturing
- Retail
- Beautician sector
- Hospitality
It is also important to keep your eyes peeled for any public concerns raised surrounding your suppliers. Such information may come in a number of forms, for example: media campaigns, non-governmental organisation reports and audit non-compliance. These concerns should be escalated and investigated further as they are often indicative of deep-rooted issues.

Why Is It Important to Recognise Modern Slavery in Your Supply Chain?

Slavery has now been abolished in every country and is strictly illegal to practice. It was abolished throughout the British Empire in 1833 and the current governing legislation in the UK is the Modern Slavery Act 2015. Those found guilty of a Modern Slavery Act offence face legal prosecution and could ultimately receive a life sentence. The scale of this criminal activity is shocking. L’Oréal, Revlon, Boots and Estée Lauder have been linked to child labour exploitation in India, illegally mining for Mica. Hershey, Ferrero and Lindt are linked to child labour and forced labour in West African cocoa production. Pandora, Goldsmiths and Tiffany to slavery and human trafficking with gold mining. With household names branded across newspaper headlines it is no surprise that huge reputational blows followed imminently. If you are found to be connected to modern slavery, even inadvertently, you risk coming under massive public scrutiny. With the astounding prevalence and a spotlight on transparency, it is crucial you thoroughly explore the considerable possibility that modern slavery exists within your supply chain. In order to identify it, you must first familiarise yourself with what modern slavery is and how it can present within your supply chain. Regular modern slavery training courses help to facilitate this understanding and protect not only the victims of slavery, but your company as well.

How are you managing your GDPR compliance requirements?

GDPR added a significant compliance burden on DPOs and data processors. Data breaches must be reported to the authorities within 72 hours, each new data processing activity needs to be documented and Data Protection Impact Assessments (DPIA) must be carried out for processing that is likely to result in a high risk to individuals. Penalties for breaching GDPR can reach into the tens of millions of Euros.

“In a world older and more complete than ours they move finished and complete, gifted with extensions of the senses we have lost or never attained, living by voices we shall never hear.”