5 Must-Have Modern Slavery Controls For Retail Businesses

In July 2020, an undercover report found workers in Leicester making clothes for online fashion retailer Boohoo being paid as little as £3.50 an hour. Later in December 2020, the Guardian published another article alleging that Boohoo was selling clothes made in a factory in Pakistan where workers were earning as little as 29 pence an hour.

Figures from last year reveal that almost 30 modern slavery victims were found every day in the UK last year. Latest estimates from the International Labour Organization also show that modern slavery and forced labour affects almost 25 million people worldwide.

With the increase in public awareness, there is growing pressure on UK-based retailers from investors to comply with modern slavery laws. Remaining diligent about ethical supply chain practices will set retailers in good stead, both ethically and legislatively speaking.

Performing due diligence is also best practice when it comes to protecting your brand and meeting customer requirements – after all, being linked to human trafficking and labour exploitation is extremely damaging to the credibility of any retailer, and rightfully so.

So how can retail businesses ensure ethical supply chain practices? Here are five Modern Slavery controls all retailers ought to practice.

Make a commitment

All large companies with an annual turnover of £36m or more are required to publish annual statements on what they are doing to tackle forced labour in their operations and supply chains under the 2015 Modern Slavery Act. However, it’s still important for smaller retailers to make a strong commitment against modern slavery.

Assigning board level responsibility for these best practice policies and laying out what the company wants to achieve in preventing modern slavery will help retailers take meaningful action.

Establish good recruitment practices

Experience shows that the recruitment stage is often where workers are most at risk from modern slavery exploitation, especially where third party labour recruiters are involved, and even more so where workers are migrant. Therefore, retailers must pay particular attention to the recruitment process.

Ensure you establish due diligence checks when appointing labour providers and develop a written policy stating that the cost of recruitment is a business cost, not to be passed onto workers.

Good record-keeping and monitoring

Ensure you establish checks of workers’ home addresses and check occupancy figures here (those held in modern slavery are often housed in overcrowded, cramped conditions). Migrant workers should have access to their passports and companies should check bank accounts to identify wages aren’t being collected by one account.

Team leaders/supervisors should be comfortable monitoring, recording, and reporting any concerning signs in the physical wellbeing of employees, e.g., bad hygiene, extreme fatigue, or malnourishment. They should feel comfortable approaching workers informally to discuss any issues.

Assess where your greatest risks are (then act to tackle them)

Draw up an initial high-level assessment of your supply chain, including direct and indirect suppliers, labour providers and contractors to identify low, medium and high-risk suppliers (consider, for example, using self-assessment questionnaires to gather information from potential suppliers).

Based on your available resources, take immediate steps to reduce the risk of any high-risk suppliers, e.g., by requiring them to establish grievance or whistleblowing procedures. Ensure you develop channels for gathering and managing any future risk information.

Train staff

Most employees are not even aware that modern slavery is an issue – that’s why training must start by raising awareness on the subject and presenting facts/figures on the severity of modern slavery in the UK and around the globe.

As well as training managers/supervisors on particular red flags to look out for in employees and how to raise and report these issues, employees across the board will benefit from awareness training which provides the tools and knowledge they need to identify and report concerns about modern slavery.

How can we help?

Increasing the levels of transparency and awareness are paramount when it comes to complying with modern slavery laws. Retail businesses can use awareness training to empower employees to spot the red flags of modern slavery and educate them about its prevalence and the areas it’s more likely to take place.

Find out how DeltaNet International can help with our range of Modern Slavery eLearning courses.

Working with the Modern Slavery Act

This training film provides a comprehensive introduction to the UK Modern Slavery Act and what it means for businesses operating in the UK. Modern slavery happens around the world and across a range of industries, from construction, farming and domestic work to mining, manufacturing and supplied labour.

Businesses Join the Fight Against Modern Slavery

Modern Slavery affects more than 40 million people worldwide, with more than half of victims working in forced labour – against their will and under threat or intimidation. Enforcement agencies are calling on businesses to do more when it comes to spotting the signs of modern slavery and educating employees about its prevalence and the areas it’s more likely to take place.

We look at the role businesses play in tackling modern slavery, maintaining ethical standards and identifying the vulnerable areas when it comes to choosing and working with external suppliers.

The Legislation

In 2015, the UK became the first country in the world to have dedicated legislation in place to tackle modern slavery. The Modern Slavery Act was introduced in 2015, combining previous slavery and trafficking laws and increasing the maximum jail term for human traffickers from 14 years to potential life behind bars.

A factsheet published by the UK government recognised that more potential victims are being identified and protected due to greater awareness and improved understanding of modern slavery. In the year to September 2018, 4,270 offences of Modern Slavery were recorded by police which was a 51% increase compared with the previous year (2,824 offences).

In one of the most shocking cases to come to light, members behind the largest modern slavery network to be exposed in the UK were jailed in July 2019 for tricking vulnerable people from Poland into England with the promise of work and a better life.

Chief Inspector Nick Dale, who led the operation, revealed that it took four years for the “really complex investigation” and called for organisations to do more to tackle the problem of modern-day slavery. Dale called for businesses to be more aware and make it difficult for organised groups to work and profit from exploiting vulnerable individuals.

Preventing Modern Slavery

There is growing emphasis on the role businesses play in identifying and reporting modern slavery. Businesses can no longer afford to ignore what is happening in their supply chains and need to ensure that they do not involve slavery at any level. Some key steps that businesses can take include:

Get to know your business partners

Gain a full understanding of your supply chain, seeking transparency while identifying all suppliers connected with your business. Check whether any of your suppliers, or suppliers’ suppliers could be using forced labour or unethical practices. Businesses need to understand the ownership and structure of your suppliers’ businesses to minimise the risk of regulatory non-compliance and reputational damage.

Identify high-risk locations

Modern Slavery could occur anywhere in the world, however annual surveys from the Global Slavery Index indicate higher levels of forced labour in certain regions and industries across the world. Using data to identify high-risk locations or industries can help businesses assess and mitigate risks from exposure to unethical working practices in the supply chain if you import products, materials, or services. The key to protecting your business is enhanced due diligence while identifying exactly where your suppliers operate from and within which industries.

Learn from recent cases

There is a lot to learn from recent cases of modern slavery, which show how gangs and networks operate and which industries they are prevalent in. Cases have also exposed the levels of abuse involved which could help increase employee awareness in spotting the tell-tale ‘red flags’ associated with modern slavery. The National Crime Agency (NCA) has identified signs of abuse to look for which include the manner of a person’s dress, visible signs of injuries, signs of stress and how people come to work in a particular area.

Awareness Training

A 2019 survey commissioned by IOSH found that 83% believe employers should ensure employees have training on how to prevent modern slavery in their operations and supply chains.

Increasing the levels of transparency and awareness are paramount when it comes to the fight against modern slavery. Businesses can protect their reputation and ensure compliance with legislation. Awareness training can empower employees to be able to spot the red flags of slavery and educating them about its prevalence and the areas it’s more likely to take place.

Find out how DeltaNet International can help with our range of Modern Slavery eLearning courses.

Tackling Modern Slavery: Australia’s New Law

On 1st January 2019, Australia’s Modern Slavery Act came into force. Many of the principles of the legislation are similar to the UK Modern Slavery Act of 2015.

Its passing shows an increasing awareness of the issue of modern slavery in supply chains, and the duty of companies to ensure theirs are free from exploitation. The US and Canada have pending modern slavery legislation and France passed a similar Act in 2017. In the modern world, where manufacturing processes and supply chains can span multiple continents, there’s an increasing awareness that modern slavery needs to be challenged robustly.

What is Modern Slavery?

The term “modern slavery” refers to a range of serious exploitation techniques. These include (but are not limited to) forced labour, people trafficking, bonded labour and sexual and criminal exploitation.

There are certain “high risk” industries whose workers are particularly vulnerable to the horrors of modern slavery. Construction, cleaning and supplying the consumer sector (including international importers of food and clothing) are examples of high risk industries.

It’s vitally important for employers to identify any modern slavery in their supply chains. Aside from the obvious moral repercussions of using exploited labour, organisations who don’t perform due diligence can face a huge public backlash from consumers who want their goods ethically manufactured and sourced.

In January 2019, the Spice Girls were criticised for not properly vetting the factory that made a line of t-shirts to raise money for Comic Relief. At the factory in Bangladesh, machinists were reportedly paid only 35p an hour and verbally abused by their managers. It was claimed that the retailer the band hired had changed manufacturers without their knowledge, but the PR damage hit the band, the charity and the retailer. This highlights the importance of the issue of workers’ rights in supply chains and how careful all companies and manufacturers must be to ensure the people who create their products are treated fairly.

International Problem, International Solutions

Although the 2015 Modern Slavery Act has been a great leap forward for tackling this appalling issue, it has been criticised for not being tough enough – unlike the new Australian legislation. The UK government is therefore considering tightening the law and imposing stiffer penalties on companies that fail to report issues correctly and promptly.

The number of countries considering passing their own anti-slavery legislation, or tightening existing laws, is good news. Each advance represents a win for ethical suppliers, wherever they may be in the world, and a loss for those who exploit their workers. Modern slavery is a problem that crosses international borders. A strong, international response is exactly what’s required to confine slavery to the history books, where it belongs.

What Companies Need to Do

Organisations need to be aware of modern slavery and their responsibilities under the Modern Slavery Act.

Mapping out their supply chains is a must. Companies should pay particular attention to parts of the process that take place in countries deemed high risk for modern slavery, but must also be aware that it can happen anywhere. In the UK alone there are an estimated 13,000 people living in modern slavery, and some estimates put the figure higher than that. Modern slavery can affect anyone, regardless of age, gender or nationality; we are all potential victims.

Companies should make every effort to stay aware of their suppliers’ employment practices. Potential red flags for modern slavery include underpayment of workers, long and inhumane working hours and charging workers fees to leave employment or have health checks.

Safe Car Wash Scheme Tackling Modern Slavery

Your local car wash might seem like a harmless way to save yourself a little time, but it turns out that many hand car washes rely on slave labour and exploitation to offer low prices.

While most car washes are legitimate businesses, they are sometimes used as fronts for slave labour, in which workers are threatened, abused and exploited – and may be prevented from leaving by criminals who confiscate their passports or force them to pay off loans.

The Safe Car Wash app is encouraging people to report any car wash that exhibits any of the tell-tale signs of modern slavery. Reports from the app, including GPS location data, are sent to the National Crime Agency and the Gangmasters and Labour Abuse Authority (GLAA)

Signs that a car wash may be using slave labour include:

  • Low prices (less than £6.70)
  • Fearful behaviour
  • Use of children
  • Lack of protective clothing

The data is also being assessed by the University of Nottingham’s Rights Lab. Professor Zoe Trodd, director of the Lab, said: “Car washes are completely unregulated territory and we don’t know how big the sector is, how many hand car washes operate or how many persons are registered to work in them. This citizen engagement in data collection is a powerful technique with potential for mapping other vulnerable services such as nail bars.”

The campaign group Anti-Slavery International estimates that 13,000 people may be currently enslaved in the UK. While it may be difficult to imagine how free people become forced into slavery, there is a common approach used by criminals who want to exploit others. They typically begin by offering jobs to people in other countries – such as Albania, Vietnam, Nigeria, Romania and Poland. Once people arrive in the UK, their passports are taken away and they are forced to work to repay fees for transport and recruitment – and the work they do is very different from the job they were promised.

Modern Slavery Act 2015

The Modern Slavery Act was introduced to combat the growing problem of slavery, exploitation and human trafficking. Its provisions include:

  • Increased sentences for slavery offences
  • Protection for victims of slavery for crimes they were forced to commit
  • Requiring large companies to report on how they prevent slavery in their supply chains
  • Establishing an Anti-Slavery Commissioner to monitor the UK’s response to slavery.

Training from VinciWorks

Does your organisation need to report on slavery – or understand the nature of the problem? If your company needs to train employees about the issues surrounding modern slavery, VinciWorks can help. Our eLearning packages can be selected as complete off-the-shelf solutions, or we can customise the content to suit your unique requirements.

Browse our Modern Slavery eLearning courses now.

Modern slavery: What are Organisations Doing to Prevent it?

One of the requirements of the Modern Slavery Act 2015 is that companies with a turnover exceeding £36m must produce an annual modern slavery transparency statement, declaring how they safeguard human rights. Companies must also explain what steps they take to ensure that slavery does not occur in their business, or in their supply chain.

While it may be easy for British companies to be certain that their operations do not involve slavery or people trafficked into jobs they can’t leave, it’s much more difficult to verify conditions in far-east factories. The Modern Slavery Act is designed, in part, to tackle this issue, and prevent UK companies from turning a blind eye to abuses in the factories they depend on.

A recent study from the Department of Management Science at Lancaster University has delved into the modern slavery transparency statements from 101 UK companies in the clothing and textiles sector. As the authors of the report acknowledge, this sector has struggled with human rights abuses in recent years, problems that are exacerbated by the demands for fast, cheap fashion.

The researchers found a variety of approaches used in these reports, something that is unsurprising given that the reports have no fixed requirements. Companies are free to report – and omit – as much as they like.

Some companies use audits to check that their suppliers are adhering to agreed standards. But the usual approach for dealing with breaches is not well suited to the problem of modern slavery. For example, if an audit uncovers unsafe working practices, then the supplier and their customer would create a plan for remedying the problem. This approach allows problems to be resolved without significant interruptions to the supply chain. But, if an audit uncovered trafficked workers or slavery, then they would be duty-bound to report the matter to the relevant authorities – in spite of the PR nightmare this would entail for the customer.

Another issue the researchers uncovered is that slavery and people-trafficking are not always obvious; a trafficked worker may look like the free individual working next to them. So how can companies be confident that the goods they buy are not made by the hands of slaves? The report suggests that auditors may need to work more closely with their suppliers and law enforcement officials. Additionally, people working in these factories and workshops need to have the tools to raise the alarm and report abuses as soon as they arise.

The report was based on the first modern slavery statements required following the new legislation, so it may be the case that this first round was a learning process, and in subsequent years these reports may take on a uniform layout and include more concrete details about companies’ anti-slavery efforts.

Modern slavery training from VinciWorks

We offer eLearning on a wide variety of compliance-related topics, including Modern Slavery courses:

  • Identifying Modern Slavery in the Supply Chain
  • Modern Slavery Transparency Statements
  • What is Modern Slavery?

How to Fight Modern Slavery in the Supply Chain

How to Fight Modern Slavery in the Supply Chain

Many products currently available on the UK High Street are made by, or contain ingredients produced by, adults and children trapped in slavery. This is a global problem, so far-reaching that The International Labour Organisation (ILO) estimates the number of Modern Slaves is now approaching 25 million (and growing). These adults and children generate billions of dollars in revenue for those exploiting them, prompting a commitment by world leaders at the G20 summit in July 2017 to take ‘immediate and effective measures’ against forced labour.

It’s true that awareness of this problem has grown in recent years, leading to legislation being introduced to combat it and increase commitment from organisations, especially large, global ones, to identify and eliminate Modern Slavery from their supply chains. This is a difficult task, however, largely because supply chains are increasingly complex in big companies and often cross several countries’ borders.

In 2015 the UK introduced ‘The Modern Slavery Act’. It aims to clamp down on the trafficking of people into the UK, but also requires big UK businesses to report on how they tackle slavery in their global supply chains. Under the Act, companies with an annual turnover of over £36 million must produce a Slavery and Human Trafficking statement stating what they are doing to prevent modern slavery abuses in their operations and supply chains. This is true even if the company in question is doing nothing – they must admit to this in their transparency statement. All companies should have published their first statement by 30 September 2017.

In addition to Modern Slavery, the issue of child labour is also becoming increasingly spotlighted. The ILO estimates that over 150 million children aged between 5 and 17 are involved in child labour, and often in hazardous industries with dubious health and safety practices. MSCI, the global research and analysis firm, has identified 62 companies against which allegations have been made about employing under-age workers. MSCI is concerned that large scale use of child labour could affect the long-term viability of such companies.

So, what can be done by organisations to identify labour exploitation in the supply chain?

There are a number of red flags that can help supply chain managers and buyers to identify areas of their organisation’s supply chain that are vulnerable to slavery, human trafficking, and the exploitation of child labour.

Red flags include:

  • The location of the suppliers. The Global Slavery Index identifies regions and countries that have an increased risk of labour exploitation. These include India, China, Thailand and Bangladesh.
  • Labour hiring practices of the suppliers. A variety of red flag practices can occur during the recruitment, employment, and contract termination of workers. For example, workers being charged excessive recruitment fees, being misinformed of the contract details, or not being provided with a clearly written contract.
  • Industry sector. Some industries are considered more at risk than others as they tend to operate in countries that have minimal labour laws or because the work is seasonal and therefore temporary. These industries include: agriculture, clothing and footwear manufacturers, construction, and hospitality.
  • Publicise labour standard concerns. An organisation which has previously been linked to unethical labour practices either via a media campaign, non-government organisation report (such as the Ethical Trading Initiative) or through audit non-compliance should be considered as a risk and investigated further before being selected as a supplier.

A supply chain mapping exercise should be carried out on existing suppliers to identify which of them could potentially be using slave labour. When sourcing a new supplier these red flags should be considered early in the sourcing process. Self-assessment questionnaires can be used to gather information from potential suppliers in relation to the red flags.

All this information should be collated to determine whether the supplier is high, medium or low risk. Once the risk level of the supplier has been identified a decision can be made whether to enter into a supplier agreement with them.

As part of any supplier agreement, suppliers should agree to participate in and fully co-operate with regular audits and/or onsite assessments. This will ensure that they are maintaining their ethical standards and that information provided in their self-assessment documentation and transparency statement is accurate. It will also help to determine whether they are being successful in tackling human trafficking and modern slavery in their organisation.

Can VinciWorks help?

We have a range of courses covering the issue of Modern Slavery, including an introduction and overview of what Modern Slavery is, detailed information of how to identify and assess the risk of Modern Slavery in your supply chain, and how to write/publish a Modern Slavery Transparency Statement in line with legislation.

As ever, we’re more than happy to chat through your requirements on this important issue.

Does your organisation comply with the Modern Slavery Act?

Today is Anti-Slavery Day

Did you know that on any given day in 2016, 40 million people were victims of modern slavery? 71% of victims were female and 1 in 4 were children. Modern slavery is a global problem, affecting every country in the world. In fact, in the UK, you could be coming into contact with victims of modern slavery every day and not even know it. The National Crime Agency estimates that there are tens of thousands of people in modern slavery right now in the UK.

The 18th of October represents a chance to raise awareness about modern slavery and human trafficking, and also gives us an opportunity to consider what we can do to help victims of modern slavery and stop the people that exploit and abuse them.

Someone is in slavery if they are:

  • forced to work – through coercion, or mental, financial, or physical threat;
  • owned or controlled by an ’employer’, through mental or physical abuse or the threat of abuse;
  • dehumanised, treated as a commodity or bought and sold as ‘property’;
  • physically constrained or have restrictions placed on their freedom of movement (e.g. have their passport taken from them).

Forms of modern slavery range from forced labour, forced marriage, and forced organ removal to prostitution, human trafficking, and debt bondage. Many modern slaves endure more than one form of slavery throughout their lifetime, and many are trafficked from country to country, often hiding in plain sight.

At DeltaNet International we believe that awareness is key when it comes to the fight against modern slavery. By empowering your employees to be able to spot the red flags of slavery and educating them about its prevalence and the areas it’s more likely to take place, we can leave criminal networks of traffickers and slavers nowhere to hide.

Our modern slavery training is delivered in three engaging courses:

Identifying Modern Slavery in the Supply Chain will teach employees how to remain vigilant about modern slavery. Companies risk a great deal of reputational damage should instances of modern slavery be discovered in their supply chain. Therefore prevention is key and this course will help employees gather relevant information about your suppliers and allow you to assess whether they are high, medium or low risk.

Modern Slavery and Transparency Statements documents the necessary steps and legislation behind Section 54 of the UK Modern Slavery Act, which requires larger organisations to release an annual statement detailing the steps they have taken to prevent modern slavery in their operations.

What is Modern Slavery? is an introductory microlearning course, designed to give a short, sharp overview of what modern slavery is, what it means for your organisation and how your organisation can ensure compliance. Microlearning is an effective way of delivering modern slavery training as it is recognised to improve learner engagement, as the microlearning courses typically last for 5 minutes so even the least attentive learner can focus for the duration of the course. Microlearning is highly engaging, concise, specifically focused learning which maximises the level of knowledge that learners retain.

Hiding in Plain Sight: The Shocking Scale of UK Modern Slavery

Hiding in Plain Sight: The Shocking Scale of UK Modern Slavery

The Modern Slavery Act was introduced into law in 2015; the new legislation combined previous slavery and trafficking laws and also increased the maximum jail term for human traffickers from 14 years to potential life behind bars.

The Act was an obvious effort to crack-down on Modern Slavery and to cast light on the subject, making the public more aware of its scale and destruction. However, it’s debatable whether enough has been done to educate people about this horrendous crime since the number of suspected victims of slavery and trafficking has more than doubled in the three years 2013 – 2016. In fact, the National Crime Agency (NCA) estimates that there could be as many as tens of thousands of victims of Modern Slavery in the UK alone, making it a crime now so widespread that, as NCA Director Will Kerr suggests, ‘ordinary people would be unwittingly coming into contact with victims everyday’.

Although sexual exploitation is a the most common form of slavery reported in the UK, many victims are found working in nail bars, construction sites, brothels, cannabis farms and in agriculture or domestic environments. Many more still are hidden deep in the supply chains that service otherwise reputable organisations – places where owners and employees have no idea that any criminal activity is taking place – and, yet, these businesses still face huge reputational damage if they are found to have neglected the necessary due diligence that exists to protect vulnerable people.

There is no typical victim of slavery. Modern slaves may be men, women, or children, but all are normally among the most vulnerable and socially-excluded groups. Many believe they are escaping poverty, accessing education, or avoiding unstable socio-political conditions. However, usually the gangs and traffickers responsible for Modern Slavery are only interested in financial gain. They move people around the globe as if they were commodities to be bought and sold, and control them through fear and intimidation.

What can organisations do to tackle Modern Slavery and comply with the Modern Slavery Act?

Tackling Modern Slavery in the supply chain involves increasing employee awareness as to what the ‘red flags’ of slavery might be. If organisations teach all their employees what to look out for, then it is harder for trafficking crimes to go undetected. For example, The NCA says that signs of abuse could include:

  • The manner of a person’s dress
  • Visible signs of injuries
  • Signs of stress
  • The manner in which people come to work in a particular area

VinciWorks’ eLearning courses are designed to teach employees to identify vulnerable areas when it comes to choosing and working with external suppliers, and also what the tell-tale signs of Modern Slavery are and how to report them.