A BBC exposé recently revealed that modern slavery victims were being forced to work at a McDonald’s branch in Cambridge, as well as a factory supplying six major supermarkets in the UK. What can employers learn from this case?
Lucy Cobb, employment law specialist and Advice Operations Manager at BrightHR, says: “Employers, no matter how big or small, must be alert to the possibility of modern slavery taking place amongst their workforce and be diligent both in identifying the signs and reporting any concerns. It is clear that, in this case, numerous red flags went undetected, allowing nine vulnerable individuals to be exploited by a human trafficking network for years.
“This serves as a powerful reminder for employers to keep a close eye on suspicious activity in their workplace—including well-established signs of modern slavery such as excessive overtime, wages being paid into bank accounts registered to other people, and numerous employees being registered to the same address—and report any concerns to the Modern Slavery helpline.
“Under current legislation, employers with an annual turnover of at least £36 million and operating in the UK must publish an annual modern slavery statement. This requirement applies to suppliers of goods or services and those conducting any part of their business in the UK. Employers should verify if they meet these criteria and, if they do, publish a statement within six months of the financial year-end detailing the steps they have taken to prevent modern slavery within their organisation and supply chain. This statement must be reviewed and updated annually.
“Even businesses that are not legally required to publish a modern slavery statement can choose to do so as part of their Environmental, Social, and Governance (ESG) strategy. Smaller businesses may find that voluntarily publishing a statement not only enhances their chances when tendering for contracts, but also aids in recruiting and retaining staff, as it’s an increasingly important consideration for employees to know that their employer has a clear commitment to upholding human rights.”
How can employers spot signs of modern slavery among their workforce?
“Employers should be aware of how modern slavery could impact their staff, both in terms of their physical and mental health, and learn to identify the signs. Physical signs might include workers seeming malnourished or fatigued, wearing unsuitable clothing, or having untreated injuries. Equally important, however, are more subtle behavioural signs, such as staff being unusually shy, reluctant to interact with others, or hesitant to answer personal questions.
“As the team members with the most regular contact with employees, line managers should be trained in how to identify these signs and reminded that they should escalate any concerns to senior management. Employers should also clearly communicate their reporting procedures for unusual behaviour to all staff and ensure that employees at all levels receive training on signs modern slavery, ethical employment practices, and the proper process for reporting suspicious activity.”
What other proactive steps can employers take to prevent instances of modern slavery?
“Proactive steps employers can take include using reputable organisations to source staff, paying a fair wage for safe and legal working hours, and undertaking thorough due diligence during procurement within the existing supply chain. They should also publicise their company stance on modern slavery and make sure this is well known by staff, as this might discourage anyone that is involved in modern slavery from seeking work there if they think there might be at a higher risk of getting caught out.”