Slavery is not confined to history; it exists today in its many forms. Modern Slavery is a global issue affecting millions of people, including here in the UK. We have a duty to protect our people and protect our business by identifying the risks and taking action to eliminate exploitation and the associated criminal activity, from our workplace.
Understanding Modern Slavery
Victims are likely to be controlled and abused by their captors, unable to leave or speak out without fear of retribution. Modern Slavery is often hidden in plain sight, within supply chains or outsourced contractors, but can also be present in our day-to-day operations. A recent investigation found sixteen victims of modern slavery within a UK franchise of a household name organisation, unbeknown to managers, colleagues, or customers, until one individual took the courage to speak out. Investigations proved many warning signs had been missed. This is just one example. The International Labour Organisation (ILO) estimates there are 27.6 million people in situations of forced labour on any given day.
Jess Phillips MP writes powerfully in her foreword for the Home Office detailed Transparency In Supply Chains guidance;
“Behind these statistics and facts is the suffering of some of the most vulnerable people in our society. Businesses must be vigilant to ensure they are not knowingly or unwittingly complicit in this abuse taking place in their operations and global supply chains. Modern slavery is so prevalent that if businesses are not identifying risks and cases, they are probably not looking hard enough.”
Individuals, often vulnerable due to poverty, their immigration status, or lack of language skills, are particularly at risk of being drawn into this abhorrent trade. Sectors with a high proportion of unskilled or temporary workers also carry a higher risk, such as hospitality, agriculture, cleaning or construction.
Managers and senior leaders have a pivotal role to play in prevention, but the signs are not always obvious.
Spotting the Signs
There is no defined checklist, but warning signs might include:
- Signs of psychological or physical abuse
- Appear frightened, withdrawn or confused
- Appear not to be free to move around
- Always accompanied
- Transported to and from work, perhaps with several people in one vehicle
- Lack of protective equipment or suitable clothing
- Lack of access to their own documents, such as ID or passport
- Working unusually long hours or multiple shifts and not taking time off
- Afraid to accept money or payment
- Wages paid into someone else’s bank account, particularly one account for several employees
Trust your instincts. If something seems odd or you have concerns, report it.
The free Modern Slavery helpline is available via telephone or online.
Taking Action
- Create a fair, ethically robust recruitment process
- Ensure staff are given clear, translated information about their rights
- Create a safe environment for raising concerns or disclosures
- Build strong, transparent relationships with all suppliers throughout the chain
Identify high risk areas
- Ask pertinent questions about how staff are recruited and treated, especially in outsourced services
- Conduct spot check site visits, speaking to workers direct
- Report concerns internally or externally to the Modern Slavery Helpline
- Join ethical initiatives such as Fair Trade or GLAA licensing (Gangmasters and Labour Abuse Authority).
Legal Responsibilities
The UK Modern Slavery Act 2015 requires organisations with a turnover above £36 million to publish an annual Modern Slavery Statement.
This statement must:
- Outline steps taken to identify and mitigate slavery risks
- Be approved by the board and signed by a director
- Be made publicly available in a prominent position, usually on the company website
- The government now has the power to seek injunctions and civil penalties in the High Court for non‑publication or non‑compliance, including unlimited fines
Even if your organisation is not legally required to publish a statement, you can produce one voluntarily to commit to your moral responsibility for tackling exploitation.
Creating an Ethical Culture
A culture of fairness, respect, and transparency is fundamental. It’s not just about being compliant and meeting our legal responsibilities, it’s about meaningful actions to show we are living up to our organisational values.
Consider:
- Including modern slavery awareness at induction and in team briefings
- Ensuring safeguarding and whistleblowing procedures are visible, understood and can be trusted
Even small actions like noticing changes in behaviour or following up concerns can have significant impact. Modern Slavery can affect any business, in any location. As managers you are not expected to solve this alone, but by leading the way, keeping informed, staying observant, and being proactive, you can help make it stop.
Support and Further Guidance
Modern Slavery Helpline: 08000 121 700
- Unseen UK: Offer training and support for spotting and responding to signs
- Stronger Together: Free downloadable templates, risk assessments, and manager guides
- GOV.UK Modern Slavery Guidance: Official guidance on the Modern Slavery Act, including statement templates
- Home Office Transparency in Supply Chains (TISC) Statutory guidance