Blog: Modern Slavery: Spotting the signs. Taking action.

Hi everyone

Here comes another week- how are we already nearly in November!! Or dare I say it…. C C C Christmasssssssss! Something which I CANNOT wait for!

So a few highlights from my past week:

1. My little Hallebean turned 1– yes 1! I’m not crying, you’re crying! Not going to lie- it was very emotional. We spent the day at Yorkshire Wildlife Park and then when she was in bed, my husband and I celebrated the fact we managed to survive up until this point haha.
2. I had my 2 millionth illness and a stye- all passed on from you know who
3. My husband and I got a whole night by ourselves as the little lady was with her grandparents. I feel that we both went into a state of deliriousness with the prospect of having no responsibilities for 24 hours. It was like we both reverted back to kids for the time – was very odd. Buttt… I did get my first night of uninterrupted sleep for the first time since she was born. Did I feel like a new woman??? Noo… no I did not haha.
4. Halle’s 1^st birthday party- cue… even more tears haha. We invited all her little buddies to Little Jacks Farm and had the most perfectly special time. It was pure chaos from the minute the party started but I honestly loved every second.

As you can probably tell from all my blogs, it is pretty much near impossible to give you an update that does not involve mentioning Halle in some way. She is our little life changer and as all parents know… lives revolve around them. One day I plan to be able to do an update where I’ve had some time for me… watch this space.

Right lets get onto the legal stuff!

I thought for this week I could talk about an interesting case that shines a light on modern day slavery.

You might have seen circulating in the news that a branch of McDonald’s and a UK supermarket bread supplier unwittingly employed victims of slavery. Companies like Asda, Co-op and Sainsburys – just to name a few- were named in the report on the case.

Now the interesting thing about this case is that none of the companies named actually realised that the 16 workers were victims of a Czech trafficking gang. But what they did do, is miss vital signs that could have helped point them towards that conclusion. Some of the things that should have spiked suspicion were the fact that wages were being paid into bank accounts in other people’s names and a gang member was able to sit-in on job interviews disguising themselves as translators.

In terms of the obligations on you as a business, what you should already be aware of is that organisations that have a £36 million plus turnover have a legal obligation to prevent and address modern slavery in their operations and supply chains and must publish an annual modern slavery statement setting out their anti-slavery protocols.

The sectors that have been identified at high risk of employment slavery victims are agriculture, construction, hospitality and textiles. However, this does not mean that sectors that don’t fall within these categories won’t be affected. There are an estimated 130,000 victims of modern slavery in the UK and its even been estimated that modern slavery in the care sector has more than doubled recently, so it is a wide-reaching issue and definitely one to have on your radar.

Hand in hand with this case comes the fact that the House of Lords Modern Slavery Act 2015 Committee published a report on 16 October 2024 on the impact and effectiveness of the Modern Slavery Act 2015 (MSA), which suggests that protections have been weakened as immigration laws have been changed and which makes recommendations for improvement to government.

The report makes several recommendations for improvement such as:

1. Strengthening company accountability for modern slavery in their supply chains.
2. Urging the government to strengthen the former government’s draft Modern Slavery Bill which would make the content of Modern Slavery statements mandatory, as well as introducing proportionate sanctions for non-compliance.
3. Requesting that public bodies also be brought within the supply chain reporting requirements.
4. Introducing legislation requiring companies over a certain threshold to undertake mandatory modern slavery supply chain due diligence.
5. Urging the government to legislate to facilitate wider use of the Slavery and Trafficking Risk Orders and Slavery and Trafficking Prevention Orders under the MSA which are generally underused.

The government is due to respond by 16 December 2024–  so watch this space. There may be even more employment law changes on the horizon for us to get our heads around!

For now though, the main thing to take from this is to ensure you as a business are doing everything you can to reduce risks and a big way to do this is to ensure those within your  business are educated about the warning signs to look out for. We have popped some of these below:

1. Workers without access to their own identification documents such as passports and visas which may be controlled by someone else;
2. People working excessive hours;
3. Workers who appear withdrawn and isolated from others;
4. Workers who are often accompanied to and from work by someone who speaks for them;
5. People who seem fearful of engaging with colleagues and are reluctant to speak or talk about personal circumstances;
6. Signs of distress or anxiety and physical signs of mistreatment such as injury, malnourishment, or inadequate clothing.

We’d also say that even if you don’t meet the threshold required for a modern slavery statement to be mandatory, it might be a good idea to get one put together. You never know when it might crop up, it could be that your tender for a contract which requires you to have a statement or policy in place. Small tasks, big wins!

This can be a bit of an unspoken topic so if you do have any questions at all then please do give us a shout.

Until next time 😊