In a 2016 study, the Global Slavery Index estimated that there were 136,000 victims of modern slavery in the UK. The true number may be much higher because victims are often unwilling to report it. 

Construction site

Source: Shutterstock/ BELL KA PANG

Covid-19 has exacerbated the issue; social distancing and social isolation have increased the risk of exploitation and hampered authorities’ efforts to tackle the problem.

Criminals can make a lot of money by exploiting workers for property developments. Workers (often in deprived areas) from other parts of the UK or abroad are offered reasonably priced accommodation (often including meals) near a construction site. The worker is told they will quickly repay upfront costs from well-paid work available.

Once committed, workers find accommodation charged at a much higher cost and the work poorly paid. Workers’ debts to the criminals spiral and they cannot earn enough to clear them. Criminals may hold passports, take control of bank accounts or force workers to have wages paid into the criminals’ account. The ‘bounty’ is increased by claiming benefits on behalf of workers but not passing them on.

An organisation that supplies goods or services and has a turnover of not less than £36m must prepare a slavery and human trafficking statement for each financial year, setting out the steps it has taken to ensure that slavery and human trafficking are not taking place in any part of its business or its supply chains.

Your contracts may already include relevant provisions, but do you make relevant enquiries at procurement/tender stage? Asking questions should highlight non-compliant organisations. Does the company have a slavery and human trafficking statement? Does it ask if workers live in HMOs or travel to work together? Does it check if workers have their wages paid into the same account? Does it look out for workers’ health and welfare? Things to look out for include workers not taking leave they are entitled to, untreated injuries or even malnourishment and dehydration.

Regularly run training and refresher sessions for your employees and include obligations in your contracts for your suppliers to do the same. The signs of modern slavery are not always obvious and are even harder to detect in the ‘new normal’, where maintaining meaningful contact with people requires much more planning and effort.

Nicola Williams is a senior chartered legal executive at Blake Morgan