Lessons learned: Unveiling modern slavery risks in the built environment By EJ Allen

There’s a growing recognition across the UK built environment sector, that slavery and exploitation are everywhere. An estimated 50 million victims worldwide, and 122,000 here in the UK – on our doorstep. But what I’m yet to see is this awareness translating into the ‘penny drop’ moment, the acknowledgement from businesses that, ‘Yes, it’s likely that slavery will be lurking somewhere in my supply chain’.

So this week, it was encouraging to hear a group of construction clients and their supply chain, in a collaborative forum, openly acknowledge, ‘We need to recognise that it WILL be there somewhere in our supply chains – we need to get better at finding it and fixing it, and then sharing our experiences so that others can learn from it’. YES. More of this in 2024 please!

It sounds a bit perverse to think this is positive, but it is. It’s the first step. Due diligence, in line with the growing wave of global legislation (and the human rights frameworks out there like UNGPs and OECD), is about identifying, preventing, managing, mitigating and remediating the risk. It’s not about making a public statement of zero tolerance of slavery, or sweeping statements of, ‘no slavery in our supply chains’ (Ostrich…head…sand…springs to mind).

Businesses often tell me that they know their organisation or supply chain is very low risk or no risk because of:

  • ‘We only work with reputable businesses.’
  • ‘All our suppliers have to sign our Charter.’
  • ‘We have due diligence policies and processes in place.’
  • ‘We do all the required checks at the on boarding stages.’
  • ‘We only work with sub-contractors who sign our Code of Conduct, which includes zero tolerance of forced labour in the supply chain.’

All this is commendable and a good step in the right direction, but this doesn’t mean your supply chain is, ‘safe’.

Exploiters use sophisticated techniques to infiltrate businesses and remain undetected. Many of those 30 main contractors and developers in London and the South East who were implicated in Operation Cardinas (one of the UK’s largest modern slavery investigations) had due diligence processes in place. They were ‘reputable’ businesses. The same for many of those businesses who were affected by Operation Fort – the UK’s largest anti-slavery prosecution.

Take a look at two fantastic reports written by Emma Crates from her time at the Independent Anti-Slavery Commissioner: ‘OPERATION CARDINAS AND BEYOND: Addressing exploitation risk in the construction sector’ and ‘OPERATION FORT: What businesses should learn from the UK’s largest anti-slavery prosecution’. They’re jam packed with key findings and lessons learned from these real-life case studies:

  • Too much trust in individual employees – especially in recruitment agencies. A recruitment agency was infiltrated by a Polish lady who was responsible for managing the labour contract for a large client. She was considered a high performer by her bosses. She was described as ‘popular, shy and soft-spoken’ and was embedded at the client’s manufacturing site. She turned away genuine job seekers to ensure there was enough vacancies for trafficked men and conducted interviews, inductions, dealt with employment forms, and kept records of accidents. She was the only, ‘go to’ person for her victims, being responsible for checking in on workers and also advised her co-conspirators how to force victims to behave to avoid detection.
  • Exploiters are often hidden in plain sight, working alongside their victims on building sites and often acting as interpreters. They made sure the victims did not bring attention to themselves.
  • Ineffective checks to detect anomalies such as shared bank accounts and addresses. Sophisticated methods were used to avoid creating suspicion at labour agencies. One agency had a system of checking if multiple workers were being paid into the same account. However, as checks were only carried out on a weekly basis, the criminals swapped victims in and out of work in a random pattern, avoiding detection. Others failed to spot that many workers had the same next of kin.
  • Use of recycled or fraudulent CSCS cards and fake pass letters. Cases of photographs that did not resemble the victims, yet access to site was still granted. Fake printouts of CSCS pass letters which had clashing fonts and new names overlaying the original text.
  • Employers could have better educated their workforce and supply chains on spotting the signs of slavery, supported by clear protocols for reporting concerns

Victims on a demolition site talked of how workers had laughed at their inadequate or broken PPE. Others had been sent home from site to wash because co-workers objected to their poor hygiene.

  • Missed opportunities for collaboration. There were cases of foremen being approached by suspicious individuals to try to bring workers onto construction sites informally. Access was denied because of the suspicious circumstances, but this information wasn’t shared widely among local sites and contractors.
  • Abuse of labour contracts. Construction contracts often include a clause that if someone is unable to work on a certain day, someone equally qualified can be sent in their place. Gangs used this system to their advantage, moving victims in and out of projects without raising suspicion.

So this is what we’re up against. Sophisticated crime groups. And this is in the UK – imagine what’s happening in those international supply chains.

This is why having a Charter, a Code of Conduct, good on-boarding processes, or a good policy, doesn’t mean that the risk of modern slavery disappears. Due diligence isn’t a tick box exercise. It’s an ongoing process.

How are you ensuring that these processes are being implemented?

How are you embedding these requirements into your procurements and contract management?

How are you ensuring that workers know how to spot the signs, and are empowered to report any concerns?

How are you managing the heightened risks in your labour contracts?

How are you collaborating within the sector to share knowledge?

To discover how we’re able to support you with your modern slavery due diligence, Get in touch today.

For more information

EJ Allen
Senior Consultant

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