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:
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:
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.
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?
This was posted in Modern Slavery & Human Rights
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