Could modern slavery be in your organisation?

Action Sustainability’s Operational Toolkit: Combatting Slavery in the Built Environment aims to keep modern slavery off sites and out of the construction industry supply chain.

The built environment industry is at a high risk of modern slavery and labour exploitation due to ongoing challenges such as labour and skills shortages resulting in widespread use of temporary migrant labour, agency labour and sub-contracts. Additional pressures from low profit margins and tight deadlines can result in businesses being more likely to ignore the usual protocols and processes for bringing workers onto sites.

In response to these risks, Action Sustainability developed a toolkit for businesses, shaped by contributions from partners from the Supply Chain Sustainability School’s Built Environment Against Slavery Group. It sets out to raise awareness of what forms slavery and exploitation can take and offers practical steps to reduce the risk of a business and its supply chain being an unwitting party.

It is a myth that reputable businesses cannot be infiltrated by exploiters. Just because a subcontractor or supplier has good policies and procedures in place does not mean there are no risks of slavery or labour exploitation. Exploiters can appear trustworthy and professional, just like anyone else, and both victims and exploiters can be hidden in plain sight.

Emma-Jane Allen, Senior Consultant at Action Sustainability and author of the toolkit, says: “It’s essential to embed modern slavery due diligence into the ‘business as usual’ site set-up and management. Due diligence is about taking proactive steps to prevent, identify, manage and mitigate the risks of modern slavery and labour exploitation. This Operational Toolkit empowers those on the front lines of site management to do just this.”

What does this look like in the industry?

Gangmasters and Labour Abuse Authority identifies the most common types of exploitation reported by the built environment sector as:

• documents withheld by employer or false documentation used
• unwarranted/unexplained deductions from wages
• absence of contract of employment
• misleading information about the nature of the employment
• debt bondage – when someone is forced to work to repay a debt and their freedom is restricted until it is cleared. The debt is usually structured in a way that it is impossible to repay as it greatly exceeds the worth of the initial loan, trapping the person in a cycle of exploitation and servitude
• workers being given no information or false information about their rights
• employer not paying full tax or National Insurance contributions
• poor, tied-in accommodation
• threats to expose the worker to the authorities; and
• required to perform forced or compulsory labour.

The message is to check any sub-contractors whose documentation is not on the system or whose paperwork has been supplied by a third party. If proper competence checks are carried out, that should uncover some forms of exploitation.

Six risks 

1. ‘It won’t happen to us’ – lack of awareness on the prevalence of slavery and labour exploi-tation in the UK and of the sophisticated techniques that exploiters use to infiltrate busi-nesses.
2. Workers not knowing how or why they should report any concerns.
3. Workers unaware of their basic entitlements eg hours of work, itemised payslips, wage deductions, terms and conditions, place of work.
4. Cultural and language barriers.
5. Lapses in security and vetting, including right-to-work checks not being conducted effec-tively.
6. Organisations not set up to deal with suspicions of slavery, resulting in potential victims not receiving the support they need.

Preventative measures

The toolkit includes an examination of six key risks in the built environment sector (see Six risks), along with recommended actions to mitigate these risks.

If you think your business will not be caught out, think again. Sharing information and insights on slavery and labour exploitation risks to all those involved in setting up or operating sites – especially site managers, recruiters and supervisors – is a good way to mitigate for this first risk. The toolkit includes videos of survivors talking about the reality of the sophisticated methods used to infiltrate businesses.

The second risk is your workforce not knowing how or why they should report any concerns. Regular training on how to spot the signs of slavery and exploitation and site inductions for all workers (including subcontractors) are good ways to ensure that everyone knows what to do. Refer to ‘labour rights’, ‘labour exploitation’ or ‘worker welfare’ instead of modern slavery because this terminology is more accessible and might enable those experiencing exploitative practices (but who would not recognise themselves as a slave) to recognise and flag issues.

Establish a reporting structure, in a variety of formats and in different languages, that allows people to raise concerns anonymously and confidentially, both within the organisation and externally. External reporting mechanisms could include the 24-hour Modern Slavery Helpline or the Unseen app. Internal reporting mechanisms need to be based on site managers, project managers and construction managers building relationships with workers to create a culture of trust.

A final note on this is to ensure everyone understands not to approach victims directly as this could put both workers and victims in danger. Instead consider strategic locations to put up posters – for example, on the back of toilet cubicle doors – so that workers can self-identify and seek help.

The third risk is that those experiencing this type of exploitation are unaware of their basic entitlements, such as hours of work, itemised payslips, wage deductions and terms and conditions of employment. Linked to this is the fourth risk – cultural and language barriers. It is not unusual for gangs of one nationality to work together on a project, with some acting as translators for others. While this can be legitimate in many cases, it gives a great deal of power to the ‘translators’.

The toolkit sets out steps to ensure robust policies and procedures to counteract the final two risks – lapses in vetting and the organisation not being set up to deal with cases of suspected slavery or support the victim(s).

Jo Potts, Sustainability Director at Balfour Beatty and Co-Chair for the Built Environment Against Slavery Group, says: “Operating responsibly and with integrity while upholding the highest ethical standards is critical to success – it must be at the heart of how the construction and infrastructure industry conducts business. It is therefore integral that we empower our people to tackle modern slavery. By equipping our teams with the necessary tools and knowledge, we can significantly reduce the risks of exploitation within our projects and across our supply chain.”

The toolkit brings together site-specific, actionable insights and recommendations from across the built environment to help address slavery and labour exploitation and signposts to key resources from expert organisations. It aims to empower everyone involved in site set-up and management to effectively combat slavery and labour exploitation.

Access the toolkit at b.link/SCSS_toolkit
Find out more about Action Sustainability at actionsustainability.com

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