FEATURE MODERN SLAVERY
“I would not take somebody’s word for it. I would say, ‘Show me what you’re doing. Show me how well you buy and provide me with due diligence and evidence’.” and remediate the victims. This often means that I need to work with my supply chain – smaller subcontractor businesses – to help me to fulfil my legal obligation. “Logistically it can be very difficult. But that doesn’t let anyone off the hook either. It just means we need to be better at carrying out often very basic checks such as right-to-work visas, banking details and address details. If you have multiple people being paid into the same bank account, for example, this will be a red flag. And it’s the same for address details for workers. Ongoing monitoring using digital tools and
on-site assessments and audits are all part of the process. “The harder you look, the more you’re going to find. But my message for the construction sector is we’re not looking hard enough.” Comparing the conversation now with the dialogue taking place eight years ago in the anti modern slavery sector – which began to develop into a formalised industry after 2016 – it’s clear that not much has changed, Mitchell-Hill says. “We’re talking about the same issues, which doesn’t indicate a lot of progress being made.” To bring about significant change, Mitchell-Hill argues, “There needs to be greater awareness of modern slavery in construction and more robust processes and systems to monitor the supply chain.” A major challenge when it comes to mitigating modern slavery is that it’s often hard to see. “Not everybody would recognise when somebody is in a state of modern slavery,” Mitchell-Hill says. “It’s often hidden in plain sight. A positive step that businesses of any size can take is to make sure their people are aware of the signs of forced labour.”
– but vulnerable British nationals (31 per cent according to Home Office data from 2021) also fall prey to these modern slavers, as they are often lured with paid work and accommodation, which turn out to be lies. When the Modern Slavery Act came into force in 2015, construction was listed as one of the five industries worst affected by forced labour. “Construction is an industry at high risk of modern slavery,” says Elaine Mitchell-Hill, International Lead, Design for Freedom at Grace Farms Foundation. “A huge part of the issue is construction’s subcontracting nature. With a contractor, subcontractor, and possibly someone further down than that, the logistics are difficult to manage.” Any contractor or developer with a turnover exceeding £36 million meets the threshold under the Modern Slavery Act for businesses to report on what is happening in their supply chain’s workforce. “They need to know where their risks lie and address those risks,” explains Mitchell-Hill, who is the former ESG & Human Rights Director at Marshalls PLC. “So if I’m a big developer, I have to identify where the risks lie and show what measures I am actively taking to find instances of modern slavery, address them
Victims of modern slavery are often controlled and coerced with the threat of violence. Their captors take away their identity
Signs of labour exploitation UK charity, Unseen, provides support to survivors of human trafficking and modern slavery. It lists the following as signs that someone could be a victim of forced labour.
What to look out for in the business:
What to look out for on site: ● There are signs of psychological or physical abuse ● They appear frightened, withdrawn or confused ● They do not speak much ● They are not free to move and are always accompanied
are paid into the same bank account
● They are transported to and from work, perhaps with a number of people in one vehicle ● They lack protective equipment, clothing or training to do their job safely ● They have an injury that has not been treated ● They frequently work long hours.
● Their legitimate wages may be taken by an exploiter who is outside of the workplace ● They are afraid to accept money or payment ● They are forced to stay in often overcrowded accommodation provided by their employer ● They do not have a visa or right to work in the UK.
● They do not have access to their own documents, such as an ID or passport ● They do not have a contract, are paid less than the National Minimum Wage, or not paid at all ● They do not understand who they work for and who pays them ● Multiple individual workers
Master Builder 32
www.fmb.org.uk
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