Responding to modern slavery in the workplace

After exploring how to spot modern slavery in the workplace, steps you can take to deter it, and how you can spot it in the supply chain, this final blog for 2024 will consider the almost unimaginable situation where you suspect or identify modern slavery in your workplace.

The first consideration in suspected or actual cases of modern slavery is that affected workers may be experiencing trauma, in need of first aid and/or even basic supplies of food and drinks. Furthermore, those who have suffered this most extreme form of exploitation are likely to have been subjected to a range of coercive and controlling behaviour and may have little reason to trust anyone. 

For these reasons, any policy or process should be based on a ‘people-centred safeguarding approach’ i.e. putting the safety and wellbeing of workers at the forefront of your response. 

Any response should also consider that there may be a significant number of workers affected on a site which was illustrated in 2021, when 55 workers were safeguarded on one site in north London.

Develop a response plan 

In the same way that organisations will have a plan to respond to Health and Safety incidents, they should develop a response plan for modern slavery, which takes account of the needs of any workers involved.

A response plan should include the following elements:

• A people-centred safeguarding approach involves moving potential victims to a place of safety if safe to do so (for them and the wider workforce) and focusing on building trust and rapport. 
  Be aware that potential victims, their families and others may be in real and serious danger and therefore it is essential to carefully consider any actions and potential consequences to avoid further endangering anyone involved.
• Seek guidance from the authorities and follow their advice at the earliest opportunity in order to safeguard any victims and the wider workforce whilst supporting authorities to conduct any investigation which means:
  
  
  • Avoiding any action which may alert potential perpetrators to suspicions or detection
  • Being prepared with all the relevant information when contacting the authorities 
  • Maintaining confidentiality

Guidance and advice can be sought from the Gangmasters and Labour Abuse Authority or the Modern Slavery Helpline. Suspected cases can be reported to Crimestoppers or the Police on 101, or 999 in the event of an emergency where there is actual, or the threat of, violence or a crime is in progress.

• The escalation process should be formalised and shared across all sites and workplaces, with clear expectations for escalation internally and externally, bearing in mind the need for confidentiality and the need to keep the number of people involved to a minimum.
• Practical arrangements should be planned for, especially considering multiple workers may be affected. Including:
  • Safe room(s) availability
  • Independent interpretation arrangements for those workers whose first language is not English
  • First aid facilities and support 
  • The need to remain in the company of individual workers
• Gathering and protecting evidence should follow best practice and to a standard comparable to Health and Safety incidents. Including:
  • Recording any initial first accounts 
  • Recording details of persons present during any disclosure
  • Obtaining contact details of any potential witnesses
  • Safely storing any notes, personnel or work records
  • Putting relevant documents and any other potential exhibits into bags or envelopes/handling items with gloves/locking away securely/keeping records 
  • Collecting and preserving CCTV evidence
  • Recording relevant vehicle registration numbers, vehicle make, model and colour 

In advance of identifying actual or suspected cases, you may wish to make contact with local survivor support organisations, to assist in the development of an effective response plan and to provide support in the event of a response plan being initiated. The Human Trafficking Foundation’s Survivor Support Services Map has recently been updated and provides details of trafficking survivor services across the UK.

Follow-up and support 

Where actual cases are identified then you will want to have a Remediation Policy and Process in place to determine how survivors will be effectively supported. Information on remediation is available for free in the Resources section of the Stronger Together website, in our Tackling Modern Slavery in UK Businesses and Tackling Modern Slavery in Construction and Property Toolkit.

If you are in any doubt about the need to be prepared for cases of modern slavery in your workplace, then please read the Operation Cardinas report from the Office of the Independent Anti-Slavery Commissioner which provides insights on the UK’s largest case of modern slavery in the construction sector and the response required by those involved.

Lastly, if you want further information our Tackling Modern Slavery in Construction and Property workshops include a practical exercise on dealing with ‘an incident on site’.