Modern Slavery – supply chain compliance challenges recruitment businesses

A new global report has revised the estimated number of victims of modern slavery worldwide upwards, from 21m to 40m. Around 10,000 victims are thought to be living in the UK.

Recruiters are at higher risk of involvement in modern slavery than many other businesses, as they are likely to be the first port of call for traffickers, particularly in high risk sectors. This is borne out by recent media coverage of criminal convictions for modern slavery, involving the unwitting supply of trafficked workers to Sports Direct by recruitment businesses.

The Modern Slavery Act 2015 (MSA), which came into effect in May last year, provided that companies or partnerships operating within the UK, with a turnover in excess of £36m, must publish annual Slavery and Human Trafficking statement (SHTs), stating what steps (if any), the organisation has taken to combat modern slavery within its business and supply chain.

Although many recruitment businesses have a turnover below the £36m threshold, they should not fall into the trap of assuming that the issue of modern slavery does not affect them. The Prime Minister has pledged her commitment to tackling modern slavery, which she described as ‘the greatest human rights issue of our time’.

Recent Government guidance, entitled the “Transparency in Supply Chains etc. – A Practical Guide” encourages businesses to go above and beyond their legal obligations under the MSA, in order to enhance their reputations, attract investment and increase staff retention, as well as increasing their customer base, as consumers increasingly seek out higher ethical standards.

The Government envisages that public opinion will create a level playing field between businesses, and emphasises the need for transparency and accountability.

The guidance also seeks to create a ‘race to the top’, by encouraging consumers, investors and NGOs, such as charities, to put pressure on businesses that are failing in their responsibilities.

Conversely, companies that do not demonstrate a high level of commitment to tackling modern slavery, may find themselves the subject of negative media coverage, ‘naming and shaming’ by ethical pressure groups and boycotting by consumers, with hirers likely to follow suit for fear of being tarnished by association.

Ravi Murphy, Director of Lawspeed, agrees that this is an emerging trend: “Hirers are increasingly demanding in this area, and are refusing to work with recruitment businesses which don’t have appropriate Anti-Slavery and Human trafficking policies and procedures in place.

“Whilst this would seemingly be more relevant to those involved in the supply of labour and blue collar workers, hirers of any ilk may have governance requirements that require this compliance. The result is that any business that fails to take action could be prejudicing its business prospects. As always, those who demonstrate high levels of commitment that go beyond mere compliance will be the most competitive. Our legal team is here to help.”

For more information on Lawspeed Modern Slavery support services please contact Lawspeed on 01273 236236 or quoting ‘MS Support’ in the subject line.