Conduct & regulation
What is modern slavery?
Modern slavery covers forced labour, servitude and human trafficking. Recruitment is a sector with elevated exposure, and larger organisations must publish a statement on their supply chains.
The indicators are visible to an agency before they are visible to anyone else: several workers sharing a bank account or an address, a third party speaking for them, reluctance to hold their own documents.
Those indicators need to be known by the people who would see them, which means consultants and payroll staff rather than a compliance manager.
The statement obligation applies above a turnover threshold, but the underlying risk applies regardless of size, and the statement is not the substance of the response.
What goes wrong in practice
- Indicators not known by the consultants and payroll staff who would encounter them.
- A statement published with no underlying process behind it.
- Concerns noticed and not escalated because no route existed.