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Identifying and Tackling Modern
Slavery in Supply Chains
Mark Heath
• Created after Morecambe Bay tragedy
• Who – Home Office - NDPB, 68 staff
• What - Regulate provision of labour
• Where - UK
• When - 2005 onwards
• How - compliance, enforcement, consent
• NIM compliant – intelligence led
• Ministerial Statement May 2012
• Do not cover Construction, Hospitality, etc
The GLA
Labour exploitation - UK
National Crime Agency (NCA) find that:
• Reported victims for labour exploitation are increasing
• Key source countries include UK, Poland, Slovakia, Czech
Republic, Romania, Lithuania and Hungary
• Sectors include agriculture, factories, food processing,
construction, domestic work, fisheries, car washes
• There has been a five fold increase in the number of
potential victims of slavery in the last three years – 55%
have been labour related
The Problem
• Worldwide 45 million
• 10,000 to 13,000 victims in UK
• Low paid - low skilled - high demand – temporary
• 31m UK working population
• 10.8m high risk sectors
• 500k GLA sector
• Risk sectors include – Agriculture and fishing, food packing
and processing, Accommodation/Food services,
Construction, Wholesale/Retail, Transport/Storage
• Multiple exploitation
Emerging Trends
• Increase in number of OCGs involved in the supply of
labour
• Nationalities generally exploit “their own”
• Increase in labour exploitation – Eastern European males
• Low risk/high return
• Under the radar
• Workers reluctant to complain, often through fear
• Links to benefit and tax fraud
• Credit Card Fraud
Types of trafficking (adults) – 2015
Domestic Servitude – 353 (15%)
Male 61, Female 292
Sexual Exploitation – 863 (37.8%)
Male 48, Female 813, Transgen 2
Unknown Exploitation 171 – (7.5%)
Male73, Female 98
Organ Harvesting – 2 (0.001%)
Male 1, Female 1
UKHTC NRM totals 2015
Domestic Servitude
Labour Exploitation
Organ Harvesting
Sexual Exploitation
Unknown
Labour Exploitation – 895 (39.2%)
Male 734, Female 161
Associated crimes
• Work Finding Fee
• Sham Marriages
• College Fraud
• Benefit Fraud
• Violence, Intimidation.
• Guns, Drugs
• Cyber Crime, Cyber Slavery
• Anti social behaviour, theft
Humans are low risk and high profit
Labour Market Exploitation
• The Chancer
• The Employer
• The Intermediary (Horse Trader)
• The Organised Criminal
Recent Cases
• Workers recruited in home country
• Brought to addresses in the UK
• Placed in houses with a controller/enforcer
• Placed in work in regulated sector with licensed agencies
• No control over bank cards
• Taken to withdraw money
• Fear of assault if wages not paid over
• Actual assaults if step out of line
• Limited social contact
• Become alcohol-dependent
Case Study – Power and Profit
• Brothers Marek and Igor Marcin lived in a typical
Derby semi.
• They trafficked men into the UK from Slovakia
and the Czech Republic.
Power and Profit
• They housed 11 workers in a three-bedroomed
house
• They controlled all their bank accounts
• They paid them between £5 and £20 per week
• They claimed benefits in their names
• They wore expensive jewellery
• They drove expensive cars
• Their wives stole ‘ready cash’ from the workers
• They made in excess of £1.3 million
Power and profit
Fear and hope
Convicted
• Marek and Igor Marcin admitted human
trafficking charges
• Marek got 40 months in prison – Igor got 52
months
• Marek’s wife Gabriela (right) received an
eight month sentence for theft.
• Igor’s wife, Dagmar, got 10 months
Transparency in supply chains
• A commercial organisation with a turnover above £36m
must prepare a slavery and human trafficking statement for
each financial year.
• A statement can include details in relation to its:
• Structure, business and supply chain,
• Policies and due diligence in relation to slavery and
trafficking
• Areas of risk and the steps taken to assess and
manage the risk
• Effectiveness in identifying and tackling slavery
• Training and capacity building for staff
Role of business
• Transparency requirements
• Eyes and ears for law enforcement
• Reputational risk
• Reduced Investment
• Work in partnership
• Take and show a lead
• “Audits don’t catch criminals”
• Voluntary codes of practice
16
Know the supply chain
• Kozee Sleep Dewsbury
• Daily Mail 5 March 2016
Know the supply chain
• ‘How they lured slaves to Dewsbury factory that
made beds for John Lewis’
Next, John Lewis and Dunelm Mill failed to spot
'slaves' at Kozee Sleep factory
• Dewsbury bed factory run on 'slave workforce'
18
Labour Market Enforcement
• Immigration Act 2016 - (13 May)
The legislation proposes:
• Director of Labour Market Enforcement – to oversee some
agencies and set strategy
• Data sharing agreements
• Information hub
• Reform GLA into Gangmasters and Labour Abuse Authority with
stronger powers to tackle labour exploitation across the UK
economy
• Creates a new labour market undertaking and enforcement
order regime
The Solution
• Will continue its current role in the GLA sector
• Will have the power to investigate modern slavery, other labour law
offences and power to search/seize evidence across the entire labour
market
• Will have the power to issue enforcement undertakings
• Recognises that co-regulation is crucial
• Will provide technical and tactical assistance
• Will help you to see your supply chain single points of failure
The role of procurement
• www.ashridge.org.uk/modernslaveryreport
“We found that buyers and procurement teams
were probably the most important people to
engage, next to senior management, in the
implementation of an approach to address ethical
trade and modern slavery issues – particularly
ensuring they understand the issues and the
tensions and can make appropriate decisions in
their daily activity.”
Working together
• Call the GLA – entire labour market
• Tac. Advice, expert/impact witness
• LMEA
• Your supply chain (TISC)
• Procurement
• 0345 602 5020 (main switchboard)
• 0800 432 0804 (confidential reporting line)
• @UK_gla
