Modern Slavery is a subject that we are hearing more and more about in the UK. In this guest blog, Tony Dunkerley, a former Police Detective and Force Practitioner on Modern Slavery explores this growing problem and the links with fraudulent identity documents.
What is modern slavery?Modern slavery refers to situations where a person’s freedom has been taken away – such as their freedom to refuse certain work or to stop working – so that they can be exploited. This is done by way of threats, violence, coercion, abuse of power and deception. To put the issue into perspective, 1326 individuals were found to have been trafficked into, or around the UK for labour exploitation last year alone – the most common exploitation type recorded for adults and minors. In a recent case, in February 2018, 50 Romanian and Moldovan men were rescued from several addresses after being trafficked into forced labour on construction sites across London. In 2017, 1 in 8 calls to the Modern Slavery Helpline were linked to modern slavery in the construction industry and labour trafficking in industries from agriculture to construction has now overtaken sex exploitation as the main form of slavery in the UK.
Modern Slavery Act 2015The good news is that the Modern Slavery Act 2015 means that the UK is leading the way in terms of legislated disclosure requirements. Section 54 of the Act requires every business with an annual turnover of £36m or more which carries on a business or part of a business in the UK, to produce an annual statement of the steps it takes to ensure that slavery and human trafficking are not taking place. This has been the proverbial ‘stick’ to encourage businesses to be more transparent in how they operate their labour force, and how they are taking practical steps to prevent forced labour in their supply chains. But as a former lead detective in modern slavery investigations, I know it can be difficult to know where to start, as identifying and eliminating forced labour requires a clear understanding of how forced labour operates in different contexts, of who is affected and how.
Fraudulent identity documents
In the cases I dealt with, interestingly, we were consistently seeing the same methods used to recruit victims and prevent them from escaping, irrespective of the type and nature of exploitation. One main method used by traffickers was to withhold their victim’s identity documents once they had arrived in the UK. These were often replaced with fraudulent documents to gain employment in legitimate work, as well as masking their true nationality and gaining access to benefits.
The victims were being forced to work around the clock for next to no wage, with any payments going directly to their traffickers. And what we were seeing on the ground matched what was happening globally; the International Labour Organisation’s (ILO) Special Action Program to Combat Forced Labour (SAP-FL) had also identified document retention as one of several common indicators of modern slavery.
The retention of identity documents by traffickers is a common element of forced labour as it serves to isolate victims, restricting their movements and preventing their escape. Workers with precarious immigration status are often used by traffickers who want to conceal illegal activity, as these workers are judged less likely to go to the police for fear of being deported.
Modern Slavery in construction
In my experience, the construction industry is particularly vulnerable to modern slavery and forced labour due to its inherent and complex use of sub-contracted labour, often sourcing low-skilled migrant labour through agencies without effective due diligence procedures. In addition, many construction businesses rely on visual-only checks on sites for identity documents. Making visual ID checks presents a significant challenge for onsite staff who, without any technology to support them, do not have sufficient training to make an informed decision on ensuring documents are genuine.
Beyond the ethical implications of employing illegal workers, employers can receive a fine of up to £20,000 for each illegal worker they employ, or in certain circumstances be sentenced for up to 5 years with an unlimited fine if an employer knew or had ‘reasonable cause to believe’ a worker didn’t have the right to work in the UK.
Workers without valid accreditation and training also present a significant risk in the construction industry, not only in terms of being potential victims of forced labour, but also in relation to the safety of themselves and others on sites. It is therefore important for construction companies to be vigilant in their approach to due diligence assessments on the identification of their entire workforce.
How can technology help?
In their recently published guidance, the Home Office explains how Identification Document Validation Technologies (IDVTs) can play an important role in preventing the use of fraudulent documentation. Whilst they do not replace forgery experts, they provide much higher levels of accuracy and assurance than the manual checking of documents by staff not used to checking different forms of identity documents.
Signs / Indicators of Modern Slavery
Does the worker look malnourished and unkempt?
Is the worker suffering physical injuries? Are they vague, reluctant, or inconsistent in explaining how the injury occurred?
Do they often wear the same clothes, or the clothes they wear are not suitable for their work?
Do they fail to provide their own PPE?
Does someone speak on their behalf? If they do speak, are they inconsistent with the information they provide, such as basic facts like the address where they live?
Are they dropped off or picked up at unusual times of the day?
Tony Dunkerley, Guest blogger
Tony Dunkerley from Illustro Consultancy is a former CID Detective and Force Practitioner on Modern Slavery. He now uses his extensive experience to help forward-thinking businesses to implement anti-slavery strategies in order to prevent forced labour within their supply chains, protect brand reputation, improve investor relations and avoid legal ramifications of non-compliance to the Modern Slavery Act 2015.
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