As you’ll well know by now, under UK modern slavery/human trafficking compliance disclosure requirements, an organisation with UK£36 million turnover that is selling goods and services in the UK is required to annually publish a slavery statement demonstrating what they are doing as regards ensuring that there is no slavery in the business or the supply-chain – this requirement also applies to organisations based outside the UK selling goods & services into the UK. By way of reminder, the end of June 2017 is a key deadline as, for many organisations, the statement must be published by then.
A key part of modern slavery compliance is training. One aspect of that should be about spotting the signs of modern slavery. We have produced a short video here that looks at some of those aspects, including the following points:
- A person is acting as though they are being instructed or coached by someone else;
- Someone is telling their story with obvious errors;
- A person allows others to speak for them when spoken to directly;
- An individual may have been subject to trauma causing them to act with hostility or have difficulty in concentrating;
- Someone is not in possession of their own passport, id or travel documents;
- People are dropped off and collected from work in a non-voluntarily manner;
- A person is withdrawn or they appear frightened or have physical indicators of slavery such as injuries;
- An individual does not seem to be able to contact friends or family freely;
- A person has limited social interaction or contact with people outside their immediate environment;
- A person’s clothes are not right for their working environment;
- An individual has few possessions;
- A person has little or no control over their finances or no access to a bank account, or they are being significantly overcharged for their accommodation; and,
- People are living in a very poorly maintained and overcrowded place.
This list is by no means exhaustive–often you will also build up a picture of a person’s circumstances which may indicate something is not quite right. A person may of course display a number of the indicators set out above but they may not necessarily be a victim of slavery or trafficking. However, if you have a gut feeling that something is wrong you’re probably right. If you have a suspicion, report it, either through your organisation’s reporting procedure or, if there is immediate danger call the special UK government slavery helpline on: 0800 0121 700–don’t try and tackle a situation on your own as dangerous criminals are behind modern slavery and human trafficking.
Keep your eyes and ears open–your awareness and actions could save someone from this terrible plight!
We offer a modern slavery compliance service – for more details see here. For more information please contact André Bywater or Jonathan Armstrong who are commercial lawyers with Cordery in London where their focus is on compliance issues.
André Bywater, Cordery, Lexis House, 30 Farringdon Street, London, EC4A 4HH
Office: +44 (0)207 075 1785
Jonathan Armstrong, Cordery, Lexis House, 30 Farringdon Street, London, EC4A 4HH
Office: +44 (0)207 075 1784