Modern Slavery in the Workplace

Modern slavery is often thought of as a relic of history, yet it remains a pressing issue in today’s workplaces and supply chains. The UK’s Modern Slavery Act 2015 was a landmark piece of legislation, designed to combat practices such as forced labour, servitude, and human trafficking. Despite this framework, cases continue to emerge across industries, from agriculture and construction to hospitality and logistics.

Labour has committed itself to maintaining the UK’s current human rights framework. In its manifesto, the party confirmed that Britain will remain a member of the European Convention on Human Rights, and no changes to existing legal protections are anticipated. Building on this foundation, on 5 September 2024 the government signed the Council of Europe’s Framework Convention on Artificial Intelligence and Human Rights, Democracy and the Rule of Law, signalling its intention to engage with the challenges posed by new technologies in the human rights arena.

Modern slavery and labour exploitation remain central to the government’s agenda. In its New Deal green paper, Labour proposed introducing joint and several liability across supply chains, ensuring that companies cannot escape accountability where slavery or other criminal labour practices are uncovered. Alongside this, a system of naming and shaming would encourage businesses to undertake rigorous due diligence, with penalties for knowingly participating in supply chains tainted by exploitation.

At its core, modern slavery in employment is about control and exploitation. Workers may be compelled to work under threat or coercion, have their wages withheld, or be trapped by recruitment debts they can never realistically repay. Others may live in unsafe or degrading conditions provided by employers, with little autonomy over their movements or decisions. These are not just moral concerns but legal ones, carrying significant criminal and civil consequences.

For employers, the Modern Slavery Act 2015  created a duty to act. Companies with an annual turnover of £36 million or more must publish an annual modern slavery statement, setting out the steps they have taken to prevent exploitation in their operations and supply chains. Increasingly, large businesses require their suppliers, often smaller organisations,  to demonstrate the same standards, creating a ripple effect through industries. Failing to comply not only carries legal risk but can also cause lasting reputational damage in a marketplace where consumers and investors demand transparency.

In practice, however, compliance goes beyond paperwork. Identifying the signs of modern slavery can be challenging, as victims are often reluctant to come forward. Unexplained deductions from wages, excessive working hours, or workers appearing fearful and isolated can all signal that something is wrong. This is why many organisations are training managers and HR teams to recognise potential red flags and setting up confidential reporting channels to ensure concerns are addressed swiftly.

Recent government reviews have highlighted uneven compliance with the Modern Slavery Act, and reforms are on the horizon. We are likely to see stricter requirements around what must be included in annual statements, as well as greater scrutiny of sectors that rely heavily on agency and temporary labour. Enforcement action is expected to increase, making it essential for employers to keep modern slavery firmly on their compliance agenda.

For employees, awareness of rights and protections is equally important. Any worker in the UK has the right to fair pay, safe conditions, and freedom from coercion. Where exploitation does occur, the law provides avenues for redress, though in reality these cases often rely on vigilance from colleagues, unions, and regulators.

Businesses with an annual turnover of less than £36 million are not legally required to publish a modern slavery statement. However, the statutory guidance on transparency in supply chains encourages smaller organisations to consider doing so voluntarily. In practice, many find that producing such a statement can be useful in managing commercial relationships.

Larger customers and contractors often ask whether their suppliers have a policy or statement in place, particularly as part of their own due diligence processes. Smaller organisations may also encounter these requests when responding to customer questionnaires or when bidding for contracts against larger businesses that are subject to section 54 of the Modern Slavery Act.

By publishing a voluntary statement, smaller organisations can demonstrate a clear approach to tackling modern slavery risks in their business and supply chain. This can help reassure customers, strengthen their competitive position, and ensure they are prepared to meet the growing expectations of the market.

Beyond compliance, a voluntary statement signals a commitment to ethical business practices. It reassures clients, investors, and staff that the organisation takes modern slavery seriously and is proactive about protecting workers in its supply chain. For many smaller businesses, this transparency is a valuable way of building reputation, trust, and resilience in a marketplace where ethical standards increasingly matter.

Modern slavery is not a distant issue, it is a present challenge that touches the world of work in subtle but significant ways. Addressing it requires more than legal compliance; it demands cultural vigilance, ethical leadership, and a recognition that every worker deserves dignity and freedom.

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The information contained in this blog post is provided for guidance and is a snapshot of the law at the time it is written. It is provided for your information only and should not be used as a substitute for obtaining legal advice that it specific to your particular circumstances.

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