In this week’s guest blog, we are pleased to welcome Phil Brewer, Specialist Advisor on Modern Slavery from the Human Trafficking Foundation. Phil was previously a Detective Superintendent in the Metropolitan Police, responsible for investigations into modern slavery and criminal exploitation. In this blog, he explains the red flags to watch for and offers guidance on how businesses can safeguard these vulnerable workers and protect themselves.
When I first joined the police force, I never imagined I’d end up where I am today. It happened completely by accident and has since taken over my life. I’m deeply fascinated by the complexities of human trafficking, but knowing my work can make a difference – even to just one person – makes it worthwhile.
The truth is, virtually any organisation, in any sector, is vulnerable to exploitative labour practices. Whilst not all cases are as serious as modern slavery, breaches like paying below minimum wage contribute to many employees facing exploitation. This can range from not being paid correctly and poor working conditions to more extreme cases where workers are physically or psychologically coerced and find themselves bonded to their exploiters.
The cleaning industry is one area where exploiters are active. The high turnover of staff together with the (inaccurate) perception that is a low-skilled role make it seem like an easy target. What’s more, the nature of cleaning work makes it easier to hide workers and reduce the risk of being caught: Cleaners typically work at night or when business is quiet, minimising their visibility and ability to strike up conversations or build relationships with other employees on-site.
Identifying exploitation can be tricky because some indicators might not necessarily point to someone being exploited. It’s difficult because we often look for clear red flags, but in cases of modern slavery or exploitation, the signs aren’t always obvious.
It’s important, therefore, to take a step back and look at the situation objectively. Consider this: a colleague who arrives hungry, is dropped off early and picked up late, who often appears quite dishevelled, doesn’t always look like they’ve had enough sleep, keeps to themselves, and avoids conversations about their personal life. These signs can create a gut feeling that something isn’t right. Or they could indicate various other innocuous scenarios, from a difficult home life to simply being shy.
The key is to look at the big picture and speak with people that you trust. If something feels ‘off’, discussing it with a colleague or your boss can provide reassurance on whether something really isn’t right. There are options you can take to raise concerns without necessarily feeling like you’ve made a wrong call.
If you’re concerned about a colleague, should you address it with them directly or go to your company’s HR department? It really depends on your relationship. If you’re comfortable and it feels right, then definitely talk to them directly. Going through HR can feel like a formal, official route and it might be that you’re better placed to find out additional information. On the other hand, you could overstep boundaries and cause offence. In this scenario, it is wise to flag your concerns with HR or your line manager first. This offers reassurance that you’re not getting involved in something you shouldn’t, as well as helping to avoid potentially frightening somebody who may already feel vulnerable.
If you need to report or get help regarding modern slavery, I recommend contacting unseen. This organisation is a UK based charity, which runs the Modern Slavery and Exploitation Helpline. You can call them on 0800 0121 700 to report your suspicions and receive support and advice. They offer guidance to a range of people, including individuals, businesses, and even the police. If it’s an emergency, don’t hesitate to call 999.
Other charities can also help businesses educate themselves and feel more confident with where to seek help and what processes to implement for their company. Hope For Justice, for example, provides a free 30-minute course around modern slavery and human trafficking.
There are several steps companies can take to ensure that they are doing right by their workers, especially when dealing with subcontractors or agency workers.
Ensure employees are informed about their rights regarding minimum wage and working conditions. If you’re already running a legitimate business, why wouldn’t you share this information with staff anyway? It can trigger important conversations to say, ‘that’s not happening to me’. For instance, once they understand their rights, a worker might realise that they are being exploited if they learn that their agency is taking a significant portion of their earnings. Over the years, I’ve come into contact with victims who just didn’t recognise their own exploitation because they believed their situation was normal or better than their previous circumstances. Conversations about rights, pay, and working conditions can help them recognise the situation they are in and that they deserve better.
Companies should establish clear policies and processes for reporting concerns about other workers. Options like the previously mentioned Modern Slavery Helpline offer anonymous reporting, which can be reassuring for those hesitant to come forward.
When hiring cleaning services, organisations can look for companies that voluntarily publish modern slavery statements, even if they don’t meet the £36 million turnover threshold for mandatory reporting. This indicates a commitment to moral and ethical practices. There are also opportunities when writing up contracts with your cleaning service provider – for example, include clauses about checking visas and documents, and inform agencies that regular checks may be performed.
If you are hiring cleaning operatives directly, there are some basic checks that can be implemented, especially when employing a large number of workers. For example, ensuring that each employee has a different bank account can be crucial. In one case I dealt with, several workers were being paid into the same bank account, which was a clear red flag. Simple measures like this have a big impact.
On a personal level, just having that conversation with cleaners working on your premises can make a difference. It’s a good way to build trust and make them feel part of the team – and if there is anything untoward, they are far more likely to disclose any issues than if you treat them as an invisible worker in the background. Keeping the door open for dialogue, rather than waiting for a crisis is crucial – when someone in an exploitative situation feels ready to seek help, they need to know they can trust you and that support is available.
There’s a huge responsibility to implement these processes and actions and demonstrate a proactive approach to the potential exploitation within your supply chain or daily operations. Even if you’re not required to provide a modern slavery statement, the discovery of exploitation within your business can put you in a difficult position. It’s worse if it attracts media attention, which can severely damage you or your company’s reputation.
Tune into to episode five of Keep it Clean, a podcast from Jangro, to hear Phil talk more about how we can prevent exploitation and modern slavery within the cleaning industry. To find out more about the Human Trafficking Foundation and its work, visit https://www.humantraffickingfoundation.org/.
For more support or to report any concerns, contact the below charities:
https://www.modernslaveryhelpline.org/
More blogs filled with other voices in the industry are coming soon.