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Identifying the modern slavery risk in the waste industry

It’s not happening in a land far away, it’s not condemned to the past; slavery is here in the 21st century, happening in organisations around the country, and could be closer than you think.

The UK waste sector has become notorious as an industry that is a prevalent target of human trafficking. Slave-Free Alliance’s founding charity Hope for Justice reported that of all the UK victims they rescued in 2017, around two thirds had been placed within a recycling or waste management facility, providing first-hand insight into the scale of the problem. The large, complex supply chains of nationwide waste management companies mean there are many points of entry traffickers are able to exploit. Alongside this, the sectors heavy use of temporary recruitment agencies specialising in the placement of candidates in undesirable, low skilled roles, further adds to the heightened risk. These roles are regularly filled with workers from backgrounds of limited education, and are often attractive to migrant workers who speak restricted English looking for an entryway job in the UK. Modern slavery victims often fit both of these profiles, allowing traffickers to slip forced labourers that match the typical demographic into waste management networks undetected.

Identify Risk

The risk of exposure to modern day slavery can have ominous consequences, aside from it being an atrocious crime against humanity that needs extinguishing. For businesses who are unprotected, infiltration could have repercussions such as reputational damage, loss of major clients, reduction in company value and at the worst, legal action. This makes developing a robust anti-slavery strategy an essential business priority. The sensible foundation to begin understanding the risks of slavery within any waste management organisation or even individual facility is to undertake a gap analysis to pinpoint areas of weakness that need immediate redress. It’s recommended to work with a partner with practical, organised crime prevention expertise who will leave no stone unturned, such as the experts at Slave-Free Alliance. This ensures the exercised is optimised and tailored to the intricacies of the particular organisation, which allows for the production of enhanced recommendations bespoke to an individual company rather than a generic checklist which may still leave exposed weaknesses.


Perhaps surprisingly, British nationals have recently become the most common nationality of UK slavery victims. This means additional diligence is required when training staff to spot the signs; for migrant workers, one of the typical signs is someone acting as an unofficial interpreter on their behalf, which wouldn’t be the case for a British victim. Upskilling staff to spot universal red flags is essential; some of the indicators are employees who are chaperoned to and from work, who don’t appear to be able to make deviations from this arrangement; physical signs such as malnourishment, injuries, bruising and medical conditions going untreated; psychological signs such as paranoia, fear, agitation, confusion or being extremely withdrawn. These clues all strongly point towards the possibility of enslavement. Modern slavery is a hidden crime, therefore it can be shocking to discover its scale within UK businesses, and there’s a lot that people don’t know, but it’s not something organisations can afford to turn a blind eye to. For those with little time and resource, it’s recommended that at the very least that facilities should look to provide awareness literature placed in visible locations throughout hight footfall employee touchpoints, in various languages for the best possible employee exposure. This should be accompanied with a confidential whistleblowing hotline which gives staff a safe, anonymous way to escalate any concerns. Gaining knowledge and awareness of the signs are some of the best preparatory skills on the slavery prevention journey.

Properly Procure

In order to shield against modern slavery in the wider supply chain, it’s important that internal procurement policies have protective elements that extend high standards of safeguarding practice outside of the organisation. Before the selection and appointment of any supplier, a comprehensive and methodical examination process should be followed to ensure ethical practice and risk management within suppliers, particularly in relation to the threat of modern slavery. Most companies are now clued up modern slavery prevention to some degree, but it may be surprising how minimally known deterrents are practically applied throughout the supply chain. Make sure you choose your suppliers widely to avoid being impaired.

Recruit Consciously

Waste industry recruitment challenges mean ethical sourcing of employees is often put into the hands of external agents. This can be tricky to navigate from a modern slavery perspective; traffickers have been known to place gang members into recruitment agencies as staff, with complicit insiders further masking their illicit efforts to place victims within legitimate businesses. Slave-Free Alliance’s parent charity Hope for Justice only recently identified victims that had been placed in a well-known waste management facility through labour provider targeting. Working collaboratively and transparently with labour providers to understand the issues the waste sector faces and sharing best practice in prevention is advised, as well as putting all outsourced agencies including recruiters through a robust procurement process to ensure responsible sourcing. Carrying out second checks into employee backgrounds and document verification is also advised rather than placing sole reliance on the subcontracted supplier. HR periodic auditing of employee databases, such as a quick check for duplicate addresses in the employee files, is another rapid intervention process that can easily throw up red flags; if there are multiple employees registered at the same abode, there’s likely to be a problem.

How you can help

There’s a world of work to be done to get close to corporate elimination of modern slavery. The actions suggested in this article are the minimum basic preventative measures, but the risk is complex and more must be done. If you’re confused about where to start, Slave-Free Alliance can help your business with our flexible and affordable solutions, suitable for organisations of all sizes.

Let’s end slavery together. By taking proactive action you’ll safeguard your agency whilst also contributing to the worldwide fight against modern slavery; all profits made by Slave-Free Alliance are reinvested in Hope for Justice’s charitable activities.

Contact: 0300 008 0044

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