Modern Day Slavery in Procurement


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October 14, 2021

Modern day slavery is the illegal exploitation of people for personal or commercial gain. Victims are trapped in servitude, which they were deceived or coerced into, and cannot leave. These can include sexual and criminal exploitation, forced labour, and domestic servitude, with examples including forced marriage as part of the modern slavery act in the UK and organ harvesting, with people being trafficked to the UK for their organs to be sold on the black market.

More people are now being manipulated and controlled under these circumstances by either corrupt organisations, organised crime, or family members, currently with 40.3 million victims worldwide. The number of victims estimated in the UK is to be 13,000. More often than not, this happens when individuals feel they have no other choice in order to support themselves and their families. The best way to think about slavery is the CHOICE, and they may be controlled through things such as passports bank cards kept from them.

In this webinar, we discuss the role of Modern Day Slavery in the supply chain, how it affects every one of us, and how we need to educate ourselves on the system and try and prevent the carrying out of slavery.


Helen Carter: Lead consultant at Action Sustainability for the last 13 years. Having been in procurement for many years, her background is in sustainable procurement, and she now works with corporate clients. When the legislation came out, she moved to work within the BSI panel and now works within the construction industry, where she has lots of knowledge on the matter!


As large organisations are busy with day-to-day work, exploitation factors such as discrimination, bullying or 0-hour contracts are passed down on the supply chain to deal with.

Exploitation in the UK can be found in agriculture, blood bricks, garment industry such as Boohoo, even on our own soil, domestic servitude or provide services to individuals/families who are mistreated, nail bars where there have been instances of child labour across the country, car washes, whereby if you pay less than £5 you are paying into the exploitation, and 18% forced labour in construction.

Every day we buy items that have slavery attached to it. Whereby the more we consume, the more slavery we have through our supply chain. We need to recognise when we have consumed it and try to eliminate the use of this.

How is it changing?

The way this is altering is through the legislation on transparency due diligence reporting. Some examples are:

The UK modern slavery act 2015 Section 54

EU Non-financial Reporting Directive

USA – Trade facilitation and trade enforcement Act 2016

France – Devoir de Vigilance 2017

Moreover, companies found guilty of hiring exploited labour could be forced to pay compensation to victims.

Transparency Supply Chain Guidelines, with legal requirements being:

signed by directors, approved by the board, visible on the website, completed six months after financial generated, £36 million turnover, actions are taken to combat slavery, with the guidelines as follows: structure and size of the organisation, sectors of operation, risks within the supply chain, policies in place, KPI, grievances and remediation, training.

Spotting the signs…

On average, three modern slavery crimes are recorded every week in the Thames Valley.

There are signs we can look out for that may indicate someone is a victim of modern slavery, such as:

Manner: appearing shy or anxious,

Appearance: Signs of physical or psychological abuse, looking malnourished or unkempt, appearing withdrawn

Possessions: Have no travel documents/passport, few or no personal possessions, always wear the same clothes/or clothes not suitable for the work they are involved in

Isolation: looking out of place in an area, appearing controlled by those around them, rarely interact and rarely allowed to travel alone.

Furthermore, knowing what to do when you sport the signs is equally as important. Some practicalities of managing this are: take the victim to a safe space if able to, offer them access to food and water, separate potential suspects from victims and speak to victims individually, try to dispel any fears of law enforcement agencies, inform the police or GLAA if you suspect you have a victim of modern slavery.

What is also severely important is don’t feel it is your job to solve it- you need to offer support and help where you can!

Due diligence

The dictionary describes due diligence as “the reasonable steps taken by a person to avoid committing a tort or offence” and applies to modern slavery whereby say something if you see something, as your call could make a big difference to someone’s life.

Organisational due diligence

You need to be looking internally at your own organisation and your supply chain as an extension of your business with the issues as follows.

Accountability: Not just your role, but all the way through your business – making sure who you come in contact with your supply chain aren’t involved with modern slavery

Recruitment: What’s their supply chain pattern, are they using them unethically such as recruitment fees

Training: Continually support and understanding who needs what, and offer transparency

Grievance and remediation: Offering support to victims, such as the CO-OP who supplied Modern Day Slaves with jobs, and with the Salvation Army who offers accommodation, Modern Day Slavery helpline has legal frameworks from the police that make sure victims get what they need.

Supply chain and procurement: We need to start taking responsibility for our supply chains and make sure we ask the right questions!

Measuring and reporting: all about realising how far you are in the supply chain by using the risk assessments to see how many requirements you put into your business and improve transparency.

We’ve got plenty more fantastic industry experts lined up for 2021 to take part in our webinar series. If you’d like to find out more or to get involved as a speaker yourself then please get in touch with Robert Taylor.

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