How to Prevent Exploitation with your Organisation and Supply Chain

Modern Slavery

Modern Slavery is a crime and a violation of fundamental human rights, and the third most lucrative income-generator for organised criminals. It takes many - horrific - forms, from sexual, labour, criminal exploitation, domestic servitude, and organ harvesting, to human trafficking and people smuggling. With recruitment businesses, including those supplying workers to GLAA industries, central to labour supply and the many challenges, they have a critical part to play in identifying potential modern slavery activities and exploitation - and it all starts with supplier due diligence.

Supplier due diligence

One size does not fit all. Due diligence is not an off-the-shelf solution, especially for recruitment businesses and with so many suppliers and clients in their supply chain, you must create a due diligence model that is fit for and bespoke to their operation and business.

In my opinion, one underused resource in the end-to-end due diligence process is audit reports. These are a powerful tool that in essence tells every organisation's own story, and if the audit process is dynamic, it will reveal any risks which are specific to each individual business.

Audits are not simply a tick-box exercise, the recruiters must take interest in their findings. Desktop audits are fine, but some suppliers in the supply chain may become complacent when using only a desktop audit, whereas a physical audit can be way more valuable and beneficial.

Further, due diligence can't rely on GLAA licensing any more. GLAA no longer has the resource to visit numerous locations to carry out an on-site audit. This is why it is no longer a strong enough claim for a recruiter or business to state they only use GLAA licensed suppliers for labour, because many may not have been GLAA tested for ten years or more.

Instead, it is better to invest in worker engagement, including using worker questionnaires and worker interviews, which paint a real and present picture, and are a good indicator of worker engagement, satisfaction and treatment.

Also, use business partnerships and/or networks to understand how other businesses in your profession and industry carry out their due diligence, and the process and effectiveness of these, and strive for insights of how they measure worker engagement and avoid/mitigate modern slavery, for example.

Worker engagement must be at the forefront of any due diligence. It's essential to utilise workers to fully understand a business, to test processes and build a picture of the reality of how the client's business operates and treats its workers.

Worker engagement

A critical part of the due diligence process, worker engagement is all about talking to people, and an invaluable opportunity to establish if what you are told to be true about a business is true for the workers themselves.

Worker engagement should include questionnaires, which are very useful, but these should be only part of the wider solution. Until you truly engage with workers you won't uncover the 'behind the scenes' day-to-day operations (such as car sharing for workers, which is classifies as a risk), nor find any star workers among them. It's a chance to foster relationships by encouraging them to talk about all sorts of issues, and to create an environment where workers feel important and valued.

The initial onboarding/recruitment process is often well structured with interviews and inductions. But by committing to undertake regular conversations means you have a reboots work interview strategy. After all, the worst thing for worker retention is to put someone in a role and then never speak to them again. Regular conversations enable a recruiter to remain informed on the client/employer, and by explaining to the worker why you want their feedback and that their opinions and experiences matter, will foster positive feelings and value.

Simple steps

Audits and worker engagement should be part of the supplier due diligence process and strategy, and recruiters need to take an interest in their objective, their findings and outputs, in order to ensure workers are being well-treated, and not exploited. Where possible, structure audits to meet your business needs, not all standard audit report templates fit the bill, so it may be necessary to have a bespoke audit carried out for your particular business model.

Try adopting the PEACE Model for due diligence and worker interviews:

Strive for ethical interviewing, by:

Structure interviews so they are non-prescriptive, by varying questions and how they are asked, by including indicators of exploitation or modern slavery by covering:

Avoid:

Remember, worker interviews are just a conversation - as someone once said: "It's good to talk".