In July 2020, an undercover report found workers in Leicester making clothes for online fashion retailer Boohoo being paid as little as £3.50 an hour. Later in December 2020, the Guardian published another article alleging that Boohoo was selling clothes made in a factory in Pakistan where workers were earning as little as 29 pence an hour.
Figures from last year reveal that almost 30 modern slavery victims were found every day in the UK last year. Latest estimates from the International Labour Organization also show that modern slavery and forced labour affects almost 25 million people worldwide.
With the increase in public awareness, there is growing pressure on UK-based retailers from investors to comply with modern slavery laws. Remaining diligent about ethical supply chain practices will set retailers in good stead, both ethically and legislatively speaking.
Performing due diligence is also best practice when it comes to protecting your brand and meeting customer requirements - after all, being linked to human trafficking and labour exploitation is extremely damaging to the credibility of any retailer, and rightfully so.
So how can retail businesses ensure ethical supply chain practices? Here are five Modern Slavery controls all retailers ought to practice.
Make a commitment
All large companies with an annual turnover of £36m or more are required to publish annual statements on what they are doing to tackle forced labour in their operations and supply chains under the 2015 Modern Slavery Act. However, it's still important for smaller retailers to make a strong commitment against modern slavery.
Assigning board level responsibility for these best practice policies and laying out what the company wants to achieve in preventing modern slavery will help retailers take meaningful action.
Establish good recruitment practices
Experience shows that the recruitment stage is often where workers are most at risk from modern slavery exploitation, especially where third party labour recruiters are involved, and even more so where workers are migrant. Therefore, retailers must pay particular attention to the recruitment process.
Ensure you establish due diligence checks when appointing labour providers and develop a written policy stating that the cost of recruitment is a business cost, not to be passed onto workers.
Good record-keeping and monitoring
Ensure you establish checks of workers' home addresses and check occupancy figures here (those held in modern slavery are often housed in overcrowded, cramped conditions). Migrant workers should have access to their passports and companies should check bank accounts to identify wages aren't being collected by one account.
Team leaders/supervisors should be comfortable monitoring, recording, and reporting any concerning signs in the physical wellbeing of employees, e.g., bad hygiene, extreme fatigue, or malnourishment. They should feel comfortable approaching workers informally to discuss any issues.
Assess where your greatest risks are (then act to tackle them)
Draw up an initial high-level assessment of your supply chain, including direct and indirect suppliers, labour providers and contractors to identify low, medium and high-risk suppliers (consider, for example, using self-assessment questionnaires to gather information from potential suppliers).
Based on your available resources, take immediate steps to reduce the risk of any high-risk suppliers, e.g., by requiring them to establish grievance or whistleblowing procedures. Ensure you develop channels for gathering and managing any future risk information.
Most employees are not even aware that modern slavery is an issue – that's why training must start by raising awareness on the subject and presenting facts/figures on the severity of modern slavery in the UK and around the globe.
As well as training managers/supervisors on particular red flags to look out for in employees and how to raise and report these issues, employees across the board will benefit from awareness training which provides the tools and knowledge they need to identify and report concerns about modern slavery.
How can we help?
Increasing the levels of transparency and awareness are paramount when it comes to complying with modern slavery laws. Retail businesses can use awareness training to empower employees to spot the red flags of modern slavery and educate them about its prevalence and the areas it's more likely to take place.