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Modern Day Slavery in the UK – A Cause For Concern?


In October, I was invited by Materials Recycling Weekly (MRW) to take part in a round table discussion on the subject of modern day slavery in the waste and recycling sector. The session was prompted by some recent events relating to modern day slavery in our industry that were covered by MRW which has launched its own campaign against this practice – called Root it Out.

The session was chaired by MRW and was attended by representatives from across the spectrum of organisations affected by these issues. My attendance was as Director of NRC speaking on behalf of our Members – and therefore the local and regional waste management sector. Prior to the session, I obtained feedback from Members on their experience of the subject.

Modern Day Slavery in the UK has a few guises and covers a number of areas.  During our session it became clear that this is a very real problem in our industry today and affects all organisations, large and small – in fact the most recent cases have affected the larger players. I have decided to use this blog as an opportunity to raise awareness of the issues discussed during the session.

So, what is Modern Day Slavery?

Modern slavery is where one person controls another by exploiting a vulnerability. It is often linked with human trafficking, where a person is forced to act against their will – usually through work or prostitution. The control can be physical, financial or psychological.

The signs of modern slavery can manifest in four key areas:

  1. Sexual Exploitation – a person trafficked for sex may be controlled by violence, threats, substance abuse, deception or grooming, with extreme physical or psychological domination.
  2. Forced Labour – forced labour is work done under the threat of a penalty such as violence or harm to family. Victims are often further controlled by debt bondage.
  3. Domestic Servitude – a person is forced to provide services with the obligation to live on or in a property without the possibility of changing those circumstances.
  4. Organ Harvesting – a person who is trafficked and specifically chosen for the harvesting of organs or tissues, such as kidneys, liver etc. without consent, to be sold.

General Indicators of Modern Day Slavery

There are some general indicators that could alert an employer or employee that their colleague is being exploited.

Trafficking victims are often lured into another country by false promises and so may not easily trust others. As such, they may be unaware they have been trafficked. They may also:

  • Be fearful of telling others about their situation, including police/authorities;
  • Be fearful of the trafficker, believing their lives or family members’ lives are at risk if they escape;
  • Exhibit signs of physical and psychological trauma e.g. anxiety, lack of memory of recent events, bruising, untreated conditions;
  • Be regularly moved to avoid detection;
  • Believe they are simply in a bad job where they’re unpaid or paid very little;
  • Have limited access to medical care and freedom of movement;
  • Appear to be in debt to someone;
  • Have no passport or mention that someone else is holding their passport;
  • Be controlled by use of witchcraft eg Ju Ju.

For our sector it looks as though staff employed for recycling, specifically Material Recovery Facilities (MRF), are where this practice is most likely – this is called Forced Labour. Many organisations operating MRF’s or other waste picking activities need a flexible staff rota, low skilled staff, quick response to demand and at the lowest cost possible – more often than not, our sector employs these staff through third party labour supply agencies – therefore the challenge is to know if the people supplied have been properly vetted.

Many of the staff supplied do not speak good English, or at all, and could even be from a homeless background – where despite the threat to their liberties they actually have better living conditions than on the street – so may even be reluctant to be “rescued”.

There are specific issues for individuals being forced to work that may become evident as they spend more time in an organisation.

Forced Labour

This is where all the work is done under the menace of a penalty or the person has not offered himself voluntarily and is now unable to leave. They may experience:

  • Threat or actual physical harm;
  • Restriction of movement or confinement;
  • Debt bondage ie working to pay off a debt or loan, often the victim is paid very little or nothing at all for their services because of deductions;
  • Withholding of wages or excessive wage reductions;
  • Withholding of documents eg passport/security card;
  • Threat of revealing to authorities an irregular immigration status;
  • Their employer is unable to produce documents required;
  • Poor or non-existent health and safety standards;
  • Requirement to pay for tools and food;
  • Imposed place of accommodation (and deductions made for it);
  • Pay that is less than minimum wage;
  • Dependence on employer for services;
  • No labour contract;
  • Excessive work hours/few breaks.

The recent issues of forced labour in MRF’s has exposed the fact that despite larger organisations having high levels of support, resources, policies and procedures, they are still participating in this immoral practice. This further highlights the extra challenges felt by smaller organisations, where limited resources can make uncovering these practices a real challenge.

Therefore, it is interesting that the current requirement for organisations to develop Modern Day Slavery policies only covers organisations with a turnover above £36 million per annum. While developing a policy isn’t the answer in itself, it does act as a key driver to raising this issue to a wider audience – so, we question whether this threshold needs lowering.

Attending the session were a number of NGO organisations and some ex-police officers with particular experience in this area.

Their observations and experience were enlightening and my thoughts on how we might manage this increasing challenge are as follows:

  • Are employers confident that the picking line staff on site are not being forced to work?
  • How thorough are checks on the labour supply company to ensure that their processes are robust?
  • Do some of the picking line employees keep themselves separate from the group?
  • Is someone speaking for them?
  • Are the current labour supply rates the cheapest around – if so, why? – perhaps it’s cheap for a reason.

It needs to be made clear that there are organisations available to help – to advise, review your operations and systems, to train your staff or to provide guidance.  Taking time to talk to the staff about themselves and their lives could highlight concerns.

I don’t believe that any professional organisation sets out to employ staff that are being forced to work. However, we are dealing with highly organised crime – and criminals can be very shrewd in the practices they adopt to place these staff in reputable companies.

The group came to a consensus on what will be progressed by MRW and its Root it out campaign. The starting point was to raise awareness of Modern Day Slavery in the UK to help all organisations in the sector get a deeper appreciation of the issue and how to overcome it.

In the short term, if we can get every employer to take a few minutes to ask those vital questions about some of their employees and to validate their current suppliers, we could start to make an impact.

With interest in modern day slavery on the rise, we hope that this blog will help to increase awareness around the issue, and we look forward to working with MRW and its Root It Out campaign as they take it forward.

For more information about NRC’s services and expertise, contact NRC on or 0845 299 6292.