Deconstructing modern slavery

More than two-thirds of attendees at a recent webinar on modern slavery in the construction industry said they were either just starting to address the issue or hadn’t started at all yet. At the end of the webinar, all the attendees felt that their organisation was at risk and indicated that they would be beginning an initiative on the issue immediately or very soon.

The webinar featured Karen Gray for LexisNexis, Jantine Werdmüller von Elgg from Stronger Together, Shamir Ghumra at building firm BRE, and Ian Nicholson from Responsible Solutions.  The construction industry’s particular risks in terms of exposure to modern slavery come from a number of areas, from labour and from materials, but also because of fragmented supply chains, transient employment and labour sub-packaging. In the United Kingdom, the Modern Slavery Act came into effect in 2015, requiring commercial organisations operating with an annual turnover of £36 million or more, to “prepare an annual statement on the steps the company has taken, if any, to ensure slavery and human trafficking is not happening in its own business and supply chains.” But Nicholson noted that companies that don’t meet the threshold cannot afford to ignore the requirements of the Act. Many smaller organisations will be working for larger ones that will eventually want to examine all the way down the supply chain. In addition, he said, prevention is better than a cure. While not too many cases have been found on British soil, the global nature of many organisations means that risk may not be at home.

Webinar coverage

Introduction to ethical labour issues in the sector
Why construction firms of all sizes should respond to the modern slavery commitments and legislation
What should good practice look like?
What should you do if you are an employee and you suspect human trafficking?
How can the industry help the sector and itself?
How can business measure progress and demonstrate success?
If you could only do one thing after today, what should that be?




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The question of measurement of progress and success was key to the discussion. Ghumra described an effort called Labour Sourcing Standard, a verification approach. “We are not trying to create something,” he said, “that is a requirement about how well an organisation is doing, but more about the commitment that the organisation is making to continuously improve.” Gray noted that many companies simply went for a zero-tolerance standard for reputational reasons, as well as moral and ethical ones. Von Elgg said it was important to set clear Key Performance Indicators (KPIs). Every business will have to do their own risk assessment,” he said, “and analysis to decide on their key risks and areas of work. It is important every business sets their own clear KPIs as well, so they can measure their progress at the end of the year.”

“Whenever we talk about statistics, we should keep in mind that behind every statistic is a person. That is what we ought to do as businesses and as individuals when making decisions, think about those people that are being held in exploitation and how we can create change for them.”
Jantine Werdmüller von Elgg, Stronger Together



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During the question and answer session at the end of the webinar, the panel provided some examples of KPIs. These are given in Box 2. Gray called on companies to devote significant resources to the process and to enhance the due diligence process, working with HR, the legal department and the compliance department. Another question asked about human rights due diligence, and the panel responded by referring to the UN Guiding Principles Reporting Framework, which says that human rights due diligence is: “An ongoing risk management process … in order to identify, prevent, mitigate, and account for how [a company] addresses its adverse human rights impacts. It includes four key steps: assessing actual and potential human rights impacts; integrating and acting on the findings; tracking responses; and communicating about how impacts are addressed.”

Some examples of KPIs

Requiring [all staff/staff working in [specify countries]/supply chain managers/HR professionals] to have completed training on modern slavery by [date];
Developing a system for supply chain verification [in place since [date]/expected to be in place by [date], whereby the organisation evaluates potential suppliers before they enter the supply chain;
Reviewing its existing supply chains [completed on [date] expected to be completed by [date], whereby the organisation evaluates all existing suppliers.

Nicholson added that it was important to start with a supply chain mapping exercise to know what the supply chain is and develop a risk assessment. “Show your actions against that risk assessment to start to show the progress that you are making,” he added. Von Elgg also stressed collaboration with others, which was possible through several of the organisations represented on the panel. And another question brought up the issue of collaboration that might prevent duplication. Ghumra said that at the Supply Chain School, supply chains are often shared. “What we often find in procurement,” he continued, “are pre-qualification questionnaires to be completed by clients, major contractors and throughout the supply chain. At present, these are variable, there is a demand from the sector to simplify and standardise them.” The school is working with the leading pre-qualification systems in the United Kingdom on developing common core parameters regarding modern slavery questions.

“We need to find ways in how we are looking at performing, how we are measuring, how we are reporting, monitoring our activities, and being able to be more transparent. The intent and ethos of this issue is that by being more transparent, we will get better over time.”
Shamir Ghumra, BRE

Finally, an attendee noted the poor record of social compliance audits over the last 20 years and wanted to know how this situation could be improved significantly. The panel announced that, with the Chartered Institute of Building (CIOB), Stronger Together will launch a “Tackling Modern Slavery in the Construction Sector” programme in February. This programme is based on a similar programme that S2T has already rolled out in the consumer goods industry, which brings together retailers, suppliers, sub-contractors, and labour providers to work on tackling modern slavery together. The programme will be launched on 16th February in the House of Lords.