STOP THE TRAFFIK’s Risk Typologies

Supporting Guidance for: Assessing your Modern Slavery Risk: A Self-Assessment Scorecard for Public Sector Organisations


Construction is a crucial sector within the UK economy, employing approximately 2.3 million individuals. However, this sector ranks second to the sex industry for the scale of exploitation. According to the ILO, $34 billon of the $150 billion generated by forced economic exploitation globally, is made in the construction, manufacturing, mining and utilities industries. The construction industry is reliant on demographics that are highly vulnerable to exploitation for reasons such as debt bondage and employer-tied visas which make it hard to leave abusive employment.

In addition to worker demographics, the business model, market structure, and payment models contribute to the sector’s nature of being high risk for MSHT (Modern Slavery and Human Trafficking).

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    • Retentions are an amount of money withheld by clients from the contractors, as assurance of project completion. While acting as a guarantee for the client, this can lead to contractors cutting corners around worker pay, health and safety, and holidays.
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    Illegal Working Practices

    • Apart from general breaches of health and safety, union bans, confiscation of identification documents, and poor accommodation, workers also report having accommodation costs deducted from their wages with no rental contract provided.
    • Workers also experienced intimidation to prevent them from reporting malpractice of employers to the authorities or leaving exploitative conditions.
    • Wages below the National Minimum Wage are common, with reports describing daily rates as low as £10 for more than eight hours of work. A survey also found that at least a third of around 100,000 European migrant construction workers in London had done jobs for no pay and experienced verbal and physical abuse.


Companies within the construction sector have a critical role to play in mitigating modern slavery on their sites and in their supply chains. The following steps to start are:

– Increasing collaboration and information sharing with relevant authorities like the GLAA

– Offer staff general and role-specific training about modern slavery, including what it is, how to spot the signs of exploitation, and how to report suspicions

– Accept that modern slavery could exist in your own supply chains and take steps to find out where its most likely to take place to improve transparency

STOP THE TRAFFIK has extensive experience in mapping supply chains to find out where modern slavery is occurring and has done so with many FTSE 100 companies. Please contact us at [email protected] find out more about this service.


Despite generating £50 billion and hiring 1.54 million people in 2020/2021, the care sector is a large industry relied upon by the UK for the care of its population. However, the GLAA (Gangmasters and Labour Abuse Authority) and other NGOs have identified rampant labour exploitation within the sector, such as:

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    Withheld wages and subminimum wages

    • This can be due to wage deductions for training, uniforms, and accommodations, which are common.
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    Debt bondage

    • Some migrant workers are found to borrow money to come to the UK and work in the care sector to pay off that debt.
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    Poor working conditions

    • A notable aspect of this was the lack of PPE during the pandemic.
    • There are reports of accommodation provided by exploiters for care workers often being substandard and overcrowded.

Structural and Demographical Risk Drivers

One major reason for exploitation in the care industry is a trend toward a more decentralized market that is made up of many small organisations, rather than being more centralised and local-authority-led. This means that most providers within the sector do not fall under the income threshold obligating them to the UK Modern Slavery Act (MSA) 2015. This puts millions of pounds of local authority procurement expenditure into businesses that potentially have no modern slavery mitigation measures and do not fall under the MSA.

The workforce that fuels the care sector mainly comes from agencies. This means that there is less oversight over labour standards and transparency over worker checks, even as far as full DBS checks waived during the pandemic to make up for staff shortages. Agency-dominated staff provision also means less unionization of workers and less rights for workers because they’re not permanently hired. These workers are roughly 80% women, some of whom may need the income to support children or elderly parents, which makes it more difficult to stand up to employer malpractice.


– Provide training and awareness for modern slavery that addresses the way someone might encounter it through their role (e.g: role-specific training)

– Require and maintain best practice for employment and working conditions from agencies

– Continue information sharing with relevant authorities like the GLAA

– Perform actual risk mapping to identify which suppliers in the care sector are high risk for modern slavery and policy reviews to assess the robustness of your organisation’s modern slavery mitigation

STOP THE TRAFFIK has extensive experience in performing risk mapping and policy reviews to provide actionable steps for improving mitigation efforts. This knowledge has been applied across many FTSE 100 companies and across over £15 billion in procurement spend. Please contact [email protected] for more information.

Facilities Management

The FM sector accounts for 7.5% of the UK’s GDP, employing more than 10% of the UK workforce. The sector is well-known for its reliance on non-UK nationals to provide labour and services. Recent estimates suggest that around 28% of employees in the sector are non-UK nationals.

Employees in the soft FM sector (which includes services such as cleaning, private security, and gardening & landscaping), are often isolated from the community as they typically conduct their services outside of working hours once others have left the facilities, reducing the touchpoints through which members of the public can identify concerns. Furthermore, within the cleaning there is widespread use of part-time and temporary contract workers and wage deductions to increase profits. Paired with industry-wide low pay, this creates vulnerability to exploitation and financial difficulty among workers.

Common cases of exploitation across the soft FM sector tend to present in the following forms:

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    Recruitment fees and debt bondage

    • Although not necessarily an exploitative practice itself, recruitment fees can quickly change into an employer loan to pay the ‘upfront fees’. This can leave the employee indebted to the employer, making them vulnerable to debt bondage, where the debt is used against an individual to force them into unpaid work.
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    Contract issues

    • Many FM employees are not given proper employment contracts before starting work. This has meant that employers have been laying workers off without adequate notice if they had not been given a contract before the Covid-19 outbreak.
    • This indolent approach to necessary documents can lead to more problematic contractual issues, such as contract substitution, whereby an employee is promised a job, but when starting the role, is required to sign a different contract. Both the conditions of work and the salary might be significantly worse than the original agreed-upon contract.
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    Wage Abuses

    • Unlawful deduction of wages was the most common abuse identified among migrant women working in soft FM, with 51% of women surveyed having deductions to their pay. There were also cases where women were denied overtime pay, sick pay, or payment during statutory annual leave.
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    Human trafficking

    • In extreme cases, exploitation can move from ‘lighter’ forms of labour exploitation, such as wage deductions or working overtime, to more serious exploitation, such as the restriction of movement, the withholding of documents, and minimal to no pay.


STOP THE TRAFFIK recommends the following areas to focus on for enhanced due diligence. These criteria can be evaluated for both existing suppliers using self-assessment questionnaires (SAQs) and can also be included in the standard approved vendor list (AVL) process. The necessary criteria that suppliers must comply with are that:

  • Suppliers operate by the “Employer Pays” principle, as this can help mitigate the risk of financially vulnerable workers (i.e: migrant workers) falling into debt bondage.
  • Workers are paid the national minimum wage (NMW), not just by policy, but also in real terms in view of the issues of pay deductions.
  • Workers are assured the freedom of movement and association to mitigate risks of exploitation worsening into more severe forms.
  • Workers are paid for sick leave, overtime, and annual leave.
  • Workers not only have work contracts in place, but that work contracts are not substituted upon the arrival of the workers.
  • Workers are provided clear and transparent information on:
    • What their rights are and,
    • What grievance mechanisms and remediation processes are for when non-compliances take place.

STOP THE TRAFFIK has extensive experience in performing risk mapping and policy reviews to provide actionable steps for improving mitigation efforts. This knowledge has been applied across many FTSE 100 companies and across over £15 billion in procurement spend. Please contact [email protected] for more information.