Modern slavery

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Does your business have appropriate policies and practices to prevent modern slavery?

Question collaborator: Anti-Slavery International


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Modern Slavery is a widespread, complex global human rights abuse taking a number of different forms. It encompasses child slavery, bonded labour, forced and compulsory labour, descent-based slavery, early and forced marriage, and human trafficking. The 2016 Global Slavery Index estimates there are 45.8 million people living in some form of modern slavery globally. It is worth noting that estimates are difficult, given slavery’s often hidden nature, and definitions do vary. However, all researchers and NGOs agree that slavery remains a grave human rights abuse. For the purpose of this question, the term “modern slavery” is used as an overarching term to describe one or more of these practices.

According to the ILO’s most recent figures, 14.2 million of those working under conditions of forced labour are in the private economy – primarily in agriculture, construction, domestic work, manufacturing, mining and utilities – it has become increasingly clear from both government and civil society perspectives that business must play an integral role in the fight against this global crime. The Modern Slavery Act was passed into Law in order to tackle modern slavery in the UK, thereby making ‘commercial organisations’ with a turnover of more than £36 million legally accountable, by making them publish an annual statement on slavery in their own organisation and their supply chains.

The protection of human rights is embodied in international laws and several conventions that are binding on nation states where countries have ratified international conventions. These requirements will be reflected in most national laws. The UN Guiding Principles on Business and Human Rights (UNGPs) “apply to all States and to all business enterprises, both transnational and others, regardless of their size, sector, location, ownership and structure.” These principles establish that all businesses have an explicit role in the realisation of human rights through a responsibility to respect them, to take steps to avoid infringing on the rights of others, and to address any adverse human impact as a result of their corporate activity. The UNGPs are built on the “Protect, Respect and Remedy” framework and apply to all human rights issues. Notably, it challenges businesses to identify, prevent, and end human trafficking and to ensure that no forced, bonded or child labour is engaged in the production or sourcing either of its own organisation or across its supply chain.

Abuse of labour is not an issue limited to developing countries. Human trafficking is the fastest growing crime around the world today. The International Labour Organization (ILO) estimates that almost 21 million people are victims of forced labour worldwide and conservative research from 2012 estimated trafficking victims as comprising some 44% of this figure. Given the nature of modern slavery, it is very difficult to conduct any accurate calculations. However, based on the 2014 global estimate of human trafficking, the ILO has calculated that illicit profits from the use of forced labour in the private economy amount to US$150.3 billion.

Forced labour, often as a form of human trafficking, occurs in every country, including the United Kingdom. In 2013, the UK National Referral Mechanism (NRM) received 1746 referrals of potential victims of trafficking. This number increased to 3805 cases in 2016. Estimates of numbers of trafficking victims in the UK had ranged from 10,000 to 13,000, but this has been revealed to be only the tip of the iceberg. Forced labour occurs primarily in industries that depend on casual and temporary labour, offer low wages and predominantly use subcontractors, making it hard to track along the value chain. Such abuses are most likely to be found in agriculture (along with related businesses, such as food processing and packing), construction, the services sector (restaurants, hotels, domestic work and care homes) and the sex trade. As well as causing damage to the individual, the criminal activity generally associated with forced and bonded labour may also have negative effects on wider society. Governments also face a loss of tax revenue.

All businesses, whatever the service provided or trade offered, product sold or money invested, are potentially at risk of being affected by modern slavery in their organisations or value chain, with consequent potential legal, operational, financial and reputational damages. However, there are identifiable risk factors:

  • Forced labour is likely to be most prevalent where sourcing or other processes occur in countries with inadequate regulation or weak enforcement
  • High-risk industries include those which involve raw materials and employ methods which are arduous and hazardous
  • Industries which rely upon a low-skilled and temporary workforce with fluctuating seasonal work also carry a higher risk of exploitations, as do those which rely on migrant workers
  • Competitive pricing models can increase the chances of forced labour as pressure is passed down the chain to reduce costs
  • The risk of having forced labour in the value chain will vary subject to the complexity, sector and locations of value chains involved.

Some forced or bonded workers may be trafficked children. Children may also take on work ‘voluntarily’ as a means of survival, a phenomenon that the UNGPs aim to end. However, many children work within their family or their community as a way of gaining knowledge and skills they will need in adult life, such as subsistence farming or craft work. As pointed out by the United Nations Children's Fund (UNICEF) and other child and labour advocacy groups, the question of acceptable or unacceptable work done by those under 18 years old is a complicated one that is dependent on numerous factors, including the child's age, type of work and conditions they work in. A blanket ban on ‘child labour’ would be unfortunate if it affected children safely engaged in useful work that contributes to their family.

Besides the UNGPs, there are other guidelines promoting best practices for businesses in how they respect the rights of children. A prominent example is “Children's Rights and Business Principles” published in 2012 by UNICEF, the UN Global Compact and Save the Children. The ILO also promotes tools and guidance to identify and combat forced and bonded labour.

However, there is still considerable controversy over the best approach to ensuring that modern slavery is not part of the value chain. Many businesses and NGO practitioners doubt the value of ‘ethical auditing’ of value chains, which has a poor track record in identifying cases or promoting change. Instead a combination of strategies is advocated: risk analysis to identify the parts of value chains most likely to engage in modern slavery; human rights investigations of those value chains to identify any wrongdoings; and potential remediation. This often involves promoting freedom of association, credible complaints procedures, and working with local civil society and government to bring about systemic change.

Modern slavery is a widespread, complex global crime taking a number of different forms. It encompasses child slavery, bonded labour, forced and compulsory labour, descent-based slavery, early and forced marriage, and human trafficking. For the purpose of this question, the term “modern slavery” is used as an overarching term to describe one or more of these practices.

The various types of modern slavery include one or more aspects set out in this glossary section.

Bonded Labour

'Bonded labour' is the most widespread form of slavery in the world. A person becomes a bonded labourer when their labour is demanded as a means of repayment for a loan.

Child Labour

'Child Labour': According to the ILO, there are over 200 million child labourers around the world. Child labour is not slavery, but nevertheless hinders children’s education, development and future livelihoods. For example, children who are working below the legal minimum age for employment. Not all work done by children (defined as human beings below the age of 18) should be classified as child labour that is to be targeted for elimination. “Child labour” is a much narrower concept than “child work” and refers to children working in contravention of ILO standards contained in Conventions 138 and 182 and the UN Convention on the Rights of the Child. This means all children below 12 years of age working in any economic activities, those aged between 12 and 14 engaged in work that is more than just light work, and all children engaged in the worst forms of child labour (children being enslaved, forcibly recruited for armed conflict, prostituted, trafficked, forced into illegal activities or hazardous work (work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children)).

Child Slavery

According to the [1956 UN Supplementary Slavery Convention]
(, “any institution or practice whereby a child or young person under the age of 18 years, is delivered by either both of his natural parents or by his guardian to another person, whether for reward or not, with a view to the exploitation of the child or young person or of his labour” comes under the definition of 'child slavery'.
Children who come under this category [include those who are] (

  • used by others who profit from them;
  • in forced labour (in agriculture, factories, construction, etc.);
  • forced to take part in armed conflict;
  • child domestic workers and those engaged in “hazardous work”;
  • child trafficking and child marriage
Child Work

'Child work': Some types of work make useful, positive contributions to a child's development. Work can help children learn and develop particular skills that will benefit them and the rest of society. According to the UN Convention on the Rights of the Child, parents are not prohibited from expecting their children to help out at home in ways that are safe and appropriate at their age. If children help out in a family farm or business, the tasks they do be safe and suited to their level of development and comply with national labour laws. Children's work should not jeopardize any of their other rights, including the right to education, or the right to relaxation and play.

Decent-based Slavery

'Descent-based slavery': This describes a situation where people are born into a slave class, caste or group viewed as being in slavery by other members of their society. Even though slavery is prohibited by international law, descent-based slavery can be so culturally ingrained in some sections of societies (e.g., Niger, Mauritiana, India, etc.) that challenging its existence can be very difficult.

Early or Forced Marriage

'Early and forced marriage': Child marriage can be said to be slavery if the child:

  • has not given their free and informed consent to enter the marriage
  • is subjected to control a sense of “ownership” in the marriage itself (through abuse, threats, exploitation to undertake domestic chores within or outside the marital home and/or engage in non-consensual sexual relations)
  • cannot realistically leave or end the marriage, leading potentially to a lifetime of slavery.
Forced Labour

'Forced labour' is defined by the ILO Convention No. 29 as all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily. The individual may be paid little or no wages for the work. Another example is an employer holding the identity papers or travel documents of workers so they are unable to leave their employment. The ILO indicators of forced labour are: Abuse of vulnerability; Deception; Restriction of movement; Isolation; Physical and sexual violence; Intimidation and threats; Retention of ID documents; Withholding of wages; Debt bondage; Abusive working/living conditions; Excessive overtime.

Human Trafficking

The UN defines 'Trafficking in persons' as “the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs.”

The Kafala System

The Kafala system is (meaning ‘sponsorship’ system) is a system used to monitor all migrant labourers working in Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates, and most in Jordan and Lebanon. The system gives sponsors a set of legal abilities to control workers: without the employer’s permission, workers cannot change jobs, quit jobs, or leave the country. If a worker leaves a job without permission, the employer has the power to cancel his or her residence visa, automatically turning the worker into an illegal resident in the country. Workers whose employers cancel their residency visas often have to leave the country through deportation proceedings, and many have to spend time behind bars.

Transparency In Supply Chains (TISC)

'Transparency in Supply Chains' etc is part 6 of the Modern Slavery Act 2015, which seeks to address the role of businesses in preventing modern slavery from occurring in their supply chains and organisations by requiring business to provide a statement every financial year. Guidance has been published to assist businesses reporting on their supply chain.

Value Chain

The 'value chain' of a company is the set of activities that are performed in order to deliver a product or service to the market. It consists of:

  • The supply chain, including raw materials produced by primary industries, non-material resources and the operations performed on them by intermediaries up until supplies are purchased by the company
  • The value delivered by the company itself through its product manufacturing, service development or other activities
  • The demand chain, through which the company’s products or services reach their market through to final disposal, including the distribution and sales to customers by intermediaries.

Forced labour and human trafficking can occur in business operations in a variety of ways:

  • Directly – by employing a trafficked or exploited person within the business or through a subcontractor or recruitment agency;
  • Indirectly – through illegal subcontracting occurring within supply chain or through use of products or materials which have been produced by people under conditions of forced labour;
  • By association – where trafficking occurs within the local area as the result of a company’s operations, or as a secondary consequence of a company’s actions.

Anti-Slavery International points to several characteristics that distinguish ‘slavery’ from other human rights violations. Someone is in slavery if they are treated in one of the following ways:

  • If they are forced to work, through mental or physical threat;
  • If they are owned or controlled by an ‘employer’, usually through mental or physical abuse or the threat of abuse;
  • If they are dehumanised, treated as a commodity or bought and sold as property;
  • If they are physically constrained or have restrictions placed on their freedom of movement.

Answering YES

All Businesses MUST

Describe their business sector and number of employees

Describe their organisational structure, their business and their value chains

Describe any policies they may have which relate to slavery and human trafficking

Describe any due diligence processes in relation to slavery and human trafficking in business and value chains

Describe any parts of the business or its supply chains where there is a risk of slavery and human trafficking taking place, and the steps they have taken to assess and manage that risk

Explain whether they have been effective in ensuring that slavery and human trafficking is not taking place in the business or in its value chains, measured against such performance indicators as are considered appropriate

Describe any training about slavery and human trafficking which is available to staff

Identify how your business model may create pressure points that could facilitate or promote modern slavery, and what steps have been taken to minimise them

All Businesses MAY

Have this policy signed and endorsed by the director, partner, or a designated member

State where this policy is published on their website and provide a hyperlink, if available

Describe any other good practice they implement, such as setting out directives/guidelines for employees to follow should any form of human trafficking be discovered in the value chain

State whether they are members or supporters of any organisations seeking to improve labour standards or work against trafficking

State how far down their value chains they investigate and describe how that depth of scrutiny is determined

Explain what they would do in the event of uncovering human rights abuses in the value chain

Explain if and how they go beyond minimum legal compliance to ensure best practices

Explain whether they engage with governments on issues that contribute to modern slavery and seek to positively influence the political agenda

Describe how you mitigate risk based on your operating model

Identify key areas of concern or uncertainty relating to modern slavery

Describe how Modern Slavery policies and practices fare when the business faces challenges

Outline the KPIs and conditions relating to human rights and modern slavery in your supplier contract

Explain how you identify high risk customers and clients, and outline which circumstances would lead you to not do business with another organisation, relating to slavery

Large and Multinational Corporations (MNCs) MUST

State how frequently their practices and policies are reviewed

If they operate internationally, state if their policies against human trafficking differ from one country to another

Explain any differences if they exist

Answering NO

All Businesses MUST

Explain why they do not or cannot answer YES to this question, listing the business reasons and other reasons that apply

Explain what actions they have taken to identify and eliminate the risks of forced labour, slavery, human trafficking, and child labour within their supply chains, in the absence of such policies

All Businesses MAY

List any practices that are relevant, but not sufficient to answer YES

Mention any future intentions regarding this issue

DON'T KNOW is not a permissible answer to this question

NOT APPLICABLE is not a permissible answer to this question

Version 5

To receive a score of 'Excellent'

Prevention of forced labour, slavery and human trafficking are strategic business issues

Examples of policies and practices which may support an EXCELLENT statement:

  1. Commitments to detecting and avoiding human rights abuses form part of corporate strategy, which are formally published in the firm’s annual reports
  2. Adopts a comprehensive reporting framework and encourages a pro-active approach to disclosure, e.g. UNGDPs DB, CHRB
  3. Engages in activities that promote better human rights policies and practices amongst regulators, law-makers and governments, and encourages their widespread adoption
  4. All staff are fully engaged with efforts to reduce risks of slavery, as well as board and stakeholders
  5. Effective actions taken to prevent forced labour are measured and monitored, with evidence to support positive results
  6. Several types of focused audits used throughout value chain, e.g. financial, social, ethical, outsourced, with results are used to reduce risks
  7. Build strong supplier relationships and communicate policies throughout value chains with the explicit aim of reducing risks of slavery, e.g. supplier roundtables
  8. Due diligence on modern slavery when awarding contracts or entering partnerships, with clear terms of agreement where expectations regarding respect for human rights are built in
  9. Developing innovative ways to work with the external value chain
  10. Externally cited as having a strong track record in practical ways of protecting labour
  11. Cited as an exemplar in its sector by an independent NGO or industry body not more than 5% funded by the Company
  12. Developed grievance mechanisms which are communicated to all workers, particularly migrant workers, for instance an integrated multi-lingual migrant hotline platform
  13. Training provided to managers and staff on identifying forced labour and human trafficking in practice and seeking necessary assistance, with ongoing assistance made available
  14. Align business strategy, KPIs and operational model with robust independent monitoring in order to minimise the risk of modern slavery
  15. Evidence of progress being made through collaborative initiatives with various stakeholders is clearly and regularly reported
  16. Business explains how and why it scrutinises to a specified depth down its supply chain
  17. Business explains what it would do in the event of uncovering human rights abuses in the value chain
  18. Business investment in best practice on modern slavery has resulted in innovation which has been approved by external bodies, eg NGOs, trade unions
  19. Business explains how it factors legal and fair labour costs into production and sourcing costs in order to mitigate against the demand for cheaper, slave or bonded labour in the value chain
  20. Leads multi-stakeholder initiatives to improve value chains
  21. As part of responsible sourcing contracting, uses leverage to encourage and reward improved conditions for workers and suppliers due diligence regarding human rights
  22. All employees are made aware of signs that someone is subject to forced labour through regular and mandatory training
  23. MSA statement is developed with involvement of board
  24. Efforts to prevent abuses are embedded throughout the organisation
  25. Describes on website how efforts to prevent abuses are financially incentivised and embedded across the organisation with appropriate resourcing and support internally and to suppliers to realise improvements
  26. Clearly describes the business value chains (per UK MSA statement Home Office guidance) in terms of countries, operations, known worker nationalities and foreign contract worker levels involved, etc
  27. Ensures that workers all the way through the supply chain are aware of the labour rights and laws and freedom of association is supported, internal whistleblowers are protected
  28. Publishes online information describing commitments and efforts to address risks of modern slavery and readiness to receive any complaints/reports from consumers or other stakeholders about exploitation in company’s supply chains
  29. Demonstrates that reports from hotline platform are used to improve policies and practices, and performance on reducing risks of slavery
  30. Business has regular discussions with suppliers to ensure its demands/ practices do not create pressure points for suppliers that increase the likelihood of slavery occurring at some point in the supply chain
  31. Company has a dedicated team and sufficient budget for ethical trade in order to implement the policies
  32. Business model designed to minimise creating risk factors for modern slavery
  33. Clearly identified the areas of the value chain that are of greatest risk to human rights, rather than of greatest risk to the business
  34. Engages prominently in public discussion on Modern Slavery and positively influences the political agenda
  35. Asks key questions to suppliers, such as ‘Under what circumstances can you claw back money from your employees
  36. Active monitoring and KPIs’ are consistently put into terms and conditions of supplier contracts
  37. Business uses its position as a large supplier to influence clients to act on Modern Slavery
To receive a score of 'Good'

The business has established clear practices to prevent forced labour, slavery, and human trafficking

Examples of policies and practices which may support a GOOD statement:

  1. Selective reporting of few but not all aspects of their value chain
  2. Statement of philosophy or values with regard to human rights
  3. Clear policies and practices easily implemented across the organisation
  4. Ensures that labour recruitment practices comply with efforts to eliminate practices that lead to forced labour, human trafficking, etc. e.g. staff and other stakeholders engaged
  5. Undertaken audit (or similar) in supply chain or for contractors
  6. Actions to reduce risk of labour abuse measured and monitored
  7. Has a demonstrably good track record in practical ways of protecting labour
  8. Collaboration with various stakeholders to deal with modern slavery in a holistic way
  9. Business explains how and why it scrutinises to a specified depth down its supply chain and across its value chain
  10. Business explains what it would do in the event of uncovering human rights abuses in the value chain
  11. Business explains if and how it goes beyond minimum legal compliance to ensure best practices
  12. Participates in multi-stakeholder initiatives to improve value chains
  13. Growing small business sets targets for improvement for itself once it reaches a certain size
  14. Wide awareness of signs that someone is subject to forced labour
  15. Statements produced under the Modern Slavery Act improve year on year
  16. There is board level ownership that goes beyond approval and signing the Modern Slavery Act statement
  17. Targets in the Modern Slavery statement are realistic
  18. Statement of philosophy or values with regard to modern slavery
  19. Membership of UN Global Compact and/or other relevant bodies
  20. Developed a framework under the UNGPs
  21. Business explains if and how it goes beyond minimum legal compliance to ensure best practices
  22. Gives high quality assurance to clients that there’s no evidence of slavery in the business
  23. Has clear policies and practices and explains how they are being implemented across the organisation
  24. Statements produced under the Modern Slavery Act consistently improve year on year
  25. Transparency about gaps in the business’ knowledge on its value chains
  26. The Modern Slavery Statement gives a detailed, open account of various different policies and practices that are in place to prevent forced labour and trafficking
  27. The Modern Slavery Statement provides a comprehensive overview of its risks, gaps in overcoming these and specific actions to address risks
  28. Business has developed on the ground partnerships with local NGOs, trade unions and worker representatives, etc
To receive a score of 'Okay'

The business has ad hoc policies or procedures for dealing with forced labour, slavery, and human trafficking

Examples of policies and practices which may support an OKAY statement:

  1. Reliance on inadequate policies and processes in reporting – little disclosure or evaluation of human rights risks in their value chains
  2. Explains why not an issue in the particular business sector
  3. Statement of commitment to preventing human rights abuse in its value chain but evidence only of intermittent practices
  4. Explains why not monitored or measured consistently
  5. May piggy-back on published audits by other respected companies for overseas value chain
  6. May use recognised certifications
  7. Complies with legal requirements
  8. Does not knowingly rely on slave labour, but does not take care to investigate to ensure it doesn’t
  9. Slavery has been shown to exist recently in its value chain, but it has acted to rectify it
  10. Statements produced under the Modern Slavery Act are adequate, but don’t show improvement year on year
  11. The Modern Slavery Act statement is approved by the board and signed by a director
  12. Targets in the Modern Slavery Act statement are sometimes unrealistic
  13. Transparency on value chain is limited
  14. Modern Slavery Act statement is not detailed in terms of policies and practices in place to prevent forced labour and trafficking.
  15. Statement of future intent to improve
  16. Investigation of practices within the value chain are limited to direct operations and direct suppliers
  17. Business focuses efforts only on areas of highest risk in value chain, with efforts to target other areas underdeveloped
To receive a score of 'Poor'

No evidence of any practices to prevent human trafficking

Examples of policies and practices which may support a POOR statement:

  1. The business acknowledges performance below expectations
  2. No action apparent
  3. The company has been implicated in slavery and has failed to rectify this
  4. Fails to meet legal requirements
  5. Lack of reporting or investigation of value chains
  6. Preventing slavery and exploitation is not a consideration when making business decisions
  7. Statements produced under the Modern Slavery Act are inadequate or not put into practice
  8. Little to no board level interest or buy in to obligations under the Modern Slavery Act