Firms on front line against trafficking and exploitation

Guidance launched as Justice Secretary calls on businesses to take responsibility.

Practical guidance has been produced to help businesses identify and prevent human trafficking and exploitation across their operations.

Justice Secretary Humza Yousaf has also announced he will write to all major Scottish companies who appear not to have met their duty to publish an annual statement outlining steps they have taken to prevent modern slavery in their business and supply chain.

Speaking at an Anti-Slavery Day conference hosted by the Scottish Government and COSLA, Mr Yousaf said:

“Human trafficking and exploitation prey on the most vulnerable in society. Often hidden in plain sight and in legitimate businesses, these offences are on the increase worldwide. Since our Trafficking and Exploitation Strategy was published in 2017 we have made significant progress but businesses need to understand the risks and tackle the conditions that foster these crimes.

“With investors increasingly focusing on human trafficking as a business risk, this is one issue that boards simply cannot afford to ignore. The guidance launched today offers practical advice for businesses of all sizes and I hope it will help more companies to identify and trafficking and exploitation across their operations, including in their supply chains.

“Our biggest firms must lead by example, ensuring they are not complicit in these horrendous crimes, and that is why I am writing to companies to demand urgent action.”

The guidance has been developed with advice from the Corporate Group established to support implementation of the Trafficking and Exploitation Strategy. Its members include HSBC, The Co-op, Multiplex Construction, SSE and the Scottish Trades Union Congress (STUC).

Alison McGregor, CEO of HSBC Scotland, said:

“Every business plays a critical role in supporting the eradication of Human Trafficking and helping those that have been affected by it and HSBC is proud to play its part.  This guidance is an important new tool for all.”


Access the Business Guidance online.

Human trafficking impacts all types of businesses and the guidance recommends that checks should be undertaken to ensure workers have access to identification documents, are not being held in debt bondage and are not being coerced.  Employees should be given training to spot signs of exploitation and encouraged to report concerns to Police Scotland or the UK Modern Slavery Helpline on 08000 121 700

Under the Modern Slavery Act 2015 companies with a turnover of at least £36 million are legally required to publish an annual Slavery and Human Trafficking Statement, clearly linked from the homepage of their website. However, research undertaken by the Scottish Government shows that a significant minority of businesses do not appear to have published statements.

Case study: Brightwork staff look out for red flags

Trafficking and exploitation within labour supply chains is a well-documented area of vulnerability as it embraces flexible working and the use of temporary workers to meet with the peaks and troughs of seasonality demands on business. 

Brightwork Recruitment has introduced a number of training measures for all their front-line staff and upgraded their Customer Relationship Management System to minimise any chance of labour exploitation within their candidate pool. 

An example of using technology is the way they analyse the personal data that they hold on their temporary workers across Scotland. Brightwork clients must have their own bank account in their own name before their system will even allow them to register, and if there is a duplicate mobile or email address registration will be rejected. This is to ensure that no individual is in control of another person with regards to their finances or their working arrangements.

Previously Brightwork used to run these checks at the back office but that meant the worker could have been working for at least one week before the red flags were highlighted.

Working with the police and border agencies Brightwork have updated their processes and can now identify possible victims before they start working.

Their front line staff are fully trained in spotting the signs of modern slavery in the interview process or if they are working at any of their customers’ sites. Examples of warning signs include: workers being dropped off and picked up by the same person; one individual providing lunch for a group of workers; or even signs of physical abuse. All of these scenarios are visible red flags that Brightwork staff look for.

 There have been a number of cases that have gone to trial across the UK that Brightwork have been able to support the local Police and the Gangmasters and Labour Abuse Authority with by collecting the evidence necessary.


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