What Is Modern Slavery Risk Assessment?

Risk assessments are essential when it comes to seeking out and eradicating modern slavery in the workplace, it is also a huge part of an organisation’s corporate social responsibility. By law, businesses with a turnover of £36 million must complete a modern slavery statement — part of which will include a modern slavery risk assessment. However, smaller businesses are still encouraged to voluntarily produce a slavery and human trafficking statement to examine the risks of modern slavery in their work. Before embarking on your modern slavery risk assessment, consider what comes under the detailed breakdown of the Modern Slavery Act and may be relevant to your workplace or industry.

Identifying Risks Associated with Modern Slavery

To fully assess the hazards in your workplace, we recommend you familiarise yourself with the different types of modern slavery in construction. These can impact on your business directly, or through supply chain relationships that you may have with subcontractors or suppliers. Though not an exhaustive list, the most common types of modern slavery in construction are:

• Human trafficking.
• Forced labour.
• Bonded labour.
• Slavery of children.

Knowing how to identify the signs will help you formulate a thorough modern slavery risk assessment. As with any risk assessment, you want to identify the hazards, who is at risk and how.

Spotting workers who are at risk may require you to incorporate new practices into your recruitment or induction process. For example, an instance of a worker at risk could be if they have had their personal belongings or identification taken from them — or if other documents are being withheld. If your processes include checking documents, they will highlight any operatives unwilling to provide that information. An individual may also not have their own bank account, or may be found to have a common address with many other workers.  These can also be indicators that need further checking. Once you have a bigger picture of the potential risks in your business and beyond, you can begin to plan a strategy to reduce and eliminate the risk of modern slavery.

Injuries, fatigue or poor physical health and a lack of adequate and suitable personal protective equipment can be an indication of modern slavery.  If unchecked, they can lead to further risk of harm in the workplace. If you have someone at work who is not fit for work through exhaustion, injury or stress, or inadequate safety clothing they are more likely to incur further injury. This also increases the possibility of hazards that put other workers at risk.

When identifying risks associated with modern slavery, it’s best to start with your immediate workplace and first-tier suppliers — though these may be considered low risk — followed by a commitment to delve deeper into further tiers in your supply chain.

Due Diligence in the Supply Chain

A good place to start when identifying modern slavery risks in your supply chain is to seek out an annual modern slavery statement as written by your suppliers. This document must disclose the steps taken to ensure that slavery and human trafficking are not taking place in their operations and supply chains. Companies are required to publish an annual statement if they meet all of the following criteria:

• They are a “body corporate” or a partnership, wherever incorporated or formed.
• They carry on a business or are part of a business in the UK.
• They supply goods or services.
• They have an annual turnover of £36 million or more.

If your suppliers have published modern slavery statements, they will likely be featured on their websites, but you can request to see copies of them. UK government guidance also recommends that companies keep their previous annual statements available, so you should be able to access information about the progress they are making in their missions to eliminate modern slavery.

Specific Modern Slavery Risk-Assessment Training

Incorporating modern slavery risk assessment into your current training processes can be useful, but given the scale of the risks associated with modern slavery, it’s worth compiling an additional, specific training process. While any training you might offer that covers ethics or human rights is a good starting point, make sure you are constantly developing modern slavery risk-assessment training in line with new legislation and Government guidance.

As part of your modern slavery risk assessment, you should also address a code of conduct for the behaviour you will and won’t tolerate in the workplace. Make sure this is included in your induction training so all staff know what types of behaviour they should report. Many responsible businesses offer a confidential whistleblowing service where people can raise concerns.  There is also a confidential modern slavery helpline where you can raise a concern in confidence – 08000 121 700.

An Active Anti-Slavery Stance and Culture in the Workplace

If your stance and protocols around modern slavery are clear, it’s more likely you’ll attract work with other companies that share those values. Making a clear standpoint also reassures workers that you will root out modern slavery in your workplace or supply chain.

Companies should also include explicit reporting procedures in a modern slavery risk assessment. If this is accompanied by active encouragement to report unethical behaviours or signs of modern slavery, you can continue to promote the benefits of reporting and shared accountability. It’s worth having several methods of reporting and named supervisors or managers as bodies to report to — this way, everyone is aware of exactly how they can report signs of modern slavery. It’s crucial that workers feel assured there will be no negative consequences so that they are comfortable reporting without fear of reprisal.

CHAS clients can sign up free of charge and monitor the compliance of supply chain partners with modern slavery legislation. Clients can also check the IDs, credentials and rights to work of their people.  

Alternatively, you can become a CHAS contractor and gain access to industry-leading accreditation schemes and risk management resources, including training modules, risk assessment templates, Business Shield support and more.