Producers have been advised to go “above and beyond” simply checking the licensing credentials of third-party agencies, and engage with the workers to find out more about their payment terms, living conditions, and circumstances behind arriving in the country.
The growing problem has been acknowledged by Prime Minister Theresa May, who in July put £33.5M behind a new taskforce to combat slavery.
It follows on from the establishment of the Modern Slavery Act in 2015.
Jayne Hussey, partner at legal firm Mills & Reeve, said manufacturers’ responsibility shouldn’t stop at checking whether third-party agencies were licensed by the Gangmasters Licensing Authority (GLA).
‘Where the labour is coming from’
“A producer should be aware of where the labour is coming from, and the conditions and terms of that labour.
“For example, if the workers are staying in temporary housing, who has provided that temporary housing? Where is the temporary housing, and what condition is it in?”
According to Hussey, it was about having a “nose” for things that didn’t seem quite right.
“There are some really good toolkits around, but you need to make sure it’s more than just a tick-box exercise,” she said.
‘Where is the evidence’
“You can convince yourself that correct procedures are being followed, but where is the evidence behind it?”
Shanta Martin, human rights specialist at law firm Leigh Day, said food manufacturers should not only comply with existing obligations but also consider the direction in which the law and consumer expectations were moving.
“There is a trend towards greater accountability and food manufacturers that take proactive steps to eliminate the driving forces of modern slavery (short-term labour demands, impossibly short turnaround times, low wages) will find themselves ahead of the game,” she said.
The Modern Slavery Act requires businesses with a turnover above £36M to publish an annual statement confirming steps had been taken to prevent slavery and human trafficking.
Meanwhile, in July a toolkit was launched to help firms guard against the risk of modern slavery in their global supply chains