CPD articles

CPD: How to spot modern slavery on your site

2 March 2017

High-profile cases of worker exploitation in the Middle East have put the issue of modern slavery in the spotlight, but the fact is it is a much wider problem for the industry, writes Emma Crates.

Prime minister Theresa May has called modern slavery “the great human rights issue of our time”. International legislation is ensuring that it will continue to rise up the business agenda, but how can we recognise worker exploitation on site, and what measures can we take to prevent it?

The Global Slavery Index estimates that 45.8 million people are in some form of slavery in 167 countries. In fact, more people are trapped in modern slavery today than at any other time in history.

Slavery is big business. It has its own shadow economy, generating an estimated US$150bn in illegal profits globally.
It has strong links to corruption, people trafficking and organised crime. Protected by vested interests, it is a complex problem that is not easy to tackle.

In recent years, the media has focused on worker exploitation in a variety of sectors, from agriculture (the cockle pickers in Morecambe Bay, 2004) to electronics goods (employees of Foxconn in China working on Apple products, 2012) and fast fashion (the collapse of the Rana Plaza in Dhaka, Bangladesh, 2013).

Construction has not escaped international scandal. High-profile cases include the World Cup stadium projects in Qatar, and worker exploitation on the New York University Campus in Abu Dhabi (2015), where 10,000 workers were excluded from labour safeguarding measures without the knowledge of the client.

The focus on Gulf countries by non-government organisations (NGOs) and campaigning newspapers may give the impression that the problem is only with this region. This is far from the case. Modern slavery can happen on any building site around the world. It can infiltrate, and remain hidden, within any supply chain.

Given construction’s fragmented procurement processes and heavy reliance on outsourced labour, the challenges in tackling this issue may seem overwhelming. But legislation is forcing action. The UK Modern Slavery Act requires all companies or subsidiaries based in the UK, with a turnover of above £36m, to report annually on the steps they are taking to address worker exploitation both within their organisation and their supply chains.

The California Transparency in Supply Chains Act has similar requirements and the European Non-Financial Reporting Directive is also forcing organisations to report on bribery, corruption issues and human rights.

Rooting slavery out of construction will take generations and require strong leadership at CEO and board level. New policies will need to be embedded across many disciplines and departments, including procurement, design, HR, sustainability and contracts.

While that will take time, there are actions managers can take that could make an immediate impact. Fighting modern slavery is about changing attitudes and raising awareness through education and training. Every employee has a role to play in spotting signs and reporting problems.

Modern slavery should be seen in the same context as the industry’s evolving approach to health and safety. Slow and sustainable steps, backed up by industry-wide initiatives, will change the image and working conditions of the sector over the long term.

What is modern slavery?

Simply put, modern slavery occurs when somebody effectively behaves as if they “own” the victim, depriving them of their freedom. This could be through forced labour – where the victim works against their will, often for long hours and little or no pay.

These workers will usually suffer verbal and physical abuse and threats of violence to control them. They may be in bonded labour, tricked and trapped into unrealistically high levels of debt by their handlers. They could be forced to work for free or on minimal wages to service the debt.

Alternatively, they could have become victims of human trafficking and have no legitimate status in their country of work. In developing countries child labour can also be a major problem.

Who is most at risk?

Labourers and those at the lowest parts of the supply chain are most at risk. These are typically migrant workers who move from low income to higher income countries to find better paid work.

Construction’s heavy reliance on outsourced labour makes it particularly vulnerable to human rights risks. In extreme cases, such as Qatar, migrant labour accounts for 90% of the construction workforce.

What are the common forms of abuse and control?

Illegal “recruitment fees” are often at the root of worker exploitation: to get employment, workers are duped into paying fees to agents and middle men. These fees put them into debt that cannot be paid off for years, or even during their lifetime. Sometimes the debts are held by loan sharks at extortionate rates, and could be passed on to the victim’s children. As a result, the workers are fearful of violent reprisals, both to themselves and their families.


  • The Anti Slavery Hotline, 0800 0121 700 www.modernslaveryhelpline.org
  • Unseen is an NGO that provides support and protection for victims of slavery and human trafficking in the UK.
  • The CIOB has produced two reports on modern slavery: The Dark Side of Construction (2015) and Building a Fairer System: Tackling Modern Slavery in Construction Supply Chains. Both can be downloaded from the CIOB policy website https://policy.ciob.org

Although recruitment fees are illegal in most countries, many cultures consider the practice to be normal. This enables unscrupulous parties to operate a “double dipping” system, taking fees from labourers, as well as billing employers for legitimate recruitment costs. Negligent clients may also operate under the mistaken belief that the agencies are footing all the costs of recruitment.

Because workers are forced to pay the recruitment fees before they leave their homeland, they are vulnerable before starting the job or arriving in their country of work. This leaves them open to a variety of abuses including:

Detecting human rights abuses

It’s important to understand that the abuse could be traced to inside or outside of your organisation and it could take a variety of forms. Perpetrators could be corrupt agents or recruitment consultants taking illegal placement fees. They could be an organised gang that is holding trafficked victims in forced labour.

Alternatively, they could be rogue employees, such as supervisors, who select workers for shifts on the basis that they use their sublet accommodation.

Victims are not always easy to spot. They will be typically fearful of admitting their situation because of the tight controls that they find themselves under.

Commonly, victims will not understand their rights and would be distrustful of the authorities. They may be under surveillance and fear violent retributions. They may also fear deportation, which could make their situation even worse. They may be psychologically damaged and feel too ashamed to admit that they have been duped.

Bear in mind that the victims may have entered employment with your company through legitimate channels, albeit under duress.

Spotting the signs

Although every situation should be treated on a case-by-case basis, there are some signs to look out for in the workforce.

Exploited workers may show signs of physical injuries or psychological abuse. They may be dirty or malnourished. Their behaviour may be frightened, withdrawn and confused. They may avoid eye contact.

They may also have very few possessions and not be carrying money or personal items such as purses, wallets or jewellery. They may have few clothes or wear inappropriate clothes to work. They may look hungry, and have little or no food with them.

Tellingly, exploited workers are rarely left to be on their own and are often under the control and influence of others. Be on the lookout for situations where one person speaks on behalf of a number of workers. Victims could be looking to him or her for support or permission.

In addition, a third party could be holding the labourers’ identity documents, and could answer phone calls on their behalf. Watch how workers leave and enter the site. Are they being accompanied to work and back? For example, a driver may drop them off and collect them.

What to do on site?

If you suspect that you have a problem on site, be careful that your actions do not to alert the perpetrators. They could quickly move labourers elsewhere, covering up or removing any incriminating evidence.

Labour exploitation and human trafficking are serious crimes and it is not advisable for untrained individuals or organisations to manage the investigation internally. Your discovery may also form part of a complex investigation by the police.

In the UK, your first action should be to inform the police or the Anti Slavery Hotline and receive advice on how to proceed.

Protecting and supporting at-risk individuals

If you suspect you have a problem within your organisation or on site, your primary responsibility is to ensure the safety and welfare of potential victims. They may be in a highly traumatised state and could be at risk from those around them. It will be necessary to protect them discreetly until the police, NGOs or agencies arrive.

Remain with the potential victim in a safe place, out of view of other workers and have a colleague present if possible.
It is vital that the victim’s identity is protected as other workers could be colluding in their control. Call in an interpreter if necessary — don’t rely on another worker who speaks the same language.

Where there is more than one potential victim it is advisable to put them in separate rooms as it may not be possible to know who is being exploited and who is an exploiter. Where the exploitation of one job applicant or worker is discovered, consider other applicants or workers who may also be at risk.

Recording evidence

Keep a record of the circumstances leading up to any conversation with someone considered to be a potential victim. Record any initial first complaints from victims and collect and preserve CCTV evidence if available. 

Photograph any evidence of physical injuries on a mobile phone or camera, and record vehicle registration numbers of any vehicles used by potential offenders, if safe to do so.

However, remember that your key role is to protect the victim, not to conduct an investigation.

Short- and medium-term preventative measures

Many migrant workers may lie about paying recruitment fees because they are desperate not to lose their jobs. So build up trust with them, and do not necessarily believe the first answer they give on arrival. It is good practice to ask them about recruitment fees after they have been in work for a month and to repeat the question after six months when they may be feeling more secure.

In addition, in some countries it may also be necessary to check that:

Qatar Rail turns Fresh Eyes on exploitation

As in many countries around the world, the Qatari government officially prohibits the payment of recruitment fees. In practice, however, the situation is difficult to control or monitor, as corruption has usually taken place outside of its jurisdiction, before the labourers have arrived in the country.

Last year, Qatar Rail, the client overseeing the construction of three major rail networks in the country, launched a new initiative with project management consultant Jacobs International.

Under its Fresh Eyes campaign, all levels of the team, from senior management to office staff, are encouraged to regularly go out on site. As well as checking for potential health and safety issues, they talk informally to individual workers. These regular interactions are aimed at building mutual trust over the longer term. In cases where Qatar Rail becomes aware of recruitment fees or any other form of exploitation, the client will take immediate action against the perpetrators.

“I would urge all expatriate professionals visiting or working in the region to go to the sites and witness the situation themselves. It’s important for us all to become more proactive in looking for problems,” said a spokesperson.

CIOB and the Stronger Together Toolkit

For organisations to tackle slavery sustainably, it is necessary to start conversations with both employees and key supply chain members.

To this end, CIOB has teamed up with multi stakeholder initiative Stronger Together to launch a combined toolkit, collaboration and training platform for combating slavery in the construction sector.

Stronger Together already has a successful track record in retail. Major brands including Aldi, Asda, Co-operative Food, Lidl, Marks & Spencer, Morrisons, Sainsbury’s, Tesco and Waitrose, are using the toolkit to reduce the risk of modern slavery within their operations and supply chains.

The toolkit will be available in February and can be accessed through the CIOB policy website https://policy.ciob.org


A good start to tackling an enormous problem

Sheila, 3 March 2017

this is good for the construction industry.now i know what to look out for, in case of any modern slavery attempt

John Wealth Oluwarotimi, 25 February 2019

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