A recent investigation that uncovered instances of modern slavery involving workers at McDonald’s outlets and at a supplier to major supermarkets has flagged the urgent need for employers to remain vigilant against such practices.

Sixteen vulnerable people were exploited by a criminal gang, as revealed by a BBC undercover investigation.  They were forced to work in coercive conditions for years, either at the fast-food restaurant or a factory that supplied major supermarkets, including Asda, Co-op, M&S, Sainsbury’s, Tesco, and Waitrose.

Explained company law specialist,  Jon Dunkley, Partner here at Wollens: “The victims endured gruelling hours, often working between 70 and 100 hours a week, with wages deposited into bank accounts that didn’t match their names and all were listed as having the same registered address. In a particularly troubling tactic, gang members even posed as ‘translators’ during job interviews, speaking on behalf of the victims and filling out their applications for them, which ensured the gang had control over the entire process.

“Despite all these warning signs, the businesses did not recognise what was happening.  But modern slavery, which includes forced labour, trafficking, and other forms of mistreatment, is a serious offence that carries severe consequences.” 

Under the Modern Slavery Act 2015, employers must implement rigorous measures to prevent such exploitation if their global turnover is more than £36million, including subsidiaries. This includes publishing an annual statement detailing their anti-slavery efforts. 

Many smaller companies assume they are not affected by the Act, but in a complex supply chain they are likely to find questions being asked by the larger companies at the top of the chain, with pressure to undertake detailed auditing themselves.  

It means all businesses must be vigilant for red flags and should ensure they have confidential reporting channels in place for workers to raise concerns about potential exploitation.

Employers should watch for signs such as employees showing signs of fear, working long hours with minimal breaks, or lacking control over their finances and identification documents. These are potential indicators of forced labour and should flag the need for further investigation.

Failure to tackle modern slavery can lead to significant reputational damage and legal repercussions. Employers must be proactive in training their staff, conducting risk assessments, and fostering a workplace culture where unethical practices are swiftly reported and addressed.

He added:  “The McDonald’s case underscores the importance of regular audits and transparency within businesses. Having robust reporting and monitoring systems to detect and prevent modern slavery is essential and also ensuring that all recruiting staff and managers are trained and regularly reminded of the warning signs. This will not only make sure businesses comply with the law, but also help to safeguard vulnerable people from exploitation.”

Warning signs that someone may be vulnerable:

  • not holding their own identification documents  
  • always opting to work very long hours
  • not engaging with others at work 
  • reluctant to discuss personal life 
  • physical signs such as lack of clothing or seeming hungry 
  • escorted to and from work 
  • a third party who tries to intervene to speak on their behalf  

Speak to Jon Dunkley

Jon is a Partner at Wollens and can advise you. Contact Jon via email jon.dunkley@wollens.co.uk or call 01271 341021.

You can also complete an online enquiry form. One of the Wollens team will contact you as soon as they are available.