Your workers - who are they?

In March 2025, the UK government updated its advice on "Section 54 of the Modern Slavery Act - Transparency in supply chains".

On the very first page, they state:

"Modern slavery is so prevalent that if businesses are not identifying risks and cases, they are probably not looking hard enough."

It is quite a statement.

So what's behind the government's comment - and why might modern slavery be more prevalent that we might all imagine?

Let's take a bank as an example

Last week, we were talking to one of the UK largest banking groups. They directly employ over 50,000 people in approaching 1,000 locations around the world.

Taking them (a major banking group) as an example, they are currently asking themselves some simple questions - hence the discussions with us:

• Who are the workers we have to worry about?

• What are the risks that might affect them?

• Are these risks relevant to our business.

• What might we do about them?

  
  

Employees

The bank has a lot of employees.

• Banks tend to employ higher-skilled workers, on decent wages, with good language skills, who understand their employment rights and can access legal support.

• They have clearly communicated internal standards across the business for recruitment and how individuals should behave.

• They have mandatory internal systems in place to train staff and enable 360 degree feedback up and down the hierarchies.

The chances are low that direct employees of the bank are experiencing systemic worker human rights abuses. Although rare, individual cases can arise but employees are likely equipped with the tools and capabilities to protect their worker human rights.

Are there potentially vulnerable workers present?

With approaching 1,000 locations around the world - the majority in the UK - there are a lot of people involved in keeping the bank up and running, contributing to its profits.

Many of these workers are not direct employees

They are:

• Cleaners, security guards, maintenance staff, contractors, outsourced staff who work on bank premises; and

• People who work for suppliers of goods and services that the bank consumes.

Some banks, particularly multi-lateral banks, may also widen the scope of the above list to include workers in the businesses of their customers. This is to ensure that their funds are only being used in businesses where worker human rights are respected.

We estimate that, maybe, 70% of the economic value generated by a business could come from workers who are not employees (see more here). This percentage will vary by the type of business (and a bank would likely be a much lower percentage, albeit still material).

These are "your workers" - but who are they?

In all these cases, the bank will likely not know the names of the workers, where they are from, or the terms on which they are working.

What's the statutory responsibility?

There can be statutory obligations in relation to these workers (meaning under laws that have been passed by the government).

In the UK, under section 54 of the Modern Slavery Act 2015, the bank has a responsibility to set out the due diligence it undertakes in relation to these workers to ensure their worker human rights are respected.

Many countries have laws in this area with many going further to require that effective due diligence in respect to this wider group of workers is actually undertaken.

Is there a duty of care?

This is a bigger question. In many jurisdictions, business can find its responsibilities (and liabilities and risks) can go beyond those set out formally in specific laws that have been passed. This could be the case in the UK, for example.

The tests to see whether there is a duty of care, broadly-speaking, are:

1. Are worker human rights being breached (as a fact)?

2. Is the business benefitting?

3. Does the benefit to the business flow directly from the breach?

4. Is this a foreseeable outcome?

For example, if the worker human rights of a group of workers are not respected by their direct employers (for example, by not paying them properly), the enterprise (in our example, the bank) could be directly profiting through lower costs of products and services for itself.

If there is a duty of care, it means that business has much wider responsibilities to workers, whether or not employed, to try and prevent any breaches from occurring - for example, by carrying out effective due diligence and through education, training and communication across the enterprise.

What are the risks?

Whether or not there is a legal responsibility, we can also see that there are potential reputational risks.

The lower-skillled roles that are often out-sourced or contracted-out are exactly those where vulnerable and even un-documented workers can be employed and then exploited.

On top, in situations where worker human rights are compromised, workers often get substituted and moved around frequently. The sub-contractor or employment agency providing the workers itself might not even know who the workers are.

Four steps to look at:

1.       Transparency / visibility

In order to understand risk there is a need to map and identify potential opportunities for exploitation of workers within the business model.

This need not be a long and complicated exercise. It involves considering who all the workers are that contribute to the success of the business and what’s known about them and their potential circumstances.

This may then reveal both situations where risks can be present and gaps in knowledge that might need to be addressed.

2.       Training

There are good and free resources available that can be used with your workforces to inform them of the signs of modern slavery or worker exploitation and what they should do if they spot something that is not right.

Here is a short video that can be shared, created by the UK charity Stronger Together: click here.

3.       Help lines

Workers can be helped by providing them with contacts that they can talk to, confidentially and anonymously, if they need help.

The charity “Unseen UK” operates the Modern Slavery & Exploitation help line. For information about the support they provide: click here.

The Modern Slavery & Exploitation helpline gets 1000s of calls a year from workers in the UK that are being exploited – repeating again the message at the start of this article:

"Modern slavery is so prevalent that if businesses are not identifying risks and cases, they are probably not looking hard enough."

4.       Technology

You can use technology to ask workers directly how they are being treated day to day – whilst also ensuring their answers remain anonymous and confidential.

The technology can be easily deployed in your locations and used by workers – whether they work for you or not.

There is no magic bullet that removes all the risk, but you can get much closer to understanding what's going on if you implement an effective system that enables workers (whom you may not know) to tell you what is going on.

Ask the workers

Our Ask the workers platform is simple to implement, is low cost to run, and is free for users, workers and employers. It offers:

• A scalable way to cover all the workers, all the time, across all the locations and all the suppliers; it is even extendable out to customers should this be a concern.

  
  

• Engagement with the workers directly (note that self-certification by suppliers, agencies and sub-contractors is not effective).

  
  

• And in respect to the workers, an app that is:

  
  

  • Available 24x7, 365 days a year, running continuously, available to all the workers ("all-the-workers", "all-the-time")

    
    

  • Easy and intuitive for them to use which focusses on their worker human rights and maps their responses automatically to your risks

    
    

  • Authentically links workers to their employers and the locations where they work, but without compromising their privacy (no names, phone numbers or emails)

    
    

  • Ensures that worker responses are anonymous and cannot be traced back to them

For a small team seeking to monitor worker human rights across a large number of locations and suppliers, this is the platform that you need - especially if you there are workers in your locations that you don't know.

See here for more information about "Ask the workers": click here.