Doorstep Scams, Rogue Traders, Travelling Sales and Modern Slavery

Human Trafficking and Doorstep Scams

Door to door scams and rogue traders have been points of focus recently for their links with modern slavery and human trafficking. However, the links between door to door scams and modern slavery and human trafficking are not new issues. In July 2015 the Polaris Project published a report entitled ‘knocking at your door: Labor Trafficking on Sales Crews‘, exploring the major issues of modern slavery, human trafficking and forced labour in the travelling sales industry. The Polaris Project’s report focused specifically on the US context, but awareness of door to door scams and rogue trader’s links with modern slavery and human trafficking has risen in the United Kingdom too.

 

What are Door to Door Scams and Rogue Traders?

The Neighbour Hood Watch provide a general overview of doorstep scams, including who is likely to be targeted by doorstep scammers and what sort of scams might be involved. They identify typical doorstep scams involving ‘home improvements’, where an individual will knock on the door of their victim, without warning, and explain that their home is in need of improvement works, such as gardening, re-wiring, re-roofing etc, and that this work is extremely urgent. However, more recent incarnations of these traditional scams include installing solar panels, exploitation of internet connections, and the creation of false technical service provider adverts on search engines. Aside from these typical doorstep scams, the Neighbourhood Watch also links apparent doorstep sales pitches with distraction burglary and identity theft.

 

Links to Modern Slavery

Door to door scams of the kind noted above are being increasingly identified as being undertaken by victims of modern slavery. Criminal gangs will target vulnerable individuals who are held by the gang and forced to work for little or no pay, with one reported instance stating that a victim had been forced to work long hours 7 days a week for food and tobacco.  These patterns broadly mirror the findings of the Polaris Project’s 2015 report, which found vulnerable young people in need of employment would be offered the chance to work for a travelling sales company. Once in the ’employ’ of the company the victim would be moved around the country, often under threat of violence and/or abandonment, and forced to work for no wages.

Debt bondage can be a common feature of modern slavery and human trafficking involving doorstep sales, scams and rogue traders. Vulnerable victims are initially offered shelter, food, support, and transport, which gets tallied against them as a debt. Continued reliance on the traffickers for these provisions adds to the debt, as well as failures to meet randomly assigned sales quotas.

The noted increase in victims of modern slavery being used to carry out door to door sales and scams has led to authorities calling for greater vigilance from consumers, both to be careful of new incarnations of old scams, but also of who is the individual apparently carrying them out.

Public Sector Supply Chains and Government Compliance

Public Sector Supply Chains and Government Compliance
image from Shutterstock

The Independent Review of the Modern Slavery Act published the final report at the end of May 2019. The final report proposed a consultation to run that focused on issues surrounding transparency in supply chains and modern slavery reporting. On the 9th July 2019 this consultation was launched, forming part of a governmental commitment to improving section 54 of the Modern Slavery Act 2015, which addresses modern slavery reporting requirements and transparency in supply chains. The consultation took responses from NGOs, charities, businesses, public sector bodies, and various other organisations and interested parties, addressing three key areas:

 

  1. The content of modern slavery statements: This section addressed inconsistencies in reporting approaches taken by different companies and the possibility of making certain criteria mandatory. This section also sought to address the fact that global movements in modern slavery legislation may make it desirable to ‘harmonise our approach’. The questions posed focused on reporting practices and the implications of making certain areas mandatory.

 

  1. Transparency, Compliance, and enforcement: The second section of the consultation sought to propose the introduction of a central government registry, one designed to improve transparency. It also addressed reporting deadlines, proposing a single annual reporting deadline so as to reduce the confusion of multiple separate deadlines throughout the year. It finally sought to gain views into how section 54 of the Modern Slavery Act might be enforced. Questions were posed on each of these areas.

 

  1. Public sector supply chains: The final area addressed in the consultation examined public sector supply chains. In essence, the consultation proposed that reporting requirements would be extended to public sector organisations with a turnover of more than £36 million per year.  Reporting requirements would be for each individual government body to maintain responsibility, whether given individually or as part of a group statement. The questions posed by this section of the consultation focused on the apparent benefits and challenges of imposing modern slavery reporting requirements on large public sector bodies.

 

The consultation period ended on the 17th September 2019 and the following day the UK Government announced a series of measures that would be introduced to ensure that governmental supply chains were free from Modern Slavery. The UK government spends approximately £52 billion in the procurement of goods and services, with wider public sector annual spending nearing £203 billion. The statement further announced a new partnership with the Chartered Institute of Procurement and Supply to provide training and awareness to government workers and departments. The announcements addressed several of the issues raised in the consultation surrounding public sector supply chains, with proposals that from 2021 individual ministerial departments will produce their own modern slavery statements. However, the final response to the period of consultation has yet to be released.

Organised Crime, Modern Slavery and Waste Management

The waste management industry has been receiving increasing attention as a sector at high risk of modern slavery, with figures from the anti-slavery charity Hope for Justice suggesting about two thirds of forced labour victims have worked in the waste management sector.  The waste management sector is a multi-tiered industry with many complex supply chain networks. This complex network of supply chains makes it easy for individuals to be filtered into the system for the purposes of labour exploitation.  Such an accessible system has made the waste management industry very attractive to organised crime groups, with many groups operating in the sector also involved with other major criminal enterprises such as human trafficking, county lines drugs operations and arms offences.

Organised crime is often associated with grand ‘mafia-esque’ organisational structures, but these traditional organised crime groups are giving way to more dynamic fragmented groups that operate more fluidly. In May 2019 the National Crime Agency (NCA) released organised crime figures that suggested that the number of offenders involved in organised crime in the United Kingdom was approximately 181,000 , though this is considered a conservative estimate. As part of the same press release the NCA released its national strategic assessment for 2019 which discussed the changing face of organised crime and outlines the rise in modern slavery and human trafficking referrals. Public awareness of organised crime has risen recently with several high profile reports of prosecutions and police operations to tackle gangs and organised crime groups operating across county lines. However, whilst public awareness of organised crime and modern slavery is rising it does not seem that there is any widespread awareness of how these issues impact the waste management sector.

In 2018 the government published a review of serious organised waste crime, which outlined how organised crime groups would often “colonise” pre-existing legitimate waste markets. These criminal operations would often then function through other criminal enterprises, including modern slavery and human trafficking. In response to the issues of organised crime and modern slavery in the waste sector the Environment Agency committed to taking new measures to tackle these issues. Some of these responses have included increasing inter-agency collaboration to ensure that investigations and operations carry a bigger impact against organised crime, and specially training officers to spot the signs of modern slavery. Whilst public awareness of waste crime and modern slavery in the waste sector such measures by law enforcement and government bodies signal a firm awareness of serious and major criminal activity in the waste management sector, and a commitment to addressing these issues.

The Rise of Technological Responses to Human Trafficking and Modern Slavery

Technology and Human Trafficking

Technology, and in particular mobile applications, is being increasingly identified as an important method of tackling modern slavery and human trafficking. Mobile applications have recently been responsible for the identification of nearly 1000 cases of modern slavery in car washes around the country. With the release of the Modern Slavery Helpline annual report for 2018, which recorded approximately 1 in 7 reports were made by webform submissions or through the Unseen App, it is clear that there is a rising awareness of modern slavery and human trafficking in the UK and a significant proportion of reports are made through technological methods.

However, mobile applications are not the only technologies being identified and implemented to help tackle modern slavery and human trafficking. So far in 2019 there have been several reports of new implementations of technology to combat modern slavery and human trafficking. For example, satellite imaging being recently used in a study by Nottingham University to accurately map the number of brick kilns in India. Brick kilns in India, which are associated with the exploitation of labourers through forced labour and debt bondage, exhibit unique features that can be mapped by satellite imaging and it is hoped that other industries associated with modern slavery may be vulnerable to satellite imaging too; scaling this use of technology into a major method of tackling modern slavery in remote areas. By contrast, algorithms that measure activity against a set of variables have been piloted by banks in the Netherlands to identify unusual behaviour that may be indicative of human trafficking or modern slavery.

However, whilst the use of technology to combat human trafficking and modern slavery is advancing in new directions and receiving high profile acclaim concerns have been raised that technology merely constitutes a tool and its use alone may not be enough. TechUK, an organisation responsible for representing approximately 900 companies that develop technology, has raised concerns that for technological tools to be truly effective corporations need to ensure they have a strong anti-slavery culture with a willingness to act. Whilst strong corporate and social anti-slavery cultures are vital, the development of technological tools and processes to target human trafficking and modern slavery demonstrate positive commitments by a wide range of actors to tackling these issues. Many of these technological developments are recognised as new and as these tools are refined it is quite possible that technology will take play a greater role in combating human trafficking and modern slavery.

Modern Slavery Act 2018- What does it do?

Australia_Parliament_House_Lauri_Vain
Photo Credit: Business & Human Rights Resource Centre; Lauri Väin

New Modern Slavery Act 2018 in Australia introduces strict reporting requirements for businesses among other key objectives.

There has been significant interest recently over the introduction of the Modern Slavery Act 2018 (MSA) in Australia, and its likely coming into force in early 2019. The act will carry with it significant thresholds for businesses to meet in terms of reporting requirements. But what is the new act?

Section 3 (Part 1) of the MSA 2018 details the main objectives of the act are to:

  • Combat modern slavery,
  • Provide assistance and support for victims,
  • Establish an Anti-Slavery Commissioner,
  • Provide for detection and exposure of modern slavery,
  • Raise community awareness and provide education on modern slavery,
  • Encourage collaborative cross-sector and multi-agency responses,
  • Introduce provisions for the ongoing assessment of anti-slavery laws,
  • Criminalise forced marriage,
  • and, penalise further involvement in cybersex trafficking and CSE.

 

Statistically reports of  modern slavery in Australia are low in comparison to other countries, but there are concerns this is because of a lack of awareness on the matter. As part of this, there are concerns that businesses are not fully aware of the risks of modern slavery in their supply chains. Part of the act focuses on supply chain transparency, and appears to be heavily oriented towards tackling these issues. The focus on business accountability and corporate supply chains suggests a main focus on forced labour, which is not unsurprising given forced labour accounted for approximately half of all modern slavery cases in the ILO’s 2016 statistics. However, the objective statements of the act regarding forced marriage and child exploitation demonstrate the wide reaching and comprehensive aims of the act to eradicate modern slavery in all forms.

A link to the act itself can be found here.

Global Supply Chains: 4 Principals Adopted Against Modern Slavery

The UK, Australia, Canada, New Zealand and the USA have made progress in the movement to expel modern slavery and labour exploitation from global supply chains.

These five partner countries have created a set of 4 principles designed for nations all over the world to adopt, in order to promote ethical supply chain compliance within their jurisdictions. The principles are aimed at policy level, addressing both public and private sector procurement, supply chains, recruitment and encourages the need for cooperation between such actors.

The four principles are as follows:

Governments should take steps to prevent and address human trafficking in government procurement practices

  • analyse, develop and implement measures to identify, prevent and reduce the risk of human trafficking in government procurement supply chains
  • provide tools and incentives and adopt risk assessment policies and procedures that require their procurement officers and contractors to assess the nature and extent of potential exposure to human trafficking in their supply chains
  • take targeted action, including adopting appropriate due diligence processes, to identify, prevent, mitigate, remedy, and account on how they address human trafficking

Governments should encourage the private sector to prevent and address human trafficking in its supply chains

  • work in partnership with business, workers and survivors to set clear expectations for private sector entities on their responsibility to conduct appropriate due diligence in their supply chains to identify, prevent and mitigate human trafficking
  • provide tools and incentives to the private sector to encourage meaningful action and public reporting of their efforts, including through programmes policies or legislation

Governments should advance responsible recruitment policies and practices

  • advance responsible recruitment practices, including by implementing polices that incentivise and support responsible practice, and by support initiatives such as the ‘Employer Pays Principle’
  • contribute to the growing knowledge base of promising practices for protecting workers from fraud and exploitation in the recruitment process

Governments should strive for harmonisation

  • make reasonable efforts to share information and work with other committed governments to align existing and proposed laws, regulations and polices to combat human trafficking in global supply chains

 

The UK,  leading global efforts in anti-slavery policy, is encouraging governments at the UN General Assembly to adopt these principles. By leveraging the combined $600 billion purchasing power of the partnered nations there is the capital to influence high-level actors in both public and private sectors.

The principles provide a clear and progressive framework for cooperating governments to aim towards. The major drawback, however, is the lack of enforcement of these principles, which in many instances is controlled by  legislation. However, for these principles to be effective in practice rather than theory, strict and coherent sanctions are critical. The further challenge is to address cross border transactions, and encourage non-cooperative countries that produce the majority of global slavery statistics to adopt and enforce such principles.

Combatting the Vulnerability of Refugees Against Labour Exploitation

Image Credit: Deutsche Welle - Syrian Refugee Working at BMW
Image Credit: Deutsche Welle – Syrian Refugee Working at BMW

In many cases, migrants and refugees make vulnerable targets for exploitation within their host countries as they are often in positions of desperation and vulnerability. In many cases their skill sets or education are not suited to those needed in their place of settlement, forcing them into poor and inappropriate work conditions, hard labour or making them vulnerable to recruitment by traffickers to exploitation.

The UNHCR, OECD and other international agencies are working on an ‘Action Plan’ to overcome the issue of refugee employment. This plan aims to integrate refugees into the labour market by overcoming the issues and creating a strategy to identify the skills that can actively contribute to the economy of the host nation.

Through research and interviews, having secure and safe employment is the top contributor to integration in a new society, which protects them from the potential for labour exploitation. Although each host destination has subjective conditions and labour requirements, the action plan is a holistic and broad framework composed of 10 steps:

  • Action 1 – Navigate the administrative framework
  • Action 2 – Provide employers with sufficient legal certainty
  • Action 3 – Identify and verify refugees’ skills
  • Action 4 – Developing skills for job-readiness
  • Action 5 – Match refugee talent with employers’ needs
  • Action 6 – Provide equal opportunities in recruitment and combat stereotypes
  • Action 7 – Prepare the working environment
  • Action 8 – Enable long-term employability
  • Action 9 – Make the business case for hiring refugees
  • Action 10 – Coordinate actions between all stakeholders

Whether in refuge from conflict, environmental or economic hardship, 65 million people globally have been forcibly displaced from their homes, of which refugees make up 25.5 million. Due to the nature of globalisation, these rates are increasing, along with the frequency and types of labour exploitation of refugees and vulnerable populations.

For the full Action Plan, read here.  

Men Are Vulnerable To Trafficking As Labour Exploitation Rates Prove Higher Than Sexual Exploitation

7th Annual Report: G R E T A Group of Experts on Action against Trafficking in Human Beings

The Council of Europe has released a report through the Group of Experts on Action against Trafficking in Human Beings (GRETA) which suggests labour exploitation is now the most significant form of trafficking in Europe, reflecting the rising trend in recent years. Alarmingly, it has taken over rates of sexual exploitation in several countries, including the United Kingdom, Belgium, Portugal, Cyprus, Georgia and Serbia.

Due to this shift, men are the most identified victims of human trafficking, however women and children are still severely affected. ‘Men are often exploited in industries including agriculture, construction and fisheries whereas women tend to be exploited in more isolated settings such as domestic or care work – where they are sometimes victims of both labour and sexual exploitation.’

The primary cause of these new ​figures points to the previous underestimation of labour exploitation against sexual exploitation rates, as there is relatively less targeted legislation, and there have been few successful prosecutions and convictions. With both forms of exploitation, victims fear reprisals ​from traffickers, ​which makes data collection difficult, as well as impacting on low conviction rates.

For the full 7th Annual Report: G R E T A Group of Experts on Action against Trafficking in Human Beings, read here.