‘Tis the season to be … vigilant!

Christmas preparations are in full swing. Roads and rail networks are congested with increased traffic delivering goods to warehouses, shops, and homes. Businesses thrive, and consumers eagerly seek bargains for the perfect Christmas, striving for the festive scenes and goodwill portrayed in the ads that have been on repeat since Halloween. 

Yet, behind this merry façade and increased demand lies an unsettling reality: the exploitation of temporary and seasonal workers. As the demand for labour surges during this period, many individuals find themselves caught in a cycle of precarious work conditions, long hours, and minimal salaries, often enduring exploitative practices in the name of holiday cheer. 

Major supermarket chains and leading retailers have actively launched their recruitment drives, with two major supermarkets together offering more than 50,000 roles for seasonal staff and a major online retailer taking on 20,000 temporary personnel. Within the food industries, the demand for labour is intensified by the need to provide seasonal food including processing 10 million turkeys and harvesting seasonal vegetables, including 750 million Brussels sprouts. To meet this demand, there has been a huge uplift in visas in 2023 for seasonal agricultural workers, with 45,000 available for 2023 compared to 30,000 in 2022.

Given the substantial number and increased demand for vacancies spanning various industries, numerous businesses are turning to recruitment agencies to secure the necessary labour. This approach enables stretched businesses to ramp up to peak operations during this high-demand period. 

In the realm of recruitment, it is unsurprising as businesses become stretched that lax recruitment processes can creep in, and it becomes a challenge to ascertain whether agencies are fulfilling their compliance obligations. Legitimate businesses become vulnerable to exploited workers and victims being placed within their operations. The apparent convenience of agency usage for businesses may obscure risks and diminish transparency, providing a veil for exploitative practices to go unnoticed.  

In the face of these pressures, what measures can businesses take to mitigate risks?

Vigilance and proactive steps are essential. When planning for seasonal recruitment, careful consideration must be given to implementing thorough due diligence procedures throughout the peak period. 

Consultants at Slave-Free Alliance have offered practical guidance for businesses to mitigate risks as they approach this peak season:

Strengthened Due Diligence 

  • Conduct updated right-to-work and ID checks for employees before their employment begins, avoiding assumptions that these checks have been performed elsewhere. Ask the temporary worker to bring in their ID/Right to work on day one of induction, to prove they are the same successful candidate that was recruited. This provides you with a first line of defence against infiltration by having exploited workers placed within a legitimate operation and perpetrators who look to exploit others for personal or financial gain.  
  • Conduct due diligence on any temporary labour providers to ensure that they are also conducting necessary right-to-work and ID checks, providing you with assurances that you have legitimate temporary labour, who are not exploited workers or victims of modern slavery. 
  • In terms of the logistics industry, practical advice involves conducting a site visit specifically focused on the recruitment experience of employees. Additionally, it is crucial to ensure that HR (Human Resources) and supervisor staff undergo training to enhance their awareness of modern slavery issues. This proactive approach contributes to building resilience against potential risks and fosters a more vigilant and informed workforce. 


A Worker-centric approach 

  • Explain and ask workers whether recruitment fees have been paid and to whom. Ensure that the worker understands what could be included in the term ‘recruitment fee.’ The payment of recruitment fees is a form of labour exploitation, an indicator of modern slavery. 
  • Ensure workers are informed about whistleblowing avenues and methods to report concerns and check these extend to the temporary labour too. Mechanisms like this enable those who are potential victims of labour exploitation or modern slavery an avenue to report concerns. 
  • Employers should do all they can to map out the recruitment and ‘onboarding’ journey as best they can with specific dates to allow workers to prepare. Clearly explain terms and conditions to workers, including start dates and work schedules. with seasonal migrant labour, it is vital for employees to know their start dates. Employees should know when they can expect their first day of work, their first salary, and the immediate costs they may have to plan for upon their arrival in the country. There have been instances of employees arriving with no money, no work for days or weeks, and therefore no pay, which places them in a highly vulnerable situation to exploitation. 
  • Language barriers are a vulnerability that can be used in the exploitation of a workforce. Providing guidance in different languages for workers whose first language is not English not only creates an inclusive environment but can give workers the confidence to speak up and get help if something is not right about their employment.  
  • Understand the recruitment journey of your temporary workforce. Conduct sample worker welfare discussions to ascertain the profile of your temporary workforce and any vulnerabilities to modern slavery and labour exploitation.  
  • If your business operates in the food production or packaging, horticulture, agriculture, or shellfish gathering sectors of the UK labour market, verify that any labour provider is licensed with the GLAA (Gangmasters and Labour Abuse Authority), checking for any non-compliance and recent inspection results. It is a criminal offence to enter into an agreement with an unlicensed gangmaster and it is vital to ensure that the supply of workers into these sectors is legal. 


Long Term Measures 

Peak season is a point of opportunity for businesses, but with this comes the year-round responsibility to safeguard your workers’ rights and dignity. Demonstrating your commitment to this in the long term is not only beneficial for your workforce but also builds a positive business reputation. How can you increase your resistance and confidence that you are striving to mitigate the risks of modern slavery and exploitation in your workforce?

These are our top 5 tips: 

  1. Know your suppliers 
  2. Invest in a confidential whistleblowing mechanism and publicise it widely across all areas of your business 
  3. Collaborate with Industry Groups to share best practices 
  4. Make use of Hope for Justice’s ‘Spot the Signs of Modern Slavery’ materials and display them around staff areas such as canteens and walkways as well as in private areas such as restrooms and bathrooms. 
  5. Create an inclusive workplace culture where everyone, including temporary seasonal workers, is valued and respected 


Finally, remember that SFA can help your business plan for the peak season and beyond to increase your resilience to the risk of modern slavery and labour exploitation. Working together we can be vigilant all year round, not just at Christmas.  

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