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HMRC internal manual

Labour Provider Guidance

Stakeholders: Illegal working and modern slavery: Indicators of illegal working and modern slavery

Immigration Act 2016

Spotting the signs of illegal working and worker exploitation is no easy feat unless you know what you are looking for. The signs, also known as indicators, sometimes can only be uncovered by examining documentation, business records and accounts. But others, the immediate physical, behavioural and workplace indicators are more obvious.

Indicators of modern slavery could be found in any workplace, but are most likely to be seen in industries that have a high turnover of low skilled staff, deal in cash and have labour as a high proportion of input costs. Industries with higher prevalence include catering, care, agriculture and construction. HMRC intelligence indicates that more extreme forms of worker exploitation are taking place (in addition to the sectors above) in the sex trade, nail bars and  other forms of manual labour (e.g. car washes). Often large numbers of people are housed in inhumane, squalid and overcrowded living conditions.

Indicators of illegal working and/or modern slavery can include:

  • Controlling tactics – being watched all the time, being afraid to speak up, allowing others to speak for them or being told what to say, retention of passports and identity documents (the workers can neither leave nor prove their identity status), restriction of movement and confinement to the workplace or to a limited area - rarely left alone or never seem to travel alone, debt-bondage, withholding of wages or excessive wage reductions that violate previously made agreements, threat of denunciation to the authorities regardless of whether the worker holds legal status in the UK or not.
  • Unusual or dangerous working practices – evidence of control over the workers’ movements such as being bussed en masse to and from their place of labour, often at unusual hours, working unusual or long hours with little or no access to their earnings, safety equipment/procedures might appear inadequate.
  • They might live and work in the same property in dirty, cramped or shared and overcrowded accommodation and there may be evidence of few or no personal possessions. Accommodation might be provided by the employer and subject to change at short notice, or not subject to a formal tenancy agreement.
  • Appearance: signs of physical or emotional harm (to either the individual or their family) or the threat of harm, general cleanliness – looking underfed, malnourished, withdrawn, weary, dirty and generally unkempt, clothing – is it unsuitable for the surroundings or the work they do?
  • Behaviour: signs of anxiety and a wariness of authority, seeming isolated with limited social interaction or contact with people outside their immediate environment, fearful for themselves or their family, vague about the cause of an illness or injury the cause, or unwilling to seek help, avoiding eye contact, being reluctant or afraid to say what their immigration status is.
  • Documentation: evidence of workers with identical National Insurance numbers (NINO), evidence suggesting workers are receiving benefits to which they are not entitled, poor record keeping, lack of documentation, reasons to suspect that paperwork has been altered or forged, correspondence or business address being different from the place of work, agencies providing other services (such as accommodation or transport) to the worker, for which the worker is being charged large sums, evidence to suggest that the Agricultural and National Minimum Wage (NMW)/National Living Wage might not be paid and/or other statutory requirements are not being met.