The trafficking of vulnerable people into modern slavery is not a distant problem confined to developing nations. With 136,000 people estimated to be living in modern slavery in the UK alone, this insidious crime is often hiding in plain sight within the supply chains and workforces of legitimate industries and house-hold names.

Nick Dale, director of intelligence at STOP THE TRAFFIK and a former West Midlands Police officer, has spent years investigating organised crime groups that exploit vulnerable workers. Drawing on his policing experience and data-driven work in the anti-trafficking space, he shares how employers can spot risks, protect workers, and reduce exposure to litigation and reputational harm.

Dale’s first foray into the underbelly of human trafficking revealed just how invisible but pervasive modern slavery can be. While serving as a chief inspector in Birmingham in 2015, Dale led Operation Fort, Britain’s largest and most complex modern slavery investigation to date.

The investigation led to the jailing of 12 offenders linked to two Polish crime families, with sentences ranging from three to 11 years.

Their criminal conspiracy, described by the judge at Birmingham Crown Court as the “most ambitious, extensive, and prolific” slavery network ever exposed in the UK, involved the trafficking of more than 400 vulnerable people from Poland into England with the promise of work and a better life.

But once in the gang’s clutches, the victims, who ranged in age from 17 to 60, were forced to work gruelling hours at recycling centres, farms, and meat-processing centres. Left with as little as £20 a week, the rest of the victims’ wages were taken by the organised gang. For some, this meant they were paid as little as 50p an hour.

“On the face of it, everything looked legitimate,” Dale recalls. “The workers had national insurance numbers, bank accounts, and contracts through recruitment agencies. But the reality was they were exhausted, hungry, and washing in canals. Their wages were siphoned off by traffickers who controlled their bank cards.”

When not working, the workers were housed in squalid, rat-infested housing across the Midlands; forced to sleep up to four in a room on filthy mattresses and with little to no access to clean or hot water, those that complained were threatened and physically abused by the gang members. 

The gang also convinced their victims that they would be arrested, beaten by the authorities, and deported for working illegally should they seek help from their employers. Isolated, fearful, and unable to speak English, the enslaved workers felt they had no choice by to stay with their captors.

For the employers in question, the signs of modern slavery, though subtle, were visible: workers too tired to function, common addresses and phone numbers across multiple employee records, or someone else filling in forms for non-English speakers.

Indeed, employers are often best placed to spot early indicators of exploitation. According to Dale, these include withdrawn behaviour, poor hygiene and signs of physical injuries, limited communication skills, and administrative anomalies. It is therefore important to know what to look for.

“Workers may avoid eye contact, not engage with you, or seem fearful of others in the workplace,” he says. “They might look dishevelled, arrive hungry, or lack proper hygiene because they don’t have access to hot water.”

Shared addresses, next-of-kin numbers, or bank accounts across multiple workers should also be red flags. Non-English speakers may rely on one “alpha” work colleague who could be reporting back to traffickers on the victims and warn them of an employer’s suspicions.

Employers should therefore create safe spaces for workers to talk, ideally in their native language, Dale adds, noting that some of the best recruitment agencies now employ outreach workers who would visit workers at home to check on their wellbeing.

Crucially, modern slavery often leaves a paper trail, making internal investigations into suspicious activity much easier than it once was. Dale argues that employers and banks alike should treat unusual patterns as potential indicators of trafficking. In Operation Fort, for example, traffickers were regularly seen opening bank accounts for workers and then withdrawing cash from multiple ATMs. 

“We spoke to someone at the bank who said, ‘Yeah, we know that guy. He comes in opening bank accounts with Polish workers because they can’t speak English. Then we see him going up and down the high street with a pile of bank cards, cashing money out’,” recalls Dale.

STOP THE TRAFFIK

With an estimated 49.6 million people currently trapped in modern slavery worldwide and people trafficking generating £270.4bn ($498bn) in profits that move largely unchecked through financial systems each year, the mission to end human trafficking is a daunting undertaking.

Believing that trafficking can be prevented if communities, businesses, and governments share intelligence and act together, global charity STOP THE TRAFFIK runs awareness campaigns to protect at-risk communities, provides tools like the STOP APP for anonymous reporting of trafficking offences, uses data analytics to uncover the latest trafficking routes and hotspots, and stays up to date on the latest recruitment tactics and red flag indicators.

Founded in 2005, the UK-based organisation has partnered with the likes of IBM, HSBC, and Facebook, as well as law enforcement, to help spot and stop exploitation in supply chains around the globe. Key legal sector partners Seyfarth Shaw and Clifford Chance also provide vital legal advice.

The charity’s recently launched Traffik Analysis Hub is a suite of IBM-developed technology used to collect, aggregate, and analyse data from multiple authenticated partners and public sources to reveal patterns, hotspots, and networks of trafficking that would be hard to observe in isolation.

Legislation with teeth

In recent years many governments worldwide have moved to bolster laws and regulations aimed at preventing modern slavery, with new rules mandating human rights due diligence in supply chains and hefty penalties for non-compliance.

Often the blueprint for many new bills, the UK’s Modern Slavery Act 2015, now ten years old, has been heavily criticised for its lack of enforcement power and for essentially becoming a box-ticking exercise for those corporates that make any compliance efforts. 

Section 54 of the legislation requires businesses with a turnover of £36m or more to produce a modern slavery statement each year. The statement should set out what steps the organisation has taken to ensure modern slavery is not taking place in its business or supply chains.

But writing in IEL in June, Seyfarth’s Peter Talibart described the lack of real penalty for breaching section 54 as “absolutely shameful” and in need of fixing. 

Dale agrees reform is needed: “The modern slavery act was groundbreaking legislation, but I think section 54 needs more teeth. Ideally, we should have a regulatory body specifically set up to oversee adherence, prosecute companies that don’t comply, and fund itself through fines.”

He also highlights the difficulty of securing compensation for victims. Despite Operation Fort proving traffickers pocketed around £2.5m from their slavery network, only around £500,000 has been recovered – and none of it went to the victims. Stronger duties to provide reparation, Dale argues, should be built into future legislation.

Businesses that are content to await reforms may be in for a rude awakening, however, as the existence of modern slavery can still present legal risk.

Trafficking victims are often pushed into unsafe working conditions by their gang masters, presenting health and safety risks for both themselves and co-workers. 

“We had cases where people were made to work a night shift straight into a day shift. These were jobs involving heavy lifting or sharp tools, and workers were turning up exhausted. Employers have a direct health and safety responsibility there,” Dale says.

And then there is the risk of claims brought against employers who fail to notice the signs of exploitation. In 2021, three Polish workers freed by Operation Fort sued recycling firm Biffa Waste Services for failing to prevent forced labour within its workforce. The two men and one woman said they received about £5 a week in cash for their work sorting rubbish on a conveyor belt.

“It’s important to tell employers that, not only can this happen to you, but you can be sued as a result of it,” warns Dale.

The exploitation of vulnerable people also presents a reputational danger. A recent BBC investigation found evidence of forced labour of Czech citizens within a now-defunct bakery that supplied products to major supermarkets, including Tesco, Waitrose, Sainsbury’s, M&S, Asda, and the Co-Op. 

The criminal gang, which preyed on 16 homeless Czechs, also forced its victims to work 70 to 100 hours a week in a Cambridgeshire branch of McDonald’s. At the McDonald’s branch in question, at least four victims’ wages, totalling £215,000, were paid into one account controlled by the gang. 

The revelations have caused significant embarrassment to the major high street brands which have pledged to review their labour inspection procedures.

Trending risks

Exploitation risks continue to evolve, however. Drawing on data from STOP THE TRAFFIK’s Traffik Analysis Hub, Dale points to a rise in fraudulent job adverts and recruitment scams, particularly targeting overseas workers. 

“We’re seeing an increase in fake adverts for seasonal visas, with charges of thousands of pounds. That debt bondage can then lead to exploitation,” he notes, adding that major sporting events, such as the 2024 Paris Olympics and the upcoming FIFA World Cup, can also drive greater demand for the trafficking and sexual exploitation of vulnerable people. 

“In the two to three months before the Olympics, we observed an increase in demand, likely from people arriving to work in hospitality or stadium construction who were also seeking sexual services. And then an increase in price when the Olympics started, which we saw as corporate clients attending the games and willing to spend more money,” Dale explains.

“Whenever there’s a large movement of people, the risk increases. Victims are isolated, far from home, and traffickers exploit that.”

Whether it be traditional forms of forced labour or sexual exploitation, employers across the hospitality, construction, and logistics sectors should be particularly vigilant in the run-up to global events.

A shared responsibility

For Dale, the message to employers is simple but powerful: exploitation thrives where no one looks closely enough.

“You can’t know the full experience of every worker,” he says, “but you can be expected to understand the risks in your industry, and you can be expected to care about your workers.”

Businesses that act early – by monitoring, questioning, and engaging – can not only protect themselves from legal and reputational risk but, more importantly, help prevent lives being stolen by traffickers.

“If you understand what human trafficking is and you care about it, those are the first two important steps,” Dale stresses. “You’re the expert in your industry – you know your supply chain better than anyone else.”

Practical steps to combat slavery

Businesses seeking to mitigate modern slavery risks should consider the following actions:

- Train managers and supervisors to spot behavioural and administrative red flags.

- Audit supply chains regularly, including subcontractors and recruitment agencies.

- Use data analytics to flag anomalies in payroll, addresses, and bank accounts.

- Engage workers directly, in their own language, through outreach programmes.

- Establish safe reporting mechanisms so staff can raise concerns without fear.

- Review recruitment practices, particularly when hiring through agencies or overseas.

- Support law enforcement and NGOs by sharing intelligence where exploitation is suspected.