Here we look at labour exploitation in the warehousing industry and the headline trends for this sector including victim profiles, location and working conditions. 

Victim profile

Victims are predominantly male and of Romanian nationality, followed by Polish nationals. Age is largely unknown.
Vulnerabilities may be targeted, particularly individuals who have difficultly communicating in English. 

Location

The highest concentration of reports is in the East Midlands region. 

Recruitment

There are limited reports suggesting recruitment via friends and family, but methods of recruiting workers are not often reported. 

Accommodation

Accommodation is commonly supplied by the exploiter and is usually in a residential property. 

Payment

Wages may be withheld, including holiday pay. There are reports of workers earning less than National Minimum Wage. 

Working Conditions

Health and safety breaches are reported including fire safety, lack of training and excessive working hours. Inadequate breaks, including meal and comfort breaks also.

There are limited reports concerning debt bondage and restricted movement of workers. Aggressive behaviour and threats can be used to control workers.

Horizon scanning

The growth of online shopping is set to continue as is consumer demand for quick, convenient delivery therefore the need for workers in this industry is likely to increase.

There are fears that the points-based immigration system will result in a labour shortage.

More warehousing space is required, and this has been accelerated by the pandemic.

Key questions to prevent and identify labour exploitation 

• Do recruitment processes include questions to identify whether a person may have been trafficked, paid work finding fees or was otherwise exploited whilst seeking work?
• Do you know and understand each level of your supply chain?
• Do you have a code of conduct for factories/suppliers? Are there regular audits to identify and address any exploitative labour practices and modern slavery?
• Do you have a whistleblowing policy and publicised mechanisms for workers to report concerns?
• Do you have any additional due diligence checks for workers at risk of being exploited? Including access to translation services?
• How do you ensure workers on site know how much they should be paid?
• Do members of your organisation receive training on spotting the signs of modern slavery and labour exploitation? 

What to consider when reporting intelligence  

Example: Subcontracted warehouse workers are being paid less than the National Minimum Wage. They work shifts of up to 13 hours per day without any breaks. No holiday pay or sick pay is paid. Workers may be fined if they do not show up for work.

What further information may assist the GLAA?

• How many workers are likely to be affected?
• Are all worker demographics affected?
• Where are the warehouses located?
• Are there any more company details?
• Are directly employed warehouse workers subject to better working conditions?
• Are there other arrangements made for accommodation and transport to/from work?
• How long has this exploitation been occurring?

Whilst not all factors may be known, any additional details will assist the GLAA in identifying people and locations involved for operational purposes and to improve our intelligence picture.

​Resources 

GLAA resources are available including our Spotting the Signs leaflet.

Find out more about the Textiles Protocol.

Who to contact

Please report to the GLAA:
• Unlicensed trading in the regulated sector (agriculture, horticulture, shellfish gathering and any associated processing and packaging) across the UK.
• Labour market offences (non-payment of the National Minimum Wage, breach of Employment Agency Standards) in the regulated sector in England and Wales
• Individuals, labour users or labour providers who are suspected of modern slavery and human trafficking in any labour industry (excluding sexual exploitation), or individuals who are potential victims of such activity in England and Wales.

Please report to partners:
• Issues of National Minimum Wage only, in sectors that are not GLAA regulated to the HMRC NMW team (https://www.gov.uk/government/organisations/hm-revenue-customs/contact/national-minimum-wage-enquiries-and-complaints)

• Health and safety issues only (all sectors) to the Health and Safety Executive (http://www.hse.gov.uk/contact/concerns.htm)

• Workplace relations and employment law issues (including contract issues, discrimination and grievances) to the Advisory, Conciliation and Arbitration Service (ACAS) (https://www.acas.org.uk/index.aspx?articleid=1410)

• When there is an immediate threat to life contact the police emergency number.

• To report labour exploitation, human trafficking or modern slavery outside of the regulated sectors in Northern Ireland or Scotland, contact the local police service.