Addressing worker exploitation: Essential guidance for HR

The UK faces a worker exploitation crisis. Labour abuse reports have surged by over 40% annually since 2021, with late 2024 recording the highest modern slavery referrals since monitoring began. Alongside being a humanitarian issue, this undermines fair competition and damages legitimate businesses.

In this article, we take a closer look at how HR professionals and employers are uniquely positioned to disrupt exploitative workplace practices before they take hold.

Guidance for employers by the Better Hiring Institute (BHI)

The Better Hiring Institute, collaborating with JobsAware, Reed Screening, the Gangmasters & Labour Abuse Authority (GLAA), and the Office of the Director of Labour Market Enforcement, has produced the first analysis of what drives worker exploitation in the UK.

This multi-agency approach shifts focus from enforcement to proactive prevention, providing employers and HR with steps to dramatically reduce exploitation from their operations and supply chains.

Understanding the root causes

The BHI’s guidance identifies the key causes of exploitation:

1. Immigration system manipulation: Some employers exploit visa restrictions, withhold documents, impose illegal recruitment fees, and misrepresent employment terms to trap workers.
2. Enforcement fragmentation: Overlapping jurisdictions and inconsistent oversight create confusion for workers, underreporting and limited state enforcement.
3. Exploitative recruitment: From trafficking to misleading advertisements and exploitative contracts, these practices can act as gateways to serious abuse.
4. Economic desperation: Financial hardship makes workers vulnerable to exploitation as survival needs override concerns about working conditions.
5. Lack of knowledge: Complex modern employment arrangement such as “working from home” and temporary working, leave workers unclear about their rights.

What employers and HR teams can do

Ensure ethical recruitment processes

Only advertise jobs on platforms that demonstrate compliance with the Online Safety Act.

Audit your recruitment partners 

Apply pressure to supply chains to uphold compliance and fair treatment of workers. Conduct due diligence on recruitment agencies, umbrella companies, and labour providers. Follow advice on managing supply chains using the Better Hiring Toolkits.

Review contract models 

Promote transparency in employment contracts and support workers' access to information about their rights. 

Establish anonymous reporting mechanisms

Support initiatives that raise worker awareness, improve reporting mechanisms, and foster a culture of accountability and fairness across their organisation and supply chain. Create safe channels for workers to report concerns.

Train your workforce 

Provide training on modern slavery and what to look out for. Engage with tools such as the Better Hiring Institute's toolkits and the GLAA's website.

Collaborate with enforcement agencies 

Collaborate with regulatory bodies like the GLAA (and the Fair Work Agency once that body has been established), and support initiatives that raise worker awareness. Build relationships with relevant authorities and share intelligence.

Document everything 

Maintain comprehensive records of all employment arrangements and working conditions. Use the Better Hiring Institute's guide to international recruitment for best practice in managing overseas worker recruitment.

Conclusion

Tackling worker exploitation requires vigilance and a proactive approach to compliance. At Browne Jacobson, our employment law and HR services teams can support your compliance and ethical employment objectives that help protect your organisation and reduce the risk of worker exploitation.