Modern Slavery – How can a banking solution assist a Business in being compliant?
Even though most people think that slavery only exists overseas, modern slavery in the UK is thriving. The British Government estimates that up to 13,000 people are in modern slavery in the UK today. Most commonly people are trafficked into forced labour in industries such as agriculture, construction, hospitality, manufacturing and car washes. Most people are trafficked into the UK from overseas, but there is also a significant number of British nationals in slavery. The most common countries of origin are Albania, Vietnam, Nigeria, Romania and Poland. (anti-slavery.org).
In response to this, in 2009 the UK Government introduced the National Referral Mechanism. To further focus on this issue, a number of current laws were brought together when in 2015 the Government introduced the Modern Slavery Legislation. Amongst other things, this requires and indeed places an emphasis on Companies with an annual turnover over £36 million to issue annually, a Modern Slavery Statement… “The Transparency in Supply Chains provision in the Modern Slavery Act seeks to address the role of businesses in preventing modern slavery from occurring in their supply chains and organisations.” To ensure that those companies with a lower turnover are encompassed, those within scope of issuing a statement are responsible for ensuring that their supply chain has in place checks and balances.
The Government and several other bodies (including the Gangmaster Licensing Agency), have published Papers, ran a TV advertising campaign, arranged seminars, and issued guidance notes to assist Employers (and their Employees) in identifying the signs of Modern Slavery, whether that be an individual case or as a group of people. Across the whole spectrum of UK Plc, Companies have been writing statements, posting them on their websites and in Company reports. One of the important notes to make is the term ‘Annual’. Companies must demonstrate annually an effective policy is in place and steps and reviews are taken.
Is this just a paper exercise and companies are simply ‘toeing the line’ or are they taking a proactive approach in adopting this and applying within their CSR programmes?
What has all this got to do with a banking solution?
- Firstly, and in simple terms, people can be paid via cash, cheque, or a Bank Transfer (to an account not in their name). From evidence gathered over the years by Enforcement Agencies, all three methods can indicate forced labour and/or coercion, i.e. does the individual have full control of their money?
- Secondly, legal migrants coming to the UK and even UK Citizens returning from years overseas, generally will not satisfy the UK Banking Industry compliance checks for a basic bank account and these under banked groups are left with no choice but to take one of the options outlined earlier.
There are alternatives provisions coming from the fintech industry for this group, thus ensuring that every person has financial control of their income!
In speaking to Businesses across the full spectrum of size and industry, some are taking this seriously, others see this as the individual’s problem and despairingly, a number are oblivious to the Act and their legal and moral responsibility.
As a CEO, MD, FD, HRD, Head of CSR and/or Compliance, Payroll Mangers (inhouse and outsourced), Audit Manager, bring your statement to life and run the following checks within your business and supply chains:
- Are many employees living at the same address?
- People paid in cash – quite simply don’t!
- If you issue cheques – is this in the person’s name? If not, don’t!
- If cheques are issued correctly, is this fair on the employee? The cost of cashing a cheque varies from a local arrangement with a Bank to a face value cost of between 5% to 18% via exchanges
- By transfer – Does the name of the account payee match that of employee? If not, investigate
- By transfer in to an account of the employee’s name – hopefully that’s everyone!
Although a tick may seem to be the right graphic, tackling Modern Slavery in the workplace and indeed in wider society, is not about just simply ticking boxes. One could easily argue that as a Human Citizen, it’s an obligation.
Suits Me Limited was launched in February 2015 and to date has created over 30,000 electronic bank accounts for predominantly low paid workers. In 2016, we received two awards from within the industry (UK & European) for ‘bringing financial inclusion to a previously excluded group’. We were then Awarded in May 2018, winner of the Recruitment International ‘Best for Banking and Financial Services’ Supplier Award was achieved through our strong alternative banking product, in harmony with our customer service to our referrers. The award was judged by feedback from our Employers/Recruitment Agencies in addition to the core product. Our aim is to be an ethical and accessible route for Companies and most importantly, affordable for Individuals. The programme has been created and developed to enable individuals to take control of their finance in a secure way and, with our cashback rewards programme, cost neutral.
Keith Poole - Managing Director
Tel: 0844 3221111