Ensure there’s no slave labour in your Black Friday warehouse.

Ensure there’s no slave labour in your Black Friday warehouse.

Black Friday this year falls on November 23rd and Cyber Monday is on the 26th. The days immediately before and after these two key dates in the global shopping calendar are probably the busiest periods for any warehouse anywhere, as shoppers literally swarm over ecommerce sites and high street retailers, looking for the best bargains.

According to 2017 research published by McKinsey, 92% of UK consumers (there are 27.2 million households in the UK) are aware of Black Friday and 30% plan to buy at least one item, typically online. Volume at this scale puts a huge strain on warehouse workers and management, many of whom are already struggling to fill jobs in some sectors.

Across the Black Friday/Cyber Monday weekend, well over £7 billion will be spent in the UK alone, resulting in 225 million e-commerce parcels predicted to be in transit. Over 82,000 lorries and vans will be on the roads, with a lorry leaving some of the large ecommerce fulfilment centres every 90 seconds. That means warehouses will need an awful lot of additional labour to fulfil demand, and logistics workers with relevant skills are already scarce in some sectors.

At the same time, cases of modern human slavery are rising all the time, up 35% in the past year and the warehousing sector is considered a higher risk, according to the the Gangmasters and Labour Abuse Authority (GLAA). In fact, the UK as a whole is considered by experts to be one of the countries where slavery trafficking for labour exploitation is very prevalent, according to The Guardian. It occurs in every part of the UK but, according to government data, the majority of victims referred to police between April and June this year were in London, West Yorkshire, the West Midlands, Scotland, Merseyside and Essex. This means manufacturers, retailers and their logistics service providers should be extra cautious about who they employ or engage to support them through the busy Black Friday period, to ensure they are not inadvertently exploiting victims of modern slavery.

How to protect workers in your supply chain Indigo Software is endorsing the work undertaken by Hope for Justice and wants to raise awareness of the risks of unwittingly using slave labour in the warehouse. Hope for Justice is a global non-profit organisation which aims to end human trafficking and modern-day slavery.

Here is some best practice advice for companies, issued by Hope for Justice, to protect the workers in your supply chain.

1. Be aware of your obligations as an employer.

If you directly employ additional warehouse workers through a third party, you are responsible for ensuring the necessary due diligence is done when choosing a labour provider or recruitment agency. Never make assumptions. A lack of awareness and proper

checks is a key reason why traffickers have had so much success in infiltrating supply chains and placing victims of forced labour into unwitting businesses.

When using a third party, ensure that their labour provider recruitment processes include modern slavery questions and that key staff have received modern slavery awareness training.

Check that supplier audits include examining the steps taken to mitigate modern slavery and include worker interviews to investigate anything suspicious. Depending on the nature of your business, you may also need a separate licence, from the Gangmasters and Labour Abuse Authority (GLAA). In other sectors, rules are enforced by the Employment Agency Standards Inspectorate (EASI).

Agree a Service Level Agreement with the labour provider or agency to ensure services provided meet all GLAA Licencing Standards. Ensure the charge rates charged by the labour provider cover employment costs and comply with minimum rates.

Prior to any supplied worker starting work, the labour user must actively check that workers have:

* Been issued with understandable and compliant terms of employment

* Not paid any fee to gain employment

* A legal right to work in the UK (and that the document bearer is the individual working)

* Received back original ID documents, these should not be retained by the labour provider / agency

* Signed an agreement to opt out of Working Time Directive if working over 48 hours per week

* Had health & safety training required to do the job, within paid time and been freely provided with the PPE required for the job (following a risk assessment)

* Been offered safe, comfortable and hygienic accommodation if supplied by the labour provider or agency

* If transport is provided by the labour provider or agency, it must be safe and the vehicles and drivers comply with all necessary standards.

2. Rules that labour providers must abide by

Labour providers cannot:

* charge a fee to a work-seeker for work finding services

* stop someone from working elsewhere or terminating their contract with you

* make someone tell them the name of any future employer

* withhold payments or wages due

* supply a temporary worker to replace someone taking part in industrial action

* charge for a uniform without telling the worker in advance

* make unlawful deductions from pay.

Labour providers must ensure that workers are:

* paid for all the work they do and receive holiday pay

* not forced to work longer than 48 hours a week

* paid at least the National Minimum Wage

* protected under health and safety laws

* given written terms of employment.

While at work, the business should check that all agency workers:

* Have safe and hygienic working conditions and facilities (e.g. hygienic place to store food, access to potable water)

* Have a method to lodge a grievance or complaint to the labour provider, and can approach you if they have an issue

* Working hours are recorded accurately and all hours are paid legally and fairly

* Do not have excessive working hours (ETI Base Code stipulates no more than 60 hours per week)

* Have all necessary rest breaks (under the Working Time Directive)

* Are always treated with dignity and respect

* As a recommendation, undertake a full tender process; ensuring that the labour provider or agency that is selected meets all GLAA Licensing Standards.


When using a labour provider, seek verification and assurance that your provider is meeting its obligations to workers. Low rates that seem too good to be true often are, because the provider might not be meeting its obligations including minimum wage, national insurance, pension auto-enrolment costs and other overheads, transport costs etc.

Do not believe claims that a labour provider can offer a lower rate because the workers it supplies do not need to pay national insurance or holiday pay, for example.

Self-assessment questions for Labour Users

Remember that the commercial agreement between you and the labour provider makes you equally responsible for the workers. Plan in advance, stay engaged with the workers supplied to you, and ask yourself the following questions:

* Do you monitor levels of agency staff in your business to ensure you are not over-reliant on agency labour?

* Do you give your agency workers as much notice as possible of their shift patterns?

* Do you monitor pay and workings conditions for your agency workers compared with your permanent workers?

* Do you treat agency workers equally to your permanent workers?

* Do you have a transparent system to transfer workers from temporary to permanent?

* Do you advertise all vacancies clearly for all workers?

* Do you have effective communication channels with your agency workers for understanding what issues they might be facing?

* Do you include agency workers in the annual staff surveys?

* Do you help workers with limited English language skills to understand operating processes and procedures?