October is anti-slavery month
It is estimated that there are 49.6 million victims of modern slavery worldwide with an estimated 122,000 victims in the UK.
Governments around the world are seeking to make businesses more accountable for abuses in their supply chains and are insisting on anti-slavery transparency disclosures with a steady increase in criminal and civil enforcement actions being taken. Businesses can no longer relinquish their responsibilities by turning a blind eye to what is happening in the supply chain.
Why does this matter for Orbit and our supply chain?
We are committed as an organisation to identifying and remedying (with our partners) any instances of modern slavery in our supply chain.
As a provider of housing services and a construction employer, we operate in high-risk areas for modern slavery.
Construction is a major employer and vibrant part of the UK economy. An estimated
2.2 million people are working on the buildings and infrastructure and while the sector is striving to meet its sustainability and carbon targets, it faces particular challenges in the ethical management of labour. The ongoing skills shortage, which has historically been offset by migrant workers, has been exacerbated by the pandemic and changing immigration rules. The sector’s labyrinthine network of subcontractors obscures visibility of lower levels of supply chains. Financial penalties for delays, shortages of labour and materials, and the rapid turnover of workers, place numerous pressures on contractors on a daily basis.
The built environment is considered high risk for modern slavery and wider exploitation.
The Unseen Modern Slavery helpline has reported a 35% increase in calls related to the construction sector. Operation Cardinas unravelled how an organised crime group placed more than 500 victims of modern slavery onto major construction sites in the South East between 2008 – 2019. The criminals prosecuted under Operation Cardinas circumvented checks and balances by fraudulently acquisition of Construction Skills Certification Scheme (CSCS) cards, use of recycled CSCS cards, creation of fake and doctored pass letters (during the period to obtain passes), addition of other bogus qualifications, use of limited companies and abuse of labour contracts.
Some people interviewed as part of this operation said they felt they were ‘battling a culture of box ticking and compliance’, as well as a resistance from some quarters that labour exploitation was a risk at all. Building sites can be tough environments, which can filter into an assumption of how people can be treated. Many opportunities to identify risk were missed such as:
· Appearance
· Clothes and kit
· Site inductions
· Administration
· Security
· Informal approaches
· Banks & financial activity.
To date, few large cases of modern slavery have emerged in construction, which has led some to argue that the industry does not have a problem. However, visibility of what is happening in the lower tiers of supply chains is often poor, or non-existent. Even on well-run sites, ethical audits have unearthed a range of problems.
Some fall within the 11 forced labour indicators as defined by the International Labour Organisation (ILO). The indicators include deception, abuse of vulnerability, intimidation and threats, withholding of wages, debt bondage and excessive overtime.
In a sector struggling with low profit margins, ethical labour initiatives must compete with other priorities such as health and safety, quality, environment or mental health campaigns.
And while major businesses must write an annual modern slavery statement on the steps that they are taking to address modern slavery risk in their operations and supply chains, they do not have contractual relationships with small businesses in the lower tiers of supply chains, where the risk is highest.
The Global Slavery Index 2023 shows countries and goods at highest risk of modern slavery.
However, there isn’t a simple solution to this problem, even experienced and well-resourced teams can have an understanding the nuances of complex taxation, employment and visa issues. The difficulties of providing effective support to workers, and battling noncompliance in supply chains has led to updated Procurement Policy Notes from UK Government during 2025 (PPN09/25 Guidance on Tackling Modern Slavery).
There is still much more that can be done.
What is Orbit doing and what are we asking from our supply chain?
We are not suggesting that we are the experts on tackling modern slavery either within the Housing Sector or within our supply chain. We are committed to working with colleagues, partners, third sector organisations and our supply chain to improve the identification of the risk of modern slavery. We want to work with partners to remedy any instances identified and support survivors of modern slavery.
During 2024/25 we revised our modern slavery statement in line with best practice from TISCReport and UK Government guidance. The initial focus has been on providing targeted training for our Procurement Function and understanding the steps being enacted by providers in high-risk categories. We have also engaged with our customer function to ensure that there is a unified approach across Orbit in terms of protecting our customers.
For 25/26 we are committed to extending mandatory training to identify the risk indicators and the impact of Modern Slavery to all our colleagues. Our Internal Audit and Talent & Recruitment Function have also implemented more stringent actions in support of this for our construction sites. Procurement are also initiating dialogues with our supply chain to provide greater guidance identified following audits by TISCReport of our suppliers’ Modern Slavery Statements. This is the first step in an exercise in collaborating with our third-party partners to raise awareness of this topic.
- Compliance with the Modern Slavery Act 2015 (section 54) is mandatory
- Organisations with £36m+ turnover must publish annual transparency statements and KPIs
- All statements must be registered publicly
Orbit Modern Slavery Statement 2024
Further reading:
Find out more, click here
Key references:
Modern Slavery Act 2015, section 54
PPN05/23 - Tackling Modern Slavery in Government Supply Chains
Modern Slavery Statement registry
Modern Slavery Assessment Tool
International Labour Organization’s Global Estimates of Modern Slavery (GEM)
