Abta issues guidance for agents on Modern Slavery Act. Ian Taylor reports


COMMENT: Make sure your business is not contributing to modern slavery, says Nikki White, Abta director of destinations and sustainability


We need to consider what modern slavery and human trafficking mean for the travel industry, given recent examples that have come to light. Lithuanian migrants,


trafficked to work in Kent on farms producing eggs for companies such as Happy Egg, recently took successful legal action, while Nestlé has admitted the use of forced labour in its seafood supply chain in Thailand. At the end of July, Theresa


May pledged £33 million to tackle modern slavery, describing it as “the great human rights issue of our time”. Companies from all sectors


are affected, including retail, food, apparel, fisheries, manufacturing, farming, construction and mining, and businesses need to identify potential risk areas. However, the


nature and complexity of the travel supply chain bring a unique set of challenges. Elements of the supply chain that can pose risks include staff at hotels, resorts, restaurants, bars and entertainment venues. They could include the laundries hotels use, the staff at excursion providers and venues, and the practices of staffing agents for cruise


companies or


“The nature of the travel supply chain brings a unique set of challenges”


other recruitment agencies. Modern slavery means holding a person in slavery or servitude. That might seem extraordinary in this day and age, but it happens. Forced or compulsory labour and human trafficking are still evident. The International Labour Organisation estimates there are 21 million people worldwide in forced labour, defined as “work or service extracted under threat of a penalty and for which the person has not offered him or herself voluntarily”. It can involve


any or all of the following: unsafe/ unhygienic working or living conditions; lack of rest, food or


water; use of underage workers; ‘working hours’ out of compliance with national or industry standards; lack of contracts or documentation; imposition of fees or withholding


wages; and deceptive recruitment practices. Many


companies already have policies in place to promote ethical business practices and


protect workers from abuse in their own organisation and their supply chain. However, the Modern Slavery Act 2015 requires all businesses with a turnover of £36 million or more to publish a slavery and human trafficking report. This should set out the steps the company has taken to ensure slavery and human trafficking are not taking place in the business or supply chain, or state that no steps have been taken – and it must be published online. It offers an opportunity for businesses to manage potential risks in their operations and supply chains. Now is the time for businesses to ensure preparation of a ‘modern slavery’ statement. Companies should also consider the following best practices: l Codes of conduct for the organisation and suppliers


l Due diligence processes to monitor business and supplier activities


l Measures to improve transparency in the business and supply chains


l Staff training l Hotline for whistleblowers l Appropriate auditing, such as Travelife for hotels. Abta is working with its members in a number of ways to tackle these issues. Hotels that are Gold-certified by sustainability certification programme Travelife have already demonstrated compliance with international labour standards and human rights. Abta’s Modern Slavery Guidance gives an overview of the act and guidelines for the industry, and is free to members. We’ll also be running workshops offering practical support. For more information, visit abta.com and travelife.org


How to adhere to the Modern Slavery Act 2015


Businesses with a turnover of £36 million or more are required to publish an annual modern slavery statement. Those with a tax year ending


March 31 must publish a statement this year for 2015-16. The Home Office recommends publication within six months of the year end. There is no standard format, but the statement should include: n Organisation structure, business and supply chain


n Policies on slavery and human trafficking


n Due diligence processes in relation to slavery and human trafficking


n Areas of business/supply chain where there is a risk of slavery and human trafficking, and steps taken to manage that risk


n Appropriate measures of effectiveness in ensuring slavery and human trafficking is not happening


n It must be in plain English and include links to relevant documents


nThe statement must be displayed on the organisation’s website, with a prominent link on the homepage


Source: Abta


11 August 2016 travelweekly.co.uk 63


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