Know your operations: Anti-Slavery Week 2026
14 October
In October 2025, Detective Superintendent Nikki Shimwell, Head of the Modern Slavery Unit at South Yorkshire Police, told us that the modern slavery cases police uncover are “only the tip of the iceberg”.
An estimated 50 million people worldwide are living in modern slavery, and 86% of forced labour happens in the private sector, inside ordinary workplaces and supply chains. That’s why governments are placing more responsibility on businesses to find it, with penalties for those that fail to.
Over the past year, the rules on how far businesses have to look below the surface have changed a great deal, in the UK, in the EU and further afield. As part of this year’s Anti-Slavery Week, and in the run up to UK Anti-Slavery Day on 18 October, we take a look at what has changed – and what businesses need to do as a result.
What has changed in the past year
For UK businesses, the biggest change is the Immigration and Asylum Bill, introduced in June. It contains the first changes to the Modern Slavery Act’s reporting rules since 2015. If it passes, the law will set out what a modern slavery statement has to cover. Companies will need evidence to back up what they say, and those that don’t comply could be fined.
At the end of June, the Crime and Policing Act 2026 made it easier to hold companies criminally liable for modern slavery offences committed by senior managers in the course of their role. In April, the new Fair Work Agency also brought the UK’s main labour market enforcement bodies, including the Gangmasters and Labour Abuse Authority, together into one organisation, with powers to investigate businesses and issue penalties.
Businesses can also refer to the government’s updated Transparency in Supply Chains (TISC) guidance on what their modern slavery statements should include.
For anyone selling into, or importing from, Europe, the EU Forced Labour Regulation now has a set of implementation guidelines, which were published in June. From December 2027, products made with forced labour can be banned from the EU market, wherever that forced labour took place. Its reach extends deep into supply chains, right down to raw materials.
Other countries, including Australia and Canada, already require companies to report on forced labour risks. So, in more and more markets, you’ll be expected to show that you know who is doing the work.
The workers most at risk
The people most at risk of exploitation are often the ones nobody is looking at. In your own operations, they might be agency staff on the night shift, cleaners or security guards employed through a contractor, or seasonal workers. In your supply chain, they might be migrant workers who paid a fee to get their job, or people working in a subcontracted factory that doesn’t appear on your supplier list.
The signs are usually subtle. Workers might always be transported together, share an address or phone number with several colleagues, or seem to have someone else managing their pay and paperwork. Audit findings can also point to problems, such as unexplained wage deductions or excessive overtime.
None of these are definitive proof of exploitation, but they’re all worth looking into. When several appear together, they start to build a clearer picture of whether someone is being exploited. The ILO’s indicators of forced labour, updated in 2025, set out eleven of the most common signs and are a useful reference for anyone who needs to know what to look for.
Know your operations
When Nikki spoke to Gabriella Wass as part of our Inherently Human Voices video series, her advice was simple:
“The real work can be done by knowing your operations and knowing your staff.”
In practice, that means talking to workers yourself instead of relying on what their supervisors tell you. She suggested checking that wages are paid into workers’ own bank accounts, that people have chosen where they live, and that nobody else is holding their passport. She also stressed the importance of training managers to spot the signs and report concerns, even if they’re unsure.
Those checks remain good practice. Under the new rules, keeping a record of them, such as notes from conversations with workers, payroll checks and training logs, also gives you the kind of evidence regulators will expect to see.
Where to start
The right place to start depends on where your risks sit. If your business has sites such as factories, farms or warehouses, begin by mapping exactly who works there on a typical day and who employs them, and by making sure your site managers know the warning signs. If most of your risk sits further along your supply chain, start by identifying which suppliers rely on agency, migrant or seasonal labour, and assessing the checks they have in place.
You can find useful free resources here:
– https://www.slavefreealliance.org/anti-slavery-day/
– https://www.stronger2gether.org/anti-slavery-day/
