CONSUMER

COUNTY LINES

Consumer businesses and financial institutions are used by criminal networks to facilitate county lines by targeting vulnerable children hanging around outside fast food restaurants after school. The cost-of-living crisis has exacerbated the issues many families are facing, making children particularly vulnerable to county lines. STOP THE TRAFFIK Group is responding to the growing problem of county lines by running a prevention campaign on Tik-Tok, targeting 12-24-year-olds in London, but businesses also need to raise awareness of this issue within their staff and their customers.

County lines is structured on organised networks of criminal gangs using children and young people to transport drugs across the UK for them; this maximises profits and distances gang members from the criminal act of physically dealing drugs. In addition to having to transport drugs, children may be sexually and financially abused and exploited by the gangs.

Consumer businesses and financial institutions are used by these networks to facilitate this form of exploitation. It has been reported that county lines gangs target vulnerable children and young people hanging around fast food restaurants on their way home from school. Recruitment often involves the criminal gangs offering new clothes and warm meals to children and young people. The cost-of-living crisis is exacerbating the issue, given families’ increased vulnerability. Additionally, our intelligence has found these gangs laundering money from their drug sales through exploited children and young people’s bank accounts.

STOP THE TRAFFIK Group is responding to the growing problem of county lines by running a prevention campaign on Tik-Tok, targeting 12-24-year-olds in London. This campaign is informed by data and intelligence from STOP THE TRAFFIK’s Pan London Project, which aims to transform London’s response to modern slavery and human trafficking through data sharing.

What can your organisation do?

• • • Train front of house staff in fast food chains to spot the signs of county lines exploitation in a vulnerable young person and ensure staff know and understand the business safeguarding procedure.
    • Training children in schools and young adults about how to safely use their bank accounts, including the penalties for allowing their bank accounts to be used by traffickers, is an excellent way for financial institutions to raise better awareness and safeguard their young, vulnerable customers.

SEXUAL EXPLOITATION UNCOVERED IN KENYA TEA FARMS

A BBC Africa Eye investigation has revealed sexual exploitation of women working on Kenyan tea farms, bringing into question the efficacy of due diligence and reporting mechanisms. Companies in industries reliant on estate agriculture need to take steps to understand the local contexts of their supply chains and effectively implement solutions.

Trigger warning for mentions of sexual assault. 

The BBC Africa Eye and Panorama investigation interviewed women working on Kenyan tea farms who reported sexual abuse by their supervisors. Whilst this investigation focuses on tea, estate agriculture employs many women and other vulnerable groups in communities where risk drivers such as a lack of other employment options can trap workers in exploitative situations.

The companies who own the farms have sexual harassment policies and training in place, as well as a grievance mechanism for employees, however, this is proving ineffective and response to grievances has been limited. A core principle of effective human-rights informed business practice is the monitoring and evaluation of solutions which are put in place. This can be achieved by conducting implementation reviews, including interviews with frontline workers to consider their experiences of the implemented measures. Many companies focus on the success of having these mechanisms in place, reporting how many suppliers now have access, where a more effective approach would be to measure how they are being used and what the outcomes of these processes are.

Companies in industries reliant on estate agriculture should take from this report the need for detailed understanding of the local contexts of their supply chains and the systemic issues which drive vulnerability to exploitation. Solutions such as grievance mechanisms should be designed with these contexts in mind, with the collaboration of those most effected and closely monitored to ensure they are delivering against their objective of protecting at-risk individuals.

What can your organisation do? 

• Implement clear process and responsibilities for the measurement of the efficacy of measures against outcome-driven KPIs such as reducing the time required to address a grievance or reports;
• Conduct detailed risk mapping beyond tier one, particularly for high risk products, to identify human rights risks at a local level;
• Engage directly with workers and local NGOs within the development and implementation of due diligence approaches to ensure that their experience is represented and reflected in mitigation actions.
• Undertake implementation assessments directly with vulnerable workers to ensure a strong human rights culture is actually being fostered and workers are comfortable reporting potential non-compliances.

FISHING COMMUNITIES ON GHANA’S LAKE VOLTA IMPACTED BY WATER SCARCITY

Climate change is driving people out of the fishing sector in Ghana’s Lake Volta region, and into other high-risk sectors and regions for exploitation. These vulnerable communities will increasingly search for employment in sectors high-risk for child and labour exploitation, such as cocoa and cotton, in neighbouring countries.

A study released in 2013 predicted climate change-related water loss in the Volta River Basin would cause food production to struggle to meet demand. 10 years later, long dry periods have dwindled fish stocks in rivers and restricted people’s access to food, making them more vulnerable to exploitation.

Historically, the Lake Volta region is already extremely high-risk for exploitation, with many children being trafficked into the fishing industry. However, climate change is pushing people out of this industry and instead, individuals are now being trafficked from Ghana into Côte d’Ivoire, Burkina Faso, and Nigeria.

Consequently, people are being exploited in other high-risk sectors to maintain their livelihood, such as the cocoa industry which is high-risk for child labour within Ghana and Côte d’Ivoire. While some successes have been achieved to combat this shift, businesses must monitor high-risk sectors integral to consumer goods in the UK and Europe. This is even more crucial, given the heightened risks from climate change-induced vulnerability among communities in the Volta River Basin.

What can your organisation do?

• Implement regular supply chain risk mapping beyond tier 1 to identify areas in your supply chain reliant on high-risk consumer goods sectors in Ghana, Côte d’Ivoire, Burkina Faso, and Nigeria.
• Build risk mitigation systems specific to labour exploitation among identified high-risk sectors in order to support local communities responsibly.
• Monitor the possible impacts of climate change in high-risk water vulnerable regions and consider partnering with local businesses and NGOs to offer support for impacted communities in accessing clean water and adequate sanitation.

WORKERS FACING EXPLOITATIVE WORKING CONDITIONS ON ITALIAN FARMS

The Italian agriculture sector depends on a migrant workforce to drive production and meet demand in fresh fruit produce, such as grapes and kiwis. These migrant workers experience exploitative working conditions, including poor and health safety, on Italian farms and businesses need to address the modern slavery risks associated with this agriculture sector.

The agriculture sector is high risk for labour exploitation due to the reliance on migrant workers and isolated working conditions on farms or in packaging houses. As the 3rd largest global producer of kiwi, Italy annually relies on over 10,000 migrant workers from India for the harvest season.

Migrant workers are reportedly not given adequate protective equipment or tools (e.g. no raincoats, scissors or boots) required to safely work on kiwi farms, and fear reprisal or deportation for raising concerns about their working conditions. The Italian agriculture sector continues to face allegations of poor health and safety standards, with labourers working over 12 hours continuously with no breaks and being subject to poor living conditions and sanitation. The lack of adequate facilities is already having fatal consequences, such as fires and illness, for vulnerable migrant workers. Employers monopolise these workers’ limited understanding of Italian to exploit them and prevent their ability to know and access their rights as agricultural workers in Italy.

The exploitation of migrant workers in the agriculture sector is not isolated to Italy, a recent report uncovered the labour exploitation of

What can your organisation do?

• Provide written contracts, worker policies and training in languages accessible to migrant workers. This will support migrant workers’ knowledge of their rights and accessibility to the worker standards in the region they are working in and are entitled to.
• Engage with suppliers in the agriculture sector to ensure that they are providing adequate living conditions for migrant workers employed during harvest seasons, this includes access to clean water and electricity.
• Require suppliers to have a health and safety management system in place on farms, including monitoring systems regularly assessing the effectiveness of their control measures.

LEGISLATIVE CHANGES IN IRELAND’S FISHING INDUSTRY DECREASES MIGRANT EXPLOITATION

Starting in January 2023, Ireland has begun granting new Stamp 4 immigration permits to migrant fishers to reduce risks of labour exploitation and improve migrant worker rights. This positive legislative move indicates the start of necessary changes needed in the fishing sector to overcome the exploitation risks.

Since 2015, Ireland’s Atypical Worker Scheme (AWS) facilitated the recruitment of non-European Economic Area (EEA) workers into the fishing workforce. However, this scheme exacerbated migrant worker vulnerability to exploitation due to certain AWS conditions such as visas being tied to specific employers and placing large amounts of power in the hands of fishing vessel owners.

Between 2015-2022, 75% of fishing vessels with AWS workers had adverse findings against them. Reports have shown AWS workers experiencing exploitative conditions including non-payment of wages, not being given allowances, and inadequate rest time. International scrutiny has since been directed towards the AWS; including in the United States’ Trafficking in Persons (TIP) 2021 Report. Subsequently, Ireland reviewed the AWS and has decided to grant current holders of the scheme Stamp 4 immigration permits, meaning non-EEA workers will have the same rights as EEA counterparts, and the ability to apply for their families to migrate to Ireland.

While the new scheme does not mitigate all human rights risks in the fishing sector, with current undocumented fishers still at risk, it does however indicate the steps being taken to ensure the protection of the migrant workforce in Ireland’s fishing community. The introduction of this permit has enabled non-EEA migrant fishers who want to remain working in fishing to have an “incontestable right to earn an equal amount to their European crewmates” thus supporting their right to fair treatment and full rights under employment legislation.

What can your organisation do?

• Advocate for enhanced visa schemes in high-risk sectors for exploitation, to protect and ensure that migrant worker rights are granted in line with non-migrant workers. For example, the Seasonal Worker programme in the UK.
• Establish clear and effective grievance mechanisms, with special consideration for migrant worker accessibility.

OUTSOURCING WORK AND OUTSOURCING RESPONSIBILITY: HOW BRANDS DISTANCE THEMSELVES FROM CHILD LABOUR VIOLATIONS

Despite claims of a zero tolerance for child labour, many global brands distance themselves from their responsibility of incidences of exploitation in their supply chain. As of 2023, 12 million children remain in exploitative conditions, highlighting the need for brand accountability in value chains high risk sectors such as agriculture.

With child labour mainly occurring upstream in the value chain, where there is the extensive use of subcontracting, companies are both physically and fiscally distanced from the harm being done. Hence accountability is often passed to those with less power and leverage such as local farmers, despite the UN Guiding Principles for Business and Human Rights outlining how business responsibility extends throughout the entire supply chain.

There is, however, good practice emerging on how to take effective action, specifically initiatives which tackle both immediate and systemic issues at local levels. An example of this is the Farmer Field School approach that aims to improve agricultural productivity by providing training to adults which enhance their skills and increase their income. As a result, this approach reduces the need for child workers and improves the family’s ability to pay school fees. Whilst not run by a business, this type of programme can be easily replicated in high-risk sourcing areas and achieved through a partnership with a trusted local organisation.

The key to effective prevention is to identify risks and then engage meaningfully with affected communities to address immediate harm, such as unsafe working practices and systemic issues, including the fair payment of wages.

What can your organisation do?

• Calculate whether the price being paid for a product allows for a living wage to be paid at every layer of the supply chain. If the price is too low, the impact will be felt most by the workers at the raw materials stage of supply chains and could increase the need for child labour.
• Conduct detailed supply chain risk mapping to understand where child labour risks might be based on country of origin and the raw materials being sourced using ETI guidance for support.
• Engage with impacted communities, regardless of an incident occurring, across your supply chain, and produce remediation plans alongside them to ensure cultural relevance and sensitivity.

PROTECTING AND RESPECTING FREEDOM OF ASSOCIATION

Freedom of association is a core human right and is one of the main ways in which workers, through official trade unions or other worker organisations, can push for change. However, with these representative groups considered unlawful in many countries, how can companies ensure workers’ voices are heard and respected?

According to the 2023 ITUC Global Rights Index, 77% of the 149 countries analysed excluded workers from the right to establish or join a trade union, an increase from 59% in 2019. The inability to join trade unions inhibits workers from being able to organise and collectively bargain to improve conditions such as pay and working hours, and ultimately protect themselves from exploitative practices. This concerning trend includes key sourcing countries with already generally poor worker rights record, such as China, Turkey and Ecuador.

In practice, this results in individuals being punished for attempting to exercise their rights. Most recently, in Honduras, 4 union leaders were murdered during initial conversations with a major apparel brand looking to close down a factory; and in Argentina, teachers protesting low wages were arrested.

Despite this context, businesses remain responsible to promote freedom of association. Solutions must be found which are fitting to local contexts and for workers who may have limited trust in their employers. For example, in China, the ETI established a representative committee for women workers within a factory in China. Women were then trained on the purpose of the group and to learn about the safe space it created to raise concerns. Despite the hostile climate towards these committees in China, the pilot was a success.

What can your organisation do?

• Do not interfere with employees choosing to join or form a trade union of their choosing and ensure the right to do so is made clear in employee contracts.
• Support suppliers to respect freedom of association within the limits of national law such as assistance with allowing workers to express their concerns and collectively bargain in different formats.
• Join local organisations to collectively lobby government to change restrictive laws and bring legislation in conformity with ILO guidance. If you want to learn more about freedom of association, please visit the ILO.