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Module 1
 

The human cost: a UK site visit

 

 

Introduction

Modern slavery is a global crisis affecting an estimated 50 million people. It hides in plain sight – on construction sites, in warehouses, in cleaning services, and in complex sub-contracting chains.

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In this module, you'll step into the shoes of a supplier manager visiting a live construction site in Leeds. Through a series of realistic scenarios, you'll learn how to identify potential signs of modern slavery and make ethical decisions that protect vulnerable workers.

The UK construction industry has been identified as a high-risk sector for labour exploitation, particularly through complex subcontracting chains and third-party labour agencies. In recent years, investigations have uncovered cases where workers were underpaid, lacked proper documentation, or were charged illegal recruitment fees – practices that can amount to modern slavery.

This interactive experience is designed to help you:

  • Recognise red flags in UK-based supply chains.
  • Understand how exploitation can be hidden in plain sight.
  • Practice making responsible choices that align with Lloyds Banking Group’s commitment to ethical sourcing.

Every decision you make in this module reflects real-world challenges – and has real-world consequences. Let’s begin.

Setting the scene

You’re a Supplier Manager visiting a key construction project.

You’re here to check on progress, but also to ensure suppliers and subcontractors are meeting their ethical obligations.

1. First impressions

On entering the site, you notice some workers don’t have visible ID or branded uniforms. One avoids eye contact and doesn’t speak English. What do you do? 

You should ask the site supervisor if everyone on site has provided CSCS (Construction Skills Certification Scheme) cards, which is a certification that proves a worker has the necessary training and qualifications to work safely on a construction site.

Unidentified or undocumented workers who don’t have CSCS cards or may be using a fake card are a key red flag for labour exploitation.

2. Tight deadlines

You bump into the site manager looking stressed. He says delays are pushing them to hire from a third-party labour agency he’s used before. Should you be concerned?

Yes, you should ask to understand more about the agency’s approach to responsible recruitment and due diligence processes.

Labour providers must be vetted, and knowing how workers are recruited helps to ensure fair wages and working conditions.

Fast hiring leads to a lack of transparency in recruitment practices and heightens the risk of workers facing exploitation, especially if the agency isn’t monitoring working hours, wages or health and safety.

3. Workers' break area

In the break room at lunchtime, one of the other workers appears fatigued and doesn’t join the others. You overhear someone mention paying fees to come and work here. What should you do?

You should raise your concern with the site manager if you feel comfortable, or report it through an appropriate speak-up or reporting channel.

Escalating concerns is critical. The mention of workers paying fees to secure employment is a significant red flag and may indicate debt bondage, a form of modern slavery prohibited under international law. Workers in these situations may be vulnerable and unable to leave their employment freely. 

By raising concerns promptly and following the correct reporting routes, you help ensure that potential risks are investigated and that vulnerable individuals are protected.

Reflect and learn

Every decision you make has an impact on real people. Ethical sourcing is not just a process to follow, it's about protecting individuals who may be vulnerable or unable to speak up for themselves.

In this scenario, the signs of modern slavery were not immediately obvious and could be easy to overlook in day-to-day interactions. However, these signals can point to more serious risks. Modern slavery can exist in plain sight, particularly in complex supply chains where visibility is limited.

Small actions, whether you choose to question, investigate, or escalate a concern, can make a meaningful difference. 

How did you do? 

In this module, you explored how modern slavery risks can appear in real-world supply chain scenarios.

You saw that:

  • modern slavery can exist in plain sight, even in UK-based operations
  • small signals, such as missing identification or recruitment fees, can indicate more serious risks
  • asking questions and taking action when something does not feel right is an important part of responsible business practice.

As a supplier, you play a key role in identifying and addressing these risks within your own organisation and across your supply chain. Being aware and taking action when needed helps protect individuals and supports more ethical supply chains.

In the next module, build your knowledge of the Modern Slavery Act and the requirements of a modern slavery statement. 

 

Move on to module 2


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