Confronting Modern Slavery in Construction's Supply Chain

The construction industry is increasingly facing scrutiny over its supply chain practices, particularly when it comes to modern slavery.

Low profit margins and pressing deadlines are pushing many companies to overlook ESG due diligence, leading to significant risks, including forced labour.

The introduction of the Operational Toolkit: Combatting Slavery in the Built Environment by the Supply Chain Sustainability School (SCSS) shines a spotlight on this issue and raises the urgent question: how bad is modern slavery in the construction sector?

The toolkit, developed by Action Sustainability, aims to help businesses identify and mitigate the risks of modern slavery within their supply chains.

It is a practical guide that encourages collaboration between clients, contractors and suppliers to build stronger, more ethical practices in construction. But just how widespread is the problem?

Risk factors in construction supply chains

The construction industry is uniquely vulnerable to modern slavery for several reasons.

Labour shortages and a lack of skilled workers often drive companies to rely on temporary or migrant labour, agency staff and subcontractors. This reliance can make it easier for exploitation to slip through the cracks.

Many construction projects, especially large-scale ones, involve complex supply chains that are often opaque, making it harder to track labour conditions.

According to the SCSS, "Low profit margins and tight deadlines can lead to businesses overlooking standard recruitment protocols, increasing the risk of forced labour slipping into the supply chain."

This is a particular concern in the built environment, where labour exploitation is not just a theoretical risk but an everyday challenge.

The industry's supply chains are frequently international and the use of migrant workers, especially in low-skilled roles, can create fertile ground for exploitation.

Migrant workers are often unfamiliar with their rights, making them more vulnerable to being taken advantage of by unscrupulous employers or labour agencies.

This dynamic is exacerbated by the use of multiple subcontractors, which can obscure accountability. Each layer of subcontracting increases the risk of labour exploitation, as companies further down the chain are less likely to be subject to the rigorous scrutiny applied to principal contractors.

In response to these challenges, Action Sustainability, working with partners from SCSS’s Built Environment Against Slavery Group, developed the toolkit to offer guidance on how to reduce these risks.

The toolkit offers step-by-step instructions for identifying potential "red flags" in the recruitment process, site management and daily operations.

Practical steps for businesses

Anna Slatcher, Senior Sustainability Manager at Barratt Redrow, highlights how the toolkit is already benefiting her company: "This guidance will be a valuable resource for us and our industry partners to improve our understanding of, and mitigate, labour risks on our sites."

The toolkit offers several practical recommendations, ranging from recruitment practices to site management and focuses on empowering construction teams to be vigilant against modern slavery. By equipping site managers and teams with the necessary knowledge, the toolkit aims to embed modern slavery due diligence into the core of daily construction operations.

This approach ensures that identifying and addressing risks becomes a routine part of site setup and management rather than an afterthought.

As Jo Potts, Sustainability Director at Balfour Beatty, points out: “Operating responsibly and with integrity whilst upholding the highest ethical standards is critical to success – it must be at the heart of how the construction and infrastructure industry conducts business.”

To help achieve this, the toolkit consolidates site-specific insights and strategies that construction companies can use to tackle modern slavery. It draws on examples from across the industry, giving organisations actionable steps to ensure their supply chains are ethical.

Emma-Jane Allen, Senior Consultant at Action Sustainability and the toolkit's author, explains, "It's essential to embed modern slavery due diligence into 'business as usual' site setup and management.

"This toolkit empowers those on the front lines of site management to prevent, identify, manage and mitigate risks of labour exploitation."

The way forward for ethical construction practices

The toolkit highlights six key risk areas in the construction supply chain where modern slavery and exploitation are most likely to occur. These include gaps in recruitment processes, ambiguous labour contracts, unregulated subcontracting and inadequate worker protections.

To address these risks, businesses are urged to take a more hands-on approach to monitoring labour practices, not just in their own operations but also throughout their supply chains.

By integrating modern slavery due diligence into everyday practices, construction companies can significantly reduce the risk of labour exploitation. This proactive stance will also protect companies from potential reputational damage, legal risks and financial penalties.

However, addressing modern slavery is not just a matter of compliance - it’s about upholding basic human rights and ensuring that everyone involved in construction projects is treated with dignity.

As Anna puts it: “It illustrates the practical steps that can be taken in recruitment, site setup and management to identify 'red flags' that may otherwise be missed and to empower our teams to ensure a working environment for everyone that is exploitation-free.”

With tools like the Operational Toolkit: Combatting Slavery in the Built Environment, the construction industry has the opportunity to turn the tide against labour exploitation.

However, success depends on a collective effort; businesses must commit to rigorous due diligence, transparency and a culture that prioritises ethical practices at every level of the supply chain.

Check out the latest edition of Supply Chain Digital and sign up to our global conference series – Procurement and Supply Chain LIVE 2025. 

Supply Chain Digital is a BizClik brand.