Guidelines for businesses to avoid hidden forced labour

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The Danish Centre against Human Trafficking has developed  ‘Avoid Hidden Forced Labour – Guidelines for businesses and employers’. The guidelines are an awareness and risk management tool developed in dialogue with relevant actors.

The guidelines include, among others, checklists and tools which can help a business with the following:
1. To investigate if the business is at risk of human trafficking for forced labour in its supply chain.
2. To prevent and reduce the risk of forced labour in the business and supply chain.



The guidelines include checklists, which detail a range of recommendations companies can implement to reduce the risk of hidden forced labour. The lists may be regarded as general recommendations for actions to reduce the risk of forced labour. The extent to which the individual items are relevant will largely depend upon the size of the company and sector in question.

Checklist A: The list concerns general company practice regarding trafficking for forced labour.

Checklist B: The list concerns the recruitment and the management of employees.

Checklist C: The list concerns the use of (sub)contractors.

Why introduce guidelines?

In recent years several Danish business sectors have faced a number of new challenges in connection with the use of foreign labour and supply chains. This has resulted in cases regarding poor working conditions and, in worst incidents, trafficking for forced labour. Industries where many unskilled and relatively low-wage foreigners are employed are particularly at risk, such as cleaning, agriculture and horticulture, construction, transportation and distribution as well as hotels and restaurants. In these sectors it can be difficult for companies to have full overview of working conditions for all employees, especially if subcontractors are used or if work is performed in remote areas or at odd hours. As a consequence, companies may risk being unintentionally associated with human trafficking for forced labour.

The International Labour Organization (ILO) estimates that in 2016 almost 16 million people globally were victims of forced labour in the private sector. In Denmark 86 persons were identified as victims of trafficking for forced labour during the period 2007-2018.

Human Trafficking for forced labour

You will find definitions of human trafficking and forced labour in the Danish Penal Code section 262 a and the ILO Convention 29.

In practice a person will often be misled and deceived into accepting working conditions which subsequently prove to be different to and worse than originally promised. As the person did not know the real working conditions she or he cannot be said to have offered him or herself voluntarily. When the person wants to leave this job, she or he is exposed to threats or violence if the job is not done. This can, for example, consist of direct physical threats, threats against his or her family or threats of not receiving wages already earned, etc. These are all conditions which force the person into continuing an employment relation and a situation of exploitation, which she or he would otherwise have left.

The guidelines elaborate on the definition of forced labour and describe important international obligations and guidelines in the field.