Defining Modern Slavery

Slavery is any system in which principles of property law are applied to people, allowing individuals to own, buy and sell other individuals.

Victims are trafficked all over the world for little or no money – including to and within the UK.

The term ‘Modern Slavery’ captures an entire range of types of exploitation, many of which occur together. These include but are not limited to:

• Sexual exploitation: this includes sexual abuse, forced prostitution and the abuse of children to produce child abuse images/videos.
• Domestic servitude: this involves victims being forced to work in usually private households, performing domestic chores and childcare duties.
• Forced labour: this can happen in various industries, including construction, manufacturing, laying driveways, hospitality, food packaging, agriculture, maritime and beauty (nail bars).
• Criminal exploitation: This can be understood as the exploitation of a person to commit a crime, such as pick-pocketing, shoplifting, cannabis cultivation, drug trafficking (including ‘County Lines’) and other similar activities that are subject to penalties and imply financial gain for the trafficker.
• Human trafficking: this requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult.
• Other forms of exploitation: organ removal; forced begging; forced benefit fraud; forced marriage and illegal adoption.

In 2024, the National Crime Agency recorded 563 potential victims of trafficking in Wales, a small increase from 559 in 2023

There is no typical victim, and some do not understand they have been exploited and that they are entitled to help and support.

Victims are often trafficked to a foreign country where they are unable to speak the language, have their travel and identity documents removed and are told if they try to escape, they or their families will be harmed.

Locally and across the United Kingdom, Criminal Exploitation generally, and ‘county lines’ drug trafficking in particular, has become a prominent way in which people, particularly children, are increasingly exploited. ‘County lines’ is the practice of trafficking drugs into rural areas and smaller towns and cities, away from the major conurbations. Many factors contribute to the way in which vulnerable children and other individuals are exploited by traffickers, and it is a key factor that a child can never consent to their own exploitation.

An improvement in the number of referrals of potential victims of trafficking into the National Referral Mechanism (NRM) has been achieved in Cardiff due to the increased awareness training that has been provided to practitioners.

The Council is fully aware of its designation as a ‘First Responder’ organisation under the National Referral Mechanism (NRM) and its responsibility to identify potential victims and refer cases to the UK Human Trafficking Centre Competent Authority of the National Referral Mechanism.

In 2024, 38 NRM referrals were made by Council staff who also assisted in many other referrals through close partnership working with other agencies including the police.

Legislation

Recent years have seen a marked and significant shift in anti-slavery supply chain legislation worldwide, with a stronger focus on stricter reporting requirements and global accountability. International businesses now face a complex landscape, juggling diverse regulations and ensuring compliance across the entire supply chain.

Navigating this landscape requires an understanding of obligations, implementing the correct reporting procedures, and strengthening approaches to mitigate the risk of modern slavery.

Crucially, new legislation demands all organisations looking beyond their direct suppliers. It extends responsibility to lower tiers in our supply chain, often spanning the globe, although we recognise our approach must remain proportionate. Even as a UK-based public body where our suppliers are mostly domestic, their tier 1 sourcing might extend beyond the UK, subjecting Cardiff Council to these regulations through indirect connections.

We remain cognisant of anti-slavery legislation and other directives recently introduced by the European Union through the Corporate Sustainability Reporting Directive (CSRD) and from other countries including France, Germany, Netherlands, Norway, Japan, Canada, Australia and the USA.

Even though the UK is not part of the EU (European Union), the EU Corporate Sustainability Reporting Directive (CSRD) (2022/2464) will impact on some UK incorporated companies. The CSRD, which entered into force in January 2023, sets out additional disclosures for companies to include in their annual report in relation to sustainability matters.

On 12 December 2024, the new EU regulation prohibiting products made with forced labour from being sold on the Union market (the “Forced Labour Regulation”) was introduced, impacting businesses that sell any products into or from the EU from the end of 2027.

Supply Chains - Due Diligence

Supply Chains are critical to the delivery of goods and services essential to the work of Cardiff Council (and the Ardal collaboration) and the Cardiff Local Authority was one of the first in Wales to sign up to the Welsh Government’s Ethical Employment in Supply Chains Code of Practice, which was launched in 2017.

The Council spends around £750m each year procuring a diverse range of goods, services and works from over 8,000 suppliers and contractors, whilst the Ardal procurement partnership with Local Authorities in Monmouthshire, Torfaen and Vale of Glamorgan managed by Cardiff Council, accounts for a collective annual spend of more than £1.2 billion

The Modern Slavery Act 2015 recommends that public procurement processes are strengthened to ensure non-compliant companies are not eligible for public contracts, so it is therefore increasingly important that we work with the right supply chains and understand the detail of first, second and third tier suppliers, to provide us with the confidence that the necessary obligations are passed on to sub-contractors.

Through the tendering process, the Council ensures that our direct suppliers are aware of our commitment to tackle modern slavery and human trafficking and that they also understand their obligations as a supplier or contractor of the Council.

The Council undertakes due diligence when considering taking on new suppliers and will seek to review its existing suppliers on an annual basis through its contract management arrangements.