Modern slavery and the financial industry

Modern slavery is the severe exploitation of people for personal or commercial gain. Ultimately, it is an economic crime and the financial industry has a key role to play in prevention and support.

Modern slavery and the financial industry

Key learnings

  • Gain insight into the nature and scale of modern slavery.
  • Recognise the vital role of the financial industry.
  • Understand how to identify and report suspected modern slavery cases.

What is modern slavery?

Put simply, modern slavery is the severe exploitation of people for personal or commercial gain. Below, we have outlined the most prominent types of modern slavery. However, modern slavery is an umbrella term. Given the complexity of the crime, many cases cannot be neatly categorised and will overlap across multiple forms of exploitation.

Victims of modern slavery may not be physically trapped in shackles and chains but their traffickers are still able to manipulate and control them. It is fear and desperation which keep people trapped in slavery today. This may include debt bondage, fear of deportation or threats to their family.

Someone is in slavery if they are:

  • Forced to work – through coercion, or mental or physical threat
  • Owned or controlled by an ’employer’ – through mental or physical abuse or the threat of abuse
  • Dehumanised – treated as a commodity or bought and sold as ‘property’
  • Physically constrained or have restrictions placed on their freedom of movement.

Definitions and terminology

For the purpose of the Survivor Financial Empowerment Hub, the umbrella term “modern slavery” has been adopted due to its use in the international arena. In the U.K. and Australia, the term “modern slavery” is defined in law, closely aligning with definitions of severe forms of human trafficking in U.S. law and trafficking in persons in international law.

As defined within the International Labour Organisation Forced Labour Convention, we refer to modern slavery as “situations of exploitation that a person cannot refuse or leave because of threats, violence, coercion, deception, and/or abuse of power.”

Today’s statistics

Today, more than 50 million people are estimated to be living in modern slavery, with victims of all nationalities, ages and genders. Across the U.K. and the U.S., the Global Slavery Index estimates that 136,000 people and 403,000 people are trapped in modern slavery respectively. However, the latest global figures are likely a conservative estimate. Recent events such as the COVID-19 pandemic, the Russian invasion of Ukraine and climate change are destabilising already fragile communities and fuelling economic migration and human trafficking.

Modern slavery is impacting more people than at any other time in history, yet it is an issue that exists in the shadows. According to our research, 45% of financial industry senior managers do not believe modern slavery exists in the U.K.

A U.S. perspective on survivor financial empowerment

In this spotlight interview, we spoke to Sara Crowe, Strategic Initiatives Director at Polaris, on modern slavery and survivor financial empowerment from a U.S. perspective.

The survivors

As a result of exploitation, survivors of modern slavery experience severe and long-term health, social and economic consequences. The financial industry has an important role to play in supporting survivors to recover and regain independence, reducing the risk of re-exploitation.

“Whether operating through formal bank branches, micro loans or digital finance, the financial sector has unique global reach to impact people’s lives. It can be a powerful force for good.”

James Kofi Annan and Timea Nagy Payne,
Survivors and Liechtenstein Initiative Commissioners

The financial industry’s role

Modern slavery is an economic crime. Money is the primary driving force behind every case of exploitation, with modern slavery and human trafficking generating $150 billion in profits annually. Vulnerability to exploitation increases when potential victims lack financial stability or access to financial services. As highlighted by the FAST Blueprint and the Themis “An Agenda for Action”, The financial industry has a crucial role to play in both the prevention of modern slavery and the protection of survivors.

Below, is a report by The Economist, exploring how banks can be used to stop human trafficking.

An Agenda for Action

In January 2021, TRIBE Freedom Foundation published a joint report in partnership with Dame Sara Thornton, former UK Independent Anti-Slavery Commissioner, and Themis Think Tank. Following 18 months of collaborative research and outreach, the report highlighted the role of the financial sector in helping to prevent modern slavery. The conclusions were clear; the financial sector is critical in preventing and disrupting modern slavery globally.

Many institutions questioned whether they had any links to modern slavery and human trafficking, highlighting a clear need for senior engagement, employee training, policy review and a greater understanding of the issue. The report and the associated training provide an Agenda for Action for employees across the financial industry.

“This report clearly demonstrates how financial institutions should be at the heart of this global effort…I hope that it serves as both a wake-up call and a useful guide providing information, insight and encouragement to those who lead financial institutions…I commend it to you.”

Dame Sara Thornton DBE QPM,
Former UK Independent Anti-Slavery Commissioner

Survivor bank accounts

As for the role of retail banks in supporting survivors, this starts with enabling survivors to open a bank account. In the U.K. alone, an estimated 136,000 people are living in modern slavery, with tens of thousands referred to the National Referral Mechanism (NRM), the U.K.’s identification and support system for potential victims of modern slavery, each year. A total of 12,727 potential victims of modern slavery were referred to the NRM in 2021, representing a 20% increase compared to 2020 (10,601.) During their recovery, most survivors will require support to rebuild their financial stability, including opening a new bank account to help reclaim their freedom and independence.

FAST Survivor Inclusion Initiative

Developed as part of the FAST Blueprint, the FAST Survivor Inclusion Initiative is the first global framework to promote financial access to survivors of human trafficking and modern slavery. The initiative brings together banks and survivor support organisations in the U.K., Canada and the U.S. to assist survivors’ reintegration into mainstream financial services by providing access to simple current accounts (and basic banking services) at some of the world’s largest banks. To date, SII participating financial institutions have opened accounts for approximately 2,000 survivors by survivor support organisation referrals across the U.K., U.S. and Canada.

See a list of participating organisations here.

FAST provides template resources and referral processes to streamline and simplify survivor account opening for banks and SSOs. This enables financial institutions to verify a survivor’s identity and satisfy traditional Know Your Customer (KYC) standards, helping to overcome the challenges faced by survivors who may have no official identity documents. They also provide training resources, basic financial literacy tools and periodic opportunities for peer learning.

Learn more about the FAST Survivor Inclusion Initiative and contact the team for an introductory consultation via their website.

Spotlight video: Modern slavery and the financial industry

In this spotlight interview, we spoke with Dame Sara Thornton, DBE QPM, former U.K. Independent Anti-Slavery Commissioner, about the crucial role of the financial industry in preventing modern slavery and supporting survivors.

Learn to spot and read the signs

There are several indicators of trafficking and forced labour. Not all of the indicators will apply in every case, and some may not be apparent at all. By learning to spot key indicators and understanding more about the nature of exploitation, you can help to report and disrupt modern slavery.

General indicators of modern slavery

  • Behaviour: withdrawn, scared, not willing to talk.
  • Appearance: unkempt, malnourished, few possessions, health concerns.
  • Work: inappropriate clothing for the job, long hours, little or no pay.
  • Fear of authorities: doesn’t want to speak to police or authorities.
  • Debt bondage: in debt to or dependent on someone else.
  • Accommodation: overcrowded, poorly maintained, controlled by an employer.
  • Lack of control: no ID, no access to a bank account, work transport provided.
  • Lack of freedom: unable to move freely, unwilling or scared to leave.
  • Children: alone, not related to an adult carer, inappropriate behaviour or clothing.

For a more detailed overview of the potential signs and indicators of modern slavery, follow this link.

Beyond the general indicators

The Polaris Campaign, “It’s not knowing the signs, it’s knowing the story“, helps to address cases where there are no visible indicators of modern slavery, where victims are hidden in plain sight. The campaign encourages individuals to look beyond the general indicators of modern slavery and pay attention to the “context” and “proximity” of people that they know or interact with.

Reporting modern slavery

If you are in the U.K. and suspect modern slavery or would like advice regarding issues around modern slavery, call the UK Modern Slavery & Exploitation Helpline on 08000 121 700.

If you are in the U.S. and suspect modern slavery or would like advice regarding issues around modern slavery, call the US National Human Trafficking Hotline on 1-888-373-7888.

If you are in Canada and suspect modern slavery or would like advice regarding issues around modern slavery, call the Canadian Human Trafficking Hotline on 1-833-900-1010.

Identifying illicit financial flows

When looking to detect and disrupt modern slavery, there are a variety of client behaviours or issues that should act as a warning that further investigation is necessary. These are known as red flags. Numerous red flag tools and methods have been developed, and efforts have been made to compile and continuously update these red flags. However, modern slavery is a continuously evolving crime and traffickers must stay ahead of the financial industry to avoid detection so it is important to take a dynamic approach.

The RedFlag Accelerator provides a unique repository of enhanced and decoded Red Flags and modern slavery indicators. This helps to accelerate the search for traces of modern slavery and human trafficking within financial institutions and can be adapted to the relevant business and national context. Banks and financial institutions can sign up for the RedFlag Accelerator via their website.

In addition, the Organisation for Security and Co-operation in Europe (OSCE) developed “Following the Money.” This resource provides financial institutions with a comprehensive step-by-step guide for anti-trafficking response systems to coordinate financial investigations. This resource contributes more broadly to the objectives outlined within the FAST Blueprint and the UN Sustainable Development Goals.

Summary: Important guidance

  1. Educate and train all bank staff on the nature of modern slavery and how to identify and report suspicious activity.
  2. Raise awareness of clear pathways to report potential modern slavery indicators across all internal teams.
  3. Notify CEOs and senior management so that they are fully aware of their commitments towards all applicable Modern Slavery and Supply Chain Transparency laws and are motivated to advance their impact against modern slavery each year.
  4. Facilitate access to bank accounts and ongoing support services to survivors of modern slavery as per the guidance in the Survivor Financial Empowerment Hub.
  5. Designate clear responsibility for survivor financial empowerment and embed tangible targets to help monitor and record progress.
  6. Adopt a holistic approach towards survivor financial empowerment by supporting wider survivor needs and recognising the multiple factors which drive long-term financial independence.

Where to next?

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Engaging with survivors to understand the challenge

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