5 Questions FM Managers should be asking

Fun fact – legally, the only policies a company (below £36m) is required to produce are terms and conditions of employment and a Health and Safety Policy if you employ five or more people.

Health and Safety requires more documents – risk assessments, method statements, COSHH data, RIDDOR.  Document driven but rooted in habit, they’re usually markers for what we do anyway.

Modern slavery compliance is often treated as a documentation exercise. Policies are drafted, statements published and supplier declarations are filed.  But exploitation, doesn’t appear through paperwork. It shows up operationally. Paying attention to detail and asking simple questions is a highly effective control method in combating exploitation

FM managers should begin with a simple question: who employs the people working on this site? Is it the company who won the contract or has it been subbed? Layered subcontracting masks oversight. Be clear about the labour chain.

Second, how is pay compliance verified? NMW compliance cannot be assumed. Payslip sampling and reconciliation between attendance and payroll provide more assurance than policies can.

Third, can workers raise concerns safely? Have a clear and safe line of communication and make sure that it’s known to everyone.

Fourth, how do we identify unauthorised labour substitution?  ID checks and unannounced audits are practical controls that reduce risk.

Finally, what would exploitation look like? Excessive hours, shared accommodation, or reluctance to speak independently are indicators but there are intuitive signs which may or may not have foundation. We do no harm in exploring the fearful worker, the signs of injury and fatigue.

Callum MacLeod, MD, Stamp Out Slavery