Modern day slavery: Could letting agents be complicit?

NCA wallThe National Crime Agency (NCA) this week reported that there are currently more than 300 police operations live tackling modern day slavery, suggesting that the problem is much more wide spread than previously though.

In fact the Agency went so far as to state that its previous estimate of 10,000-13,000 victims in the UK is likely to represent only the ‘tip of the iceberg’.

Trafficking is apparently so widespread that individuals and companies may well be encountering operations and victims every day.

In particular the NCA highlighted sectors such as care workers, agriculture, food processing and construction as potential areas of concentration – in addition to traditional target businesses such as car washes and food service.

What has this got to do with letting agents?

On the most basic level, everyone needs somewhere to live and traffickers have been known to source private rented property for this purpose. Likewise some of the criminal enterprises most commonly linked with traffickers and modern slavery are far too often fun from privately rented premises.

Police forces around the country regularly urge letting agents to look out for ‘signs’ of modern slavery. As far back as 2015 Thames Valley Policy suggested agents ask themselves a series of simple questions before agreeing a let, in order to help identify potential victims and criminal gangs:

  • Do you know exactly who you are renting your property to and who is residing in the premises?
  • Is the occupant the same person who completed the tenancy agreement?
  • Does the occupant pay for their own tenancy, from their own bank account?
  • Are you aware of any anti-social complaints relating to the property?
  • Do the occupants of the property change on a regular basis?
  • Is the occupant in possession of their own passport and identification documents, and have these been checked for authenticity prior to the start of the tenancy?
  • Does the occupant appear withdrawn, frightened or show signs of physical abuse?

Obviously the right-to-rent checks carried out by all landlords and letting agents in England will reduce the risk of unknowingly assisting traffickers, but it is important to remain vigilant.

Responsible businesses

Large companies, those with annual turnover in excess of £36 million,  are required to publish a statement outlining their policies and practices in respect of slavery and human trafficking. This is unlikely to be a useful exercise for most small to medium firms, but there are some practical steps that smaller companies could consider – based on this regulatory approach.

For instance:

  • Provide training and guidance to staff on the topic
  • Establish a system of supply chain verification to ensure that contractors do facilitate modern day slavery, either actively or passively.
  • Review existing suppliers and contractors. Letting agents frequently employ cleaning and maintenance contractors, which operate in sectors considered high risk by the NCA.

Above all any letting agent who suspects they may have encountered a case of modern day slavery should report it. This can be done using the dedicated helpline on: 0800 0121 700 or online at: https://www.modernslaveryhelpline.org/report

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