Modern Slave Trade

Two Polish brothers have been jailed for six years under the Modern Slavery Act 2015 for trafficking 18 vulnerable men from Poland to work in a Sports Direct warehouse in the UK. The Nottingham Crown Court found the Markowski brothers subjected the 18 men to poor working conditions, which included body searches and pay well below the legal minimum wage. The Markowski brothers opened bank accounts on their behalf, confiscated their passports, effectively depriving them of their freedom.

The Markowski brothers were convicted under the Modern Slavery Act 2015 of conspiracy to arrange or facilitate travel with a view to exploitation. They were also convicted for conspiracy to commit fraud by false representation, an offence under the Fraud Act.

This case comes exactly a year after the first conviction of a UK-based business owner for a human tracking offence. Mohammed Rafiq, owner of Kozee Sleep, was convicted of conspiracy to traffic by Leeds Crown Court. This case serves as an important reminder that modern slavery issues occur closer to home than we might expect.

From a business perspective, this case also emphasises the need for effective supply chain monitoring. For example, the employment agency, Transline Group, which supplied temporary workers to Sports Direct in this case, is also linked to some of the UK’s best-known brands – from amazon to Argos. Companies will need to carefully review existing policies and procedures to ensure there is both an ethical trading and an ethical supply chain statement.

The Modern Slavery Act 2015 places an obligation on certain businesses with a UK presence to prepare an Anti-Slavery and Human Trafficking Statement. Any commercial organisation which supplies goods or services, and has a total turnover of £36 million or more, is required to prepare and communicate such a statement.  Many large businesses are now publishing these on their websites. Failure to prepare and share such a Statement could result in court action to force compliance and/or an unquantified fine.

Dominic Bonham