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Modern Slavery in the Waste Industry

Modern Slavery is defined by the IPHR as an “umbrella term which encompasses the acts of slavery, servitude, forced or compulsory labour as well as human trafficking.”

Waste and recycling has long been a complex industry with intricate supply chains, multiple service providers and jobs that attract ‘low skilled’, temporary workers. Due to the nature of the industry, it is vulnerable to the infiltration of organised crime groups who profit off modern slavery and forced labour.

Modern Slavery is defined by the IPHR as an “umbrella term which encompasses the acts of slavery, servitude, forced or compulsory labour as well as human trafficking.”

It is estimated that there are currently 40.3 million people worldwide trapped in the modern slavery system, a sharp increase since 2012.

Why is modern slavery so common in waste and recycling? 

 In 2017, Hope for Justice reported that two thirds of the people who fell victim to modern slavery had been placed in waste management facilities; there is said to be over 100,000 people trapped in modern slavery in the UK; Hope for Justices’ report shows the scale of the problem within the industry. 

Due to the complexities of the waste management and recycling industry, there are many different entry points that traffickers can exploit and with the industries low retention rate of staff and large amounts of temporary workers it is easy for traffickers to move their victims around, going unnoticed by employers. The undesirability of these temporary, ‘low skilled’ roles furthers the risk of exploitation as employers are in need of workers. 

These roles are attractive to those who speak limited English, lack qualifications, are vulnerable to financial issues, lack of support and need work. Modern slavery victims are often within this demographic, giving organised crime groups the opportunity to trap victims into forced labour and place them in waste management networks. 

Recycling specialist at Clarity Environmental and expert member of the IPHR Modern Slavery HR toolkit working group, Megan Scott commented: 


The UK waste and recycling sector, by nature, is an industry highly susceptible to modern slavery. It is crucial that there is robust training and policy making across the entire supply chain to prevent this type of abuse. Modern slavery presents a huge risk to people's lives and the industry at large.

How is Clarity combatting modern slavery in the industry?  

In 2021 Clarity developed the industry’s first quality assurance programme in acknowledgement of the positive change needed in the industry and in support of the Environment Agencies overhaul. 

Clarity’s Recycling Evidence Quality Standard (CREQS) is a process which provides additional assurance to our scheme members when purchasing PRNs as well as driving for positive change to protect the environment and improve people’s lives. 

CREQS follows a three- step process which evaluates the risks associated with a reprocessor and ensures that business is being conducted with values that reflect our own. Following the three-step process, reprocessors are graded and the best scoring businesses are marked as select suppliers whilst the remaining are not recommended for an immediate relationship.  

In stage 2 and 3 of the CREQS process our specialists will evaluate the modern slavery policies of the repressor, fair work policies, safeguarding practices and look for any indicators on site that may suggest any forced labour or exploitation.  

Clarity Environmental are also a part of the IPHR Forum’s working group for modern slavery in the waste and recycling industry, helping to develop the official HR toolkit for industry professionals to use to combat modern slavery and spot the signs of exploitation.  

Megan went on to say, “developing CREQS has allowed us to only work with suppliers of recycling evidence who are fully compliant with environmental legislation and whose business values align with those of Clarity.”  


To find out more about CREQS, visit here 

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