A collaboration led by the Better Hiring Institute has published guidance that addresses “key enablers” of worker exploitation and sets out how the UK government, HR departments and the forthcoming Fair Work Agency can act to address these enablers and thereby prevent worker exploitation. We analyse the guidance and what employers can do to minimise the risk of exploitation in their workplace.
In the 10 years since the introduction of the Modern Slavery Act 2015, reports and cases of modern slavery have increased. The number of worker abuses reported to JobsAware, a non-profit organisation that works with partners across government and the police, has increased 41% year on year since 2021. The quarter from July to September 2025 saw 6,414 referrals of victims of modern slavery via the Home Office’s national referral mechanism, the highest number of referrals since it began in 2009.
The guidance centres around the core enablers of worker exploitation in the UK and sets out practical steps that businesses and the government can take to address them:
- abuse of the immigration system, such as tying work visas to a single employer or charging illegal recruitment fees;
- fragmented labour rights enforcement – there are various government agencies that enforce employment rights, which creates complexity and confusion for workers and leads to unchallenged violations;
- exploitative recruitment practices, including false job advertising or holding workers’ passports;
- economic circumstances, with workers living in poverty being particularly vulnerable to exploitation; and
- workers’ lack of awareness of their rights – for example, growth in non-traditional working models adds complexity which workers will not necessarily be aware of.
There are several government initiatives underway aimed at addressing some of these issues, as the guidance acknowledges:
- A white paper that focuses on restoring control over the UK immigration system outlines measures that tackle worker exploitation. It aims to strengthen employer accountability through mandatory sponsorship requirements and compliance checks to ensure fair treatment of migrant workers.
- In 2024, the government funded a scheme to match displaced migrant care workers with new, suitable work through an alternative visa sponsor.
- The Employment Rights Bill (the Bill) will introduce a range of reforms to increase workers’ rights and tackle worker exploitation. The Bill, if passed in its current form, will introduce
day-one employment rights, including protection from unfair dismissal and access to parental and bereavement leave, with a view to reducing vulnerability of workers in the early stages of employment. It also seeks to ban zero-hours contracts and significantly restrict “fire and rehire” practices. The Bill will also establish the Fair Work Agency (FWA). The FWA will operate as one point of contact for workers and consolidate enforcement functions. The guidance recommends that the FWA adopts a strategic approach and leverages a strong partner network with organisations that can complement regulatory enforcement. The FWA can also use its fraud powers to tackle exploitation involving fraud, such as misleading job ads and unlawful salary deductions.
The guidance recommends that the government considers civil penalties if employers breach the rights of workers on sponsorship visas (and provides support for those workers to find alternative work) and considers job scams as a key driver of fraud under the government’s new fraud strategy.
It also makes recommendations that employers and their HR teams:
- ensure ethical recruitment practices, avoiding illegal fees, misleading job adverts and discriminatory hiring;
- promote transparency in employment terms;
- support workers’ access to information;
- provide training on modern slavery, particularly what to look out for and how to report it;
- encourage supply chain compliance; and
- make use of the Better Hiring Institute toolkits (such as its guide to International Recruitment for best practice in managing overseas worker recruitment).
This guidance signals a renewed emphasis for employers on ethical recruitment, transparency and proactive HR involvement in tackling worker exploitation. As the Fair Work Agency and the Bill progress, employers should take the opportunity to review their recruitment, onboarding and compliance frameworks. Conducting a gap analysis against the guidance and existing modern slavery and right-to-work controls will help identify areas where improvements can be made. HR and in-house legal teams may also wish to engage with supply chain partners to ensure consistent standards of worker protection. Embedding these principles will help organisations demonstrate compliance, protect vulnerable workers and mitigate reputational and legal risk.
