Focus on Labour Exploitation (FLEX) is piloting a worker-informed human rights due diligence framework for service sector supply chains. This project will utilise meaningful worker-engagement methods to ensure that workers are at the front and centre in identifying risks and developing solutions to the issues that affect them. This will contribute to the efforts to prevent labour abuse and exploitation amongst outsourced workers in high-risk sectors.

Together with the Latin American Women’s Rights Service (LAWRS), we will be working directly with outsourced service staff to design a more sustainable and robust framework for ensuring responsible business conduct. The project also aims to address the business models and power imbalances which have previously limited corporate social responsibility initiatives’ effectiveness.

What is Human Rights Due Diligence?

Human rights due diligence is the process companies carry out to identify, prevent, mitigate and account for how they address actual and potential impacts in their operations and supply chains. This process is currently voluntary, however, conversations on creating binding due diligence obligations for companies are gaining traction in the UK and abroad. While FLEX continues to advocate for robust legislation on corporate accountability, our approach is intended to act as a complementary partner to regulation by demonstrating what can be achieved in practice, and not as a replacement for it.

Our Approach

The project draws on FLEX’s research into labour rights issues related to migrant and ethnic minority workers in high-risk sectors, meaningful worker engagement, and emerging models such as Worker-driven Social Responsibility (WSR). FLEX will be looking at risks in the context of the cleaning sector, where there is a high risk of labour rights abuses, and examining the gendered dynamics at play.

The decision to focus on the procurement of cleaning services was based on numerous factors. Some of these considerations include the fact that:

1. The cleaning sector is characterised by endemic levels of labour abuse and exploitation, such as sexual harassment, dangerous working conditions, and issues with pay.
2. The sharp rise in outsourcing services has caused a consistent downward pressure on wages and conditions for cleaners.
3. It is an example of a high-risk service sector in the UK where vulnerable groups of workers, including migrant and ethnic minority women, are disproportionately represented.
4. Current legislation and enforcement do not respond to increased risk and labour abuses faced by outsourced workers in supply chains.

The project’s due diligence framework will assess potential and actual impacts of private sector procurement on working conditions. It will address the ways in which company policies and purchasing practices drive exploitation and will ultimately make recommendations for prioritised actions to address, mitigate and/or remediate identified impacts. FLEX will also create initial guidance for implementing recommendations and monitoring the impact on labour conditions.

Bridging the Gap

This project can be seen as part of FLEX’s efforts to develop and strengthen ethical corporate responses and seeks to bridge the gap between research and practice. The cleaning sector provides a useful illustration of the issues faced by outsourced workers generally and the broader dynamics of the employment model. Further, it offers an opportunity to include workers’ experiences in our research as well as companies’ processes. As such, the findings and learnings will be relevant to other service sectors increasingly marked by outsourcing practices.

In piloting our approach, we hope to contribute to existing research on the importance of meaningful worker engagement in the human rights due diligence process, and provide insights on how it can be done in practice. We believe that workers should be at the centre of this process. To achieve this, workers must be recognised as experts able to contribute workable policies and processes for responsible business conduct.

For more information on this project, contact [email protected].