Here we look at labour exploitation in the car wash industry and the headline trends for this sector including victim profiles, location, how they are recruited and transported to the UK.
Victims are predominantly male between the ages of 18-35 years. Vulnerable victims are targeted, mainly irregular migrants and those who are unable to communicate in English.
Romanian nationals are most frequently reported, followed by Albanian and Bulgarian nationals.
Intelligence is focused around Yorkshire, the East Midlands and North-West regions. This may be a result of multi-agency visits in these areas.
There is very little reporting of car washes in Wales, the West Midlands and the South-West.
Where methods of recruitment are reported friends and family, social media and internet adverts are used. There are also reports of individuals being approached by the exploiter and offered work.
Some car washes are believed to have links to organised crime including drugs and human trafficking.
Transport to the UK
Where recruitment takes place overseas this is often arranged by the exploiter and reported methods are bus and aeroplane.
There are limited reports of irregular migrants and asylum seekers being transported by lorry.
It is common practice for exploiters to provide accommodation, usually a shared house. There are reports of workers residing at their place of work. Accommodation is often reported to be substandard and/or overcrowded.
Victims of exploitation in this sector are unlikely to be paid the National Minimum Wage. Car washes offer competitive prices but employ many workers; on average around five but it can be as many as 40 in some larger businesses.
Withheld wages are also reported.
Health and safety issues are a concern, often lack of PPE. There are also reports of excessive working hours and debt bondage.
The sector has been the focus of several campaigns to increase reporting and improve knowledge about exploitation. These include the Responsible Car Wash Scheme and the Safe Car Wash App.
Lockdown may have dispersed the workforce into other sectors which may have an impact on worker demographics.
Consumer demand is likely to increase and therefore additional workers will be required.
There is some scope for the licensing of hand car washes, although this is likely to be on voluntary basis in the short term at least.
Key questions to prevent and identify labour exploitation
• Are audits to establish any indicators of modern slavery and labour exploitation regularly conducted?
• Do recruitment processes include questions to identify whether a person may have been trafficked, paid work finding fees, or was otherwise exploited whilst seeking employment?
• Do you have any additional due diligence checks for workers at risk of being exploited? Including access to translation services?
• How do you ensure workers know about their employment rights, and where to report complaints or issues?
• Do members of your organisation receive training on spotting the signs of modern slavery and labour exploitation?
• Do you have an internal escalation process if you identify an issue of exploitation? Do you know who to contact?
What to consider when reporting intelligence
Example: A group of Eastern Europeans are working at a car wash in London. Workers do not look happy and seem exhausted. Rest and toilet facilities were inadequate. The workers did not have PPE or proper equipment. The car wash seemed suspiciously cheap.
What else should you consider when reporting what you have seen?
- Provide more details about the workers involved – do you know what language they speak?
- Do any appear to be minors?
- Male or female?
- What hours do they work?
- How are workers arriving, are there vehicle details?
- How much are workers paid and how are they paid?
- How does recruitment occur?
- Who is the car wash owned or run by?
- Is there evidence of workers living or sleeping onsite?
Whilst not all factors may be known, any additional details will assist the GLAA in identifying people and locations involved for operational purposes and to improve our intelligence picture.
More information about the Responsible Car Wash Scheme is available at: https://www.gla.gov.uk/whats-new/press-release-archive/22102018-responsible-car-wash-scheme/
GLAA resources are available including a useful Spotting the Signs leaflet
Who to Contact
Please report to the GLAA:
• Unlicensed trading in the regulated sector (agriculture, horticulture, shellfish gathering and any associated processing and packaging) across the UK.
• Labour market offences (non-payment of the National Minimum Wage, breach of Employment Agency Standards) in the regulated sector in England and Wales
• Individuals, labour users or labour providers who are suspected of modern slavery and human trafficking in any labour industry (excluding sexual exploitation), or individuals who are potential victims of such activity in England and Wales.
Please report to partners:
• Issues of National Minimum Wage only, in sectors that are not GLAA regulated to the HMRC NMW team (https://www.gov.uk/government/organisations/hm-revenue-customs/contact/national-minimum-wage-enquiries-and-complaints)
• Health and safety issues only (all sectors) to the Health and Safety Executive (http://www.hse.gov.uk/contact/concerns.htm)
• Workplace relations and employment law issues (including contract issues, discrimination and grievances) to the Advisory, Conciliation and Arbitration Service (ACAS) (https://www.acas.org.uk/index.aspx?articleid=1410)
• When there is an immediate threat to life contact the police emergency number.
• To report labour exploitation, human trafficking or modern slavery outside of the regulated sectors in Northern Ireland or Scotland, contact the local police service.