Understanding modern slavery risks in agency staffing

Care providers have a legal, regulatory and moral duty to minimise modern slavery risks in their supply chain. This covers everything from the food you buy to the workforce who deliver care every day.

Agency staffing is a particular area of exposure, especially with the huge increase in skilled worker visas during and after Covid. Most providers will rely on agencies at some point, so understanding the risks is essential.

While we have found that most agencies do things properly, there are a small number that unfortunately do not. Hiding behind a legal contract is not enough. If something feels off, you have an obligation to act. Turning a blind eye is not ok.

If someone is a victim of modern slavery they may be scared, unaware of their rights and protections and worried about their family. They are unlikely to talk openly. But care providers can still play a crucial role in spotting red flags when agency workers are in their homes.

Below is a list of ten simple questions you can consider asking agency workers. These are gentle, everyday questions that can be asked casually during a shift. You are not grilling them and you should avoid making them feel nervous or watched. The aim is to spot anything that does not sit right and to build a culture where concerns are taken seriously.

Ten questions to help you spot potential red flags

1. How long have you been working with your agency?

   Very new workers with vague or rehearsed answers may indicate that someone else arranged their employment for them.

2. Do you choose your own shifts or does someone else pick them for you?

   Victims are often told where to go with no choice, sometimes by a third party who is not the official employer.

3. Are you happy with how and when you get paid?

   Listen for confusion about pay, unexplained deductions or wages being paid into someone else’s bank account.

4. Who do you live with locally?

   You are not prying. You are checking whether multiple unrelated workers are living in overcrowded or controlled accommodation.

5. How do you normally get to work?

   Workers who are always dropped off and collected by the same person, or who travel in groups controlled by someone else, may be under coercion.

6. Has your agency explained your rights to you, such as pay, holidays and notice periods?

   Victims often have no understanding of their rights and have never been told the basics.

7. Do you feel comfortable contacting your agency directly if you have a concern?

   If they are told everything must go through someone else, that is a warning sign.

8. Has anyone ever kept your passport or important documents for you?

   No legitimate employer holds passports. If someone else keeps it safe, treat it as a serious concern.

9. Do you ever have to pay anyone’s fees for finding you work or arranging your visa?

   Ongoing fees, debts or deductions are common in exploitation and forced labour situations.

10. Are you planning on staying with your agency long term or looking at other options?

    Victims often believe they cannot leave and will say things like I am not allowed or I have no choice.

What to do if something feels wrong

You are not expected to be a detective, but you do have a duty to act. If an answer feels off, make a note of it and speak to your designated safeguarding lead or manager. Do not raise concerns directly with the agency if you think the agency itself may be involved. In those cases, contact your local safeguarding team or the police for advice before taking any further steps.

The key message is simple. Agency workers are part of your supply chain and you cannot completely outsource responsibility for their wellbeing. A few gentle questions and a bit of curiosity can make a real difference. If something does not feel right, do not ignore it.

To add an extra layer of protection, you can also use a specialist neutral vendor like Florence’ Agency Manager offering. A neutral vendor carries out detailed compliance checks, ongoing audits and continuous monitoring of agency standards. This strengthens your due diligence and reduces the risk of unsafe or unethical suppliers entering your home in the first place.