Sky Guidance for IPCs on Modern Slavery

Sky guidance on addressing modern slavery risks in production

This guidance document is designed to assist producers with understanding and addressing risks of slavery and human trafficking in their organisation and supply chain and to put in place good practices.

Examples of ways in which it can manifest

  • Debt bondage – when a person is forced to work to pay off a loan, often at high rates of interest for an indeterminate length of time
  • Wage abuse – when wages are withheld from workers (e.g. through compulsory savings schemes that are then used to ‘cover costs’ or unexpected deductions)
  • Recruitment fraud – when a person is recruited expecting a certain salary and working conditions only to find afterwards that the salary is much lower and/or the working conditions are not as expected but the person is at that point unable to leave
  • Removal of identity documents and travel papers – when a person is recruited from overseas and then has their passport or other ID documents retained so that they are not able to leave 
  • Compulsory overtime – when a person is forced to work long hours for no additional pay and risk a penalty if they refuse 
  • Child slavery – when children are forced to work for example in agriculture, factories, construction, mines, bars, restaurants or tourist environments; or in domestic servitude where they may suffer abuse 
  • Forced prison labour – when prisoners are required to work involuntarily for little or no pay 
  • Sexual exploitation – when people are forced to perform non-consensual or abusive sexual acts against their will for others to profit, e.g. prostitution escort work and pornography.

What do we expect?

Sky expects you to comply with the Modern Slavery Act 2015 where this applies to your organisation. We also ask that you are alert to the risks, that you check the practices of your suppliers and subcontractors and that, where possible, you put in place actions to mitigate the risks of modern slavery in your operations and those of your supply chains.

Key questions to answer are ‘where within my operations and supply chains might there be one or more risk factors present?’ and ‘what can I do to mitigate the risks identified?’

Sky has outlined risk factors, recommended good practices and details of how to find out more information below:

Risk factors

People end up in slavery for a range of different reasons. However, there are inherent vulnerabilities that put some groups at higher risk than others. There are four main areas of risk to consider*:

*Risk factors adapted from Verité's materials on forced labour and human trafficking 

Recommended good practices

  • A policy that includes an explicit reference to slavery and trafficking (it doesn’t need to be a separate policy, but could be an amended existing policy)
  • A requirement that this policy commitment is also actively communicated to your suppliers (not just available on a website) 
  • Additional checks and a focus on recruitment agencies 
  • A review of the risk factors related to slavery and an assessment of which workers might fit into the vulnerability categories 
  • A set of mitigations that target the risks identified – e.g. using subcontractors that have permanent rather than temporary workforces; sourcing equipment from suppliers with shorter supply chains and good practices of their own in place 
  • A plan to review higher risk areas in more depth 
  • A way of making workers (both employees and those subcontracted to work) aware of their rights and of potential issues related to slavery and trafficking 
  • A way for workers (both employees and those subcontracted to work) to raise concerns about themselves or their colleagues that is anonymous, protects them from reprisal, is well known about and is trusted. This could be an external helpline. 
  • A response plan should an issue be found

Where to go for further information/resources