Modern Slavery in Your Supply Chain: Why Box-Ticking Won't Protect Your Third Parties (or Their Victims)

Mike Day • 14 September 2026

Third Party Therapy Podcast — featuring Shayne Tyler, supply chain modern slavery expert

Modern slavery rarely makes the same headlines as a cyber breach or a data leak, yet its human cost is far greater — and, as this episode of Third Party Therapy makes clear, it is far closer to the corporate world than most third party risk management (TPRM) professionals assume.

Host Mike Day sat down with Shayne Tyler, a supply chain modern slavery expert with over 20 years of first-hand experience tackling worker exploitation. Shayne's involvement in this space began in the most direct way possible: as an operations manager whose own factory was exposed on the BBC's Panorama in 2000 for the illegal employment of more than 200 staff. That experience — engaging afterwards with the victims themselves — set the course for the rest of his career.

What Modern Slavery Actually Is

Shayne's central message is that "modern slavery" is a broad umbrella covering forced labour, organ harvesting, forced criminality and prostitution, but that in the corporate world, forced labour driven by human trafficking dominates. Crucially, he stresses that human trafficking does not require crossing a border: moving someone from one field, or one office, to another for the purpose of exploitation is enough.

He breaks trafficking down into three legal components that must all be present:

• Action — the transportation, harbouring or receipt of a person

• Means — control and power exercised over them

• Purpose — for financial gain

Without all three, it is a different crime entirely — smuggling, or extortion. That distinction is part of why modern slavery is so notoriously difficult to prosecute: the "chains" are usually psychological, built through debt, fear, pride or hope rather than physical restraint.

The UK Is Not Immune — and Neither Is Finance

A common assumption in TPRM circles is that modern slavery is confined to agriculture, food production or other manual, low-skill sectors overseas. Shayne dismantles this. Citing Pew Research Centre estimates of 800,000 to 1.2 million people in the UK without the right to live and work — roughly one in fifty people — he argues that any organisation interacting with more than fifty people is statistically likely to encounter someone in that position.

He points to worker substitution (the person who turns up to do the job is not the person who was vetted) as a pervasive and largely unpoliced gap, and highlights how visa routes — Tier 2 skilled worker sponsorship, the Tier 5 seasonal worker scheme, EU Settled Status, and student visas — all carry their own distinct exploitation risks, from debt bondage arranged in the worker's home country to fee-payment scams tied to fraudulent immigration paperwork.

For financial services specifically, Shayne draws a direct parallel to anti-money laundering controls: a pattern such as a victim's bank account being emptied every Friday night at a cash point is exactly the kind of anomaly that existing AML infrastructure could be adapted to flag — if TPRM, fraud and financial crime teams collaborated on it.

Why Policies Don't Stop Exploiters — Processes Do

Perhaps the sharpest insight in the episode: in 24 years of this work, Shayne says he has "not met an exploiter yet that has cared one iota about a company's policy." Exploiters study and infiltrate processes, not statements. His own audits have generated close to 30 critical non-compliances in a single afternoon by testing a labour provider's systems with deliberately falsified information — precisely the same technique an exploiter would use.

This is a direct challenge to the "modern slavery statement" as a compliance artefact. As he puts it, no statement has ever prevented a victim.

The Four Ps: A Practical Due Diligence Framework

Rather than defaulting to a checklist, Shayne recommends corporates adopt a four-stage approach:

1. Pursue — assume exploitation is present in your supply chain and actively look for it, rather than assuming the absence of evidence means the absence of a problem.

2. Prevent — use what you find to close gaps for the next case, even if you can't undo the last one.

3. Prepare — share learnings across your business, supply chain and even competitors, and train staff to recognise the signs.

4. Protect — not only the victim, but the brand, the business, the systems and the staff. Protecting everyone matters, because "there is no point in being the most ethical business on the planet if you're out of business."

Look for the Absence of Normal, Not the Presence of Abnormal

One of the episode's most striking reframes: conventional guidance tells people to look for visible signs of exploitation (houses of multiple occupancy, signs of abuse, isolation). But if a sign is visible, Shayne argues, exploiters already know to hide it. The more reliable indicator is the absence of normal — the person who never mentions weekend plans, who never has an ordinary conversation about ordinary life.

And when a potential victim is identified, the instinct to escalate immediately can be dangerous. Shayne recounts a case in which acting too fast caused 53 people connected to a single victim to disappear. His guidance: de-escalate, gather information quietly, and hand a complete picture to the authorities rather than attempting to investigate or "rescue" directly.

The Takeaway for TPRM Teams

This conversation is a reminder that third party risk management's toolkit — due diligence, escalation, ongoing monitoring — has direct relevance to one of the most serious human rights issues in modern business, but only if it moves beyond box-ticking. Real progress means testing processes the way an exploiter would, watching for the absence of the ordinary, and building cross-functional collaboration between TPRM, procurement, HR and financial crime teams.

As Shayne puts it, using a health and safety analogy: don't jump straight to the high-vis vest. Eliminate the risk first, substitute it, segregate it, administrate it — and only then rely on the last line of defence.

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