Tackling labour exploitation – an update on Operation EMPOWER 

Ronnie Megaughin, Head of Compliance and Inspections, Security Industry Authority  

In August this year Paul Fullwood, the SIA Director of Inspections & Enforcement, published an article on our response to labour exploitation in the private security industry. This is an update on our operational response to the issue, which we are calling Operation EMPOWER.

The issues that Paul highlighted in his article are most prevalent in extended supply chains involving sub-contracting labour provision to service contracts.

EMPOWER, which has been running for about four months, combines a number of approaches. These include an intensive media campaign, primarily on social media platforms, and an operational response driven by a dedicated team of SIA Compliance and Inspections (C&I) Investigators working closely with partners in HM Revenue & Customs (HMRC) and Home Office Immigration Enforcement (HOIE).

We have raised around 150 investigation cases under the EMPOWER criteria. These relate to tax evasion through bogus self-employment, failure to pay National Insurance, breaches of National Minimum Wage legislation, and abuse of student and skilled worker visas.

Whist some cases are relatively straightforward and can result in a referral to HMRC Fraud Investigation Service, others are far more complex and will require time to work through and gather evidence. One such investigation resulted in Operation JACKFRUIT. This was a UK-wide day of action, led by SIA C&I and Criminal Enforcement investigators in partnership with HMRC and HOIE teams.

The main themes which JACKFRUIT aimed to address were NMW breaches, benefit fraud, abuse of visas, and bogus self-employment. We visited 35 separate sites, with two business inspections included in the plan. HOIE arrested one individual for visa abuse (working on a skilled worker visa in front line security). HOIE have the power to apply significant fines on the offending business in such circumstances. We and our partners are progressing other lines of investigation as a result of the information we obtained on the day.

We adapted our approach to inspections at summer festivals and events this year to include engagement with operatives to establish their employment status and who they were employed by. That work identified 283 individual cases with concerns about employment status. HMRC will follow those up with a view to addressing the companies responsible for their deployment.

We launched our social media campaign on 27 August 2024, using a newly-designed campaign identity based on our brand. Since then we’ve shared more than 50 posts across Twitter (X), LinkedIn and Facebook. We have written messaging to target four specific audiences: general licence-holders, businesses, buyers of security, and potential victims of labour exploitation. Our messages have been seen more than 100,000 times, with a good deal of positive engagement.

A significant challenge we face is the use of closed WhatsApp groups to recruit and arrange deployment of security operatives. At one time many of these groups would post hourly rates well below National Minimum Wage. However, the actions of well-intentioned members of the security industry, who sought to expose them on social media platforms, have driven their activities further underground. Many will now only offer an hourly rate over the telephone. Intelligence indicates that some groups are being operated entirely in foreign languages to further frustrate any attempts to infiltrate them.

Anecdotal evidence and feedback from all our public engagement indicates overwhelming support for our work under Operation EMPOWER. We are under no illusion that there is a quick fix. However there is no doubt that more robust contract management and greater due diligence in supply chains by the larger companies in the private security industry could have a significant positive impact.

We will continue to work under Operation EMPOWER, in partnership with all interested parties, to reduce the harm.

Author: Security Industry Authority (SIA UK) Blog

The Security Industry Authority (SIA) is the organisation responsible for regulating the private security industry in the UK. This blog aims to give a deeper insight into the Private Security Industry within the UK.

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