Stakeholders’ responsibility to mitigate modern slavery risk for cleaners

Responsibilities of cleaning service providers

(E.g. cleaning contractors that directly employ cleaners.)

  • Ensure bids for contracts are sufficient to meet the full cost of the service.
  • Do not employ forced labour or trafficked persons. 
  • Ensure employment systems, policies and procedures are implemented to promote compliance with labour laws.
  • Establish genuine worker grievance mechanisms. Monitor their use and effectiveness.
  • Uphold principles of non-discrimination and equal opportunity. 
  • Do not discourage or restrict freedom of association and collective bargaining. 
  • Educate employees about their labour rights. 
  • Train managers and supervisors on industry-specific modern slavery risk factors.  
  • Engage openly with worker representatives (e.g. CAF Representatives, union delegates, union officials).  
Please note: this stakeholder category is for cleaning contractors that directly employ cleaners.

IMPORTANT: CAF Modern Slavery Guidance usage statement: This Guidance is intended for use by CAF Members only. Any unauthorised use, reproduction or distribution of the Guidance will be considered a breach of CAF Membership Terms & Conditions and may result in termination of CAF Membership. Reproduction or use of parts of the Guidance in CAF Members’ own material and statements is permitted however must be attributed to CAF and referenced accordingly. CAF highly recommends Members consult with CAF staff prior to publishing any CAF-related material to ensure accuracy.

Responsibilities of procurers of cleaning services

(E.g. building owners, building managers, corporate or government tenants that directly procure cleaning services, and cleaning contractors that subcontract core cleaning services.)

  • Ensure the contract price is sufficient to meet the full cost of the service.
  • Take commercially reasonable efforts to make sure the third parties who engage workers are reputable, legitimate enterprises and have appropriate management systems that will minimise the risk of forced labour or employment of trafficked persons. 
  • Use commercially reasonable efforts to incorporate these requirements in contracts with third-party employers. 
  • Establish policies and procedures for managing and monitoring the performance of such third-party employers on labour issues. 
  • Include oversight of contractor compliance within KPIs.
  • Ensure that contracted workers have access to a genuine grievance mechanism; monitor its use and effectiveness. 
  • If forced labour cases are reported, take steps to investigate and remedy them. 
  • Where modern slavery risks are identified, engage with the supply chain to implement corrective action and proactive measures to address the risks.
  • Where remedy is not possible, shift the primary supply chain over time to reduce the risk of forced labour.  

Responsibilities of indirect procurers of cleaning services

(E.g. investors in property, and tenants that indirectly procure cleaning services through their lease.)

  • Undertake a risk assessment to identify where there are high risks of forced labour in the primary supply chain. 
  • Engage with the entity through which cleaning services are procured (e.g. landlord if you are a tenant; owner of asset(s) you are invested in) to ensure that cleaning services are being responsibly procured, managed and delivered.
  • If forced labour cases are reported or identified, take steps to ensure they are investigated and remedied. 
  • Ensure that supply chain workers have access to a genuine grievance mechanism; monitor its use and effectiveness. 
  • Monitor the primary supply chain to identify significant changes in risks. 
  • Where modern slavery risks are identified, engage with the supply chain to implement corrective action and proactive measures to address the risks.  
  • Where remedy is not possible, shift the primary supply chain over time to reduce the risk of forced labour.