Let’s say there is a man in rural Indonesia who sells his family’s motorbike. He sells a small patch of land, too. Everything he can scrape together goes toward a single promise: a job picking strawberries in England. Lovely.
The recruiter’s brochure looks incredible. Glossy polytunnels, fruit the size of your fist, and weekly wages that would take months to earn back home. He borrows the rest from relatives, signs the paperwork, and boards a flight to Heathrow. By the time he lands, he’s more than £3,000 in debt… and he hasn’t touched a single strawberry.
On the farm, reality hits pretty fast. The picking targets are brutal, the season is short, and rumours spread through the worker caravans about illegal fees, about people being sent home before they’ve earned enough to cover what they owe. Some of the workers talk about a British watchdog with a very long name that’s apparently “looking into it.”
Key Takeaways
- The UK’s Seasonal Worker Scheme leaves migrants thousands of pounds in debt before they begin work, trapping them in exploitative conditions.
- The Gangmasters and Labour Abuse Authority oversees roughly 520,000 workers with only 21 compliance inspectors and a shrinking budget.
- The Modern Slavery Act’s supply chain transparency requirements lack penalties, allowing major companies to file meaningless boilerplate statements.
- Tied visas prevent seasonal workers from changing employers, creating ‘hyper-precarity’ where debt and immigration status enforce compliance.
- Twenty years after the Morecambe Bay disaster prompted reform, exploitation persists through legal visa routes and licensed operators rather than solely criminal networks.
Others just shrug. The supermarket shelves still need filling. Get back to picking.
That story comes from Guardian reporting in 2024. But it isn’t a new one.
Two hundred miles north of those polytunnels, on the edge of Morecambe Bay, there’s a stone memorial. It marks the spot where at least 22 Chinese cockle pickers drowned on the night of February 5th, 2004. They’d been sent onto the sands in the dark by a “gangmaster” who cared more about profit than tide tables. Most of them couldn’t swim. Some barely spoke English. They made desperate phone calls as the water rose… and for most of them, those calls were the last thing they ever did.
Their deaths were supposed to change things. Parliament actually acted fast. A new licensing authority was created to regulate the gangmasters who supplied Britain’s farms, its packhouses, its shellfish beds. For a while, it looked like the system might actually work.
Twenty years on, yeah, it’s not working.
This is the story of Britain’s gangmaster scandal: how cheap food and disposable labour created a space where exploitation thrives, how the country tried to fix it after Morecambe Bay, and how, despite “world-leading” laws and a dedicated watchdog, modern slavery keeps finding its way onto your supermarket shelf.
Fields of Strawberries, Mountains of Debt
The “Seasonal Worker Visa” is, on paper, a pretty straightforward arrangement. The UK needs people to pick fruit, harvest vegetables, and process poultry during peak seasons, and there aren’t enough domestic workers willing to do it. So the government issues short-term visas—currently up to six months—that allow overseas workers to come to Britain and do exactly that. The visas are tied to specific operators, meaning licensed labour providers who act as middlemen between the worker and the farm.
Those operators are, in turn, overseen by a regulator called the Gangmasters and Labour Abuse Authority, or GLAA. Neat and tidy, right?
Now let’s talk about what it actually looks like in practice.
In 2024, the Guardian reported on a group of Indonesian workers who’d each paid upwards of £2,000 in official visa and travel costs just to get to England, with some allegedly paying an additional £1,100 or more in broker fees to middlemen back in Indonesia.
These were obviously not wealthy people. They’d sold livestock, borrowed from family, taken out informal loans at painful interest rates—all for a six-month picking job on a British farm that they believed would change their lives. By the time they landed, most were carrying debts equivalent to a year’s income or more, and every single penny of that financial risk sat on their shoulders.
Some were dismissed within five or six weeks. Not enough hours, not fast enough, season winding down early—the reasons varied, but the result was always the same. Workers who’d crossed the world and emptied their savings were sent home with less money than they’d started with, still owing debts they now had no way to repay.
And this wasn’t some underground operation. These farms supply major UK supermarkets. The labour came through licensed operators, companies that hold official GLAA licences and Home Office sponsorship to bring workers into the country. The GLAA launched an investigation into the Indonesian cases, focused on whether illegal recruitment fees had been charged overseas.
But that raises an obvious question: if the fees were charged in Indonesia, by Indonesian brokers, how much can a British regulator with no jurisdiction outside the UK actually do about it?
The pattern keeps repeating.
Workers from countries like Indonesia, Nepal, and Central Asia are recruited with glossy promises and real paperwork. They front-load enormous costs to secure the visa and the flight. Then they arrive into a system where their ability to stay in the country, to switch employers, to complain about conditions—is almost entirely controlled by the operator who brought them in.
So, if you’re £3,000 in debt, tied to a single employer by the terms of your visa, and terrified that raising a complaint will get you sent home with nothing… you don’t need to be locked in a room to feel trapped, do you?
The word “gangmaster” conjures a very specific image. Someone like Lin Liang Ren, the man behind the Morecambe Bay disaster—a criminal operator working outside the law, sending vulnerable people into dangerous conditions for profit. And that image isn’t wrong, but it’s also not quite complete.
The modern version of this story doesn’t always involve unlicensed criminals in the shadows. Sometimes it involves licensed companies, legal visa routes, and recruitment chains that stretch across multiple countries, with the worst abuses happening thousands of miles from the farm gate.
The workers still end up exploited. The difference is that it is all, somehow, legitimate.
Who and What Are “Gangmasters”?
Before we go any further, it’s worth stepping back and asking a basic question: what actually is a gangmaster?
The word sounds old-fashioned, almost Victorian, and in some ways it is.
A gangmaster is essentially a middleman—someone who recruits workers, transports them to a job site, and manages them on behalf of whatever farm, factory, or fishing operation needs the labour. Think of it as outsourced workforce management. The farmer doesn’t want to deal with hiring dozens of seasonal pickers, sorting out their housing, handling their payroll, and replacing the ones who leave. So they call a gangmaster, who shows up with a van full of workers ready to go.
The farmer gets their crop picked. The gangmaster takes a cut. And the workers get… well, whatever’s left.
They really need a rebrand.
For decades, the UK food system has run on this model. Strawberries, asparagus, cockles, chicken processing—all of it depends on large numbers of temporary workers appearing at exactly the right moment, working flat out for a few weeks or months, and then disappearing again until next season. It’s cheap, it’s flexible, and for a long time, it was almost completely unregulated. Anyone could set themselves up as a gangmaster.
There was no licence, no inspection regime, and no real consequences if you decided to pack 15 people into a two-bedroom house and skim half their wages. If you had a van and a phone, you were in business. Boom.
Morecambe Bay changed that—at least in theory.
We’ll come back to the disaster itself in a bit, but the political fallout was swift. Parliament passed the Gangmasters (Licensing) Act 2004, which created a brand new body called the Gangmasters Licensing Authority, or GLA. Its job was to issue licences to labour providers working in four specific sectors: agriculture, horticulture, shellfish gathering, and food processing and packaging.
If you wanted to supply workers in any of those areas, you now needed a licence, and the GLA could inspect your operations, check your books, and revoke that licence if you didn’t meet their standards.
So those four sectors. Agriculture, horticulture, shellfish, food processing. That’s it.
Construction? Not covered. Hospitality? Not covered. Car washes, nail bars, care homes? None of them.
The GLA had a very specific patch, and everything outside it was someone else’s problem—except it often wasn’t anyone’s problem. HMRC had a small team enforcing minimum wage rules, the Employment Agency Standards Inspectorate existed but was tiny, and none of these bodies talked to each other particularly well. A 2017 National Audit Office report would later describe the whole enforcement landscape as “fragmented and confusing,” which is a polite way of saying it wasn’t working properly at all.
In 2016, the GLA got an upgrade. Under the Immigration Act, it was rebranded as the Gangmasters and Labour Abuse Authority—the GLAA—with new police-style powers to investigate labour exploitation across the entire economy, not just those four original sectors.
Sounds like a big step forward, right? Well… giving an organisation a bigger job title doesn’t automatically give it a bigger budget or more staff. The GLAA inherited a remit that now covered virtually every low-wage sector in the country, while its resources stayed roughly the same. But we’ll get to that particular problem later.
The point for now is this: the UK built a licensing system for gangmasters after a national tragedy, and that system covered a specific slice of the economy while leaving the rest largely unwatched. The old-fashioned gangmaster with one van and a bag of cash still exists in some corners, but the modern labour supply chain is something else entirely—a network of licensed UK operators, overseas recruitment agents, visa sponsors, and subcontractors, all sitting between the worker in the field and the logo on the punnet.
And every link in that chain is a place where things can go wrong. And boy do things go wrong.
‘Death in a Cold, Strange Land’: Morecambe Bay
Now let’s talk about that disaster we mentioned a moment ago. On the evening of February 5th, 2004, a group of around 30 Chinese workers made their way onto the vast, flat sands of Morecambe Bay on the northwest coast of England. They were there to pick cockles—the small shellfish that sit just below the surface of the wet sand—and they were working in the dark because that’s when the tide was out and the cockle beds were exposed.
Most of them were undocumented migrants who’d come to the UK through a network of snakehead smugglers and informal labour brokers, owing thousands in debts for the journey. They didn’t know the area, they didn’t speak much English, and almost none of them could swim.
The man who sent them out there was a gangmaster called Lin Liang Ren. He controlled the workers’ housing, their transport, and their access to the cockle beds, taking a large cut of everything they earned and using debt and intimidation to keep them in line.
Local British cockle pickers had been working those same sands for years, and some of them had tried to warn the Chinese groups about the tides—Morecambe Bay has one of the fastest incoming tides in the country, and the sands are riddled with hidden channels and gullies that flood without warning. But the warnings either weren’t understood or weren’t passed on. Lin Liang Ren kept sending his crews out regardless. Money had to be made, damn the consequences.
That night, the tide came in faster than anyone on the sands expected. Water poured through the channels and across the flats, cutting the workers off from shore before most of them even realised what was happening. In the confusion and the darkness, some tried to wade back toward land, but the water was rising too quickly and the currents were too strong. Several workers made desperate phone calls as the water reached their chests—one man called his wife in China to say goodbye.
Another dialled 999 but struggled to explain where he was or what was happening. Emergency services launched a rescue, but Morecambe Bay is enormous, pitch black at night—it was not a success.
By the time it was over, at least 21 people were dead.
Their bodies were pulled from the water and the sand over the following days and weeks, some carried miles from where they’d been working. One body was never recovered. Fifteen workers survived, many of them clinging to each other in the dark until rescue boats arrived.
Lin Liang Ren was arrested, charged, and in March 2006 convicted of 21 counts of manslaughter along with immigration offences and facilitating illegal entry into the UK. He received a 14-year sentence, later reduced to 12 on appeal. His girlfriend and another associate were also convicted of lesser charges. During the trial, prosecutors painted a picture of a man who knew the risks, who’d been warned about the tides repeatedly, and who sent his workers onto the sands anyway because the income was too good to give up.
The disaster hit the national news hard, and not just because of the death toll. Trade unions, particularly the GMB and the T&G, had been warning for years about exploitative gangmasters in British agriculture and food gathering. They’d used the phrase “labour sharks” to describe the network of informal fixers and recruiters who supplied cheap, compliant workers to farmers and food processors with no oversight whatsoever. Morecambe Bay proved them right in the worst possible way.
Parliament moved quickly. The Gangmasters (Licensing) Act received Royal Assent in July 2004, just five months after the disaster, creating the GLA and establishing the licensing regime we talked about earlier. For the families of the 21 workers who drowned in the cold and the dark on those sands—it was too late. But the hope was that it wouldn’t be too late for everyone else.
Building the Watchdog: The GLA Years
So the GLA opened its doors in 2005 with a clear mandate: licence the gangmasters, inspect their operations, and shut down the ones who couldn’t meet basic standards. And to be fair, the early years were genuinely productive. The authority began processing licence applications from labour providers across its four sectors, and it quickly became clear just how many operators had been running with no oversight at all.
Some were legitimate businesses that simply needed to formalise their practices. Others were… not. The GLA revoked licences, issued enforcement notices, and worked with police on joint operations targeting the worst offenders. For the first time, there was a real consequence for running a dodgy labour outfit in the food sector, and the most blatant abuses—the kind that had led directly to Morecambe Bay—did start to decline.
Good news, right? Well… kinda.
The problem was that exploitation in the food industry didn’t just come in one flavour. The GLA was well-equipped to catch the obvious stuff: unlicensed operators, workers with no contracts, flagrant safety violations. But by the late 2000s and into the 2010s, researchers and unions were raising alarms about a different kind of abuse—one that was subtler, harder to spot, and almost impossible to prove without a site visit.
A detailed 2012 study on forced labour in the UK food industry laid out the mechanisms clearly. Workers were technically employed, technically paid, technically housed—but the details told a different story. Gangmasters were charging illegal “administration fees” that ate into wages before workers saw a penny. Housing was tied to the job, meaning if you complained about conditions or refused a shift, you lost your bed as well as your income.
Some workers described what researchers called “zero-wage” situations, where deductions for transport, accommodation, work equipment, and various invented charges left them with literally nothing at the end of the week. They were working full-time and going home with empty pockets.
Others were given far fewer hours than they’d been promised—which sounds less dramatic than overwork until you remember that these people had borrowed thousands to get to the UK and were now earning too little to service their debts but too scared to walk away.
But here’s what made the GLA’s job particularly difficult.
A lot of this fell into what researchers called the “continuum of exploitation.” At one end, you’ve got clear-cut slavery and trafficking—people held against their will, documents confiscated, physical violence. At the other end, you’ve got a slightly rubbish job with a grumpy boss. But in between? An enormous stretch of territory where workers are technically free to leave but practically can’t, where the coercion is financial and psychological rather than physical, and where the legal threshold for “forced labour” is genuinely hard to meet even when everyone involved knows something is deeply wrong. It’s just not black and white.
The GLA could inspect a farm, find workers in tied accommodation earning below minimum wage after deductions, and still struggle to build a case that would hold up in court—because the gangmaster had paperwork showing the workers “agreed” to the charges, and the workers themselves were too frightened of losing their jobs and their housing to speak up.
None of this meant the GLA was useless. It had made a real dent in the worst abuses, and its intelligence-gathering work was feeding into police operations that wouldn’t have happened otherwise. But the underlying pressures that created the demand for cheap, disposable labour hadn’t changed at all. Supermarkets were still squeezing suppliers on price. Farmers were still turning to gangmasters to keep costs down. And workers were still arriving with debts, limited English, and almost no knowledge of their rights.
The “Worst Gangmaster Ever”: Chicken Catchers
Right, so let’s talk about chicken catching. Because apparently that’s a thing.
It’s one of those jobs that most people don’t even know exists, but somebody has to do it. When hens in large poultry operations reach the end of their laying cycle, or when broilers hit the right weight, teams of catchers go into the sheds at night, grab the birds by hand, and load them into crates for transport. It’s physically intense—dark, dusty, loud, and incredibly fast-paced, with teams expected to process thousands of birds in a single shift. It’s also the kind of job that’s almost impossible to fill with local workers, which makes it perfect territory for a gangmaster.
Enter DJ Houghton Catching Services, a company based in Kent that supplied chicken-catching crews to farms across southern and eastern England. The farms they serviced supplied eggs to major brands. The catching crews themselves were mostly Lithuanian men, recruited from their home country with promises of steady work and decent pay in England.
What they actually got was something else entirely.
According to court findings and the GLA’s own investigation, workers were transported to farms in overcrowded vehicles and expected to work exhausting shifts, sometimes through the night. Rather than proper accommodation, some were sleeping in the vans between jobs. Wages were routinely below the national minimum wage, and the company imposed unlawful “employment fees” and deductions that ate into what little the workers earned.
If someone complained or underperformed, wages were withheld as punishment. And keeping the workforce in line fell partly to a Lithuanian enforcer—a fellow worker given authority over the others—who used threats and intimidation to make sure nobody stepped out of line or, more importantly, talked to anyone on the outside.
The GLA investigated DJ Houghton and, in 2014, revoked the company’s licence. The statement they issued is still pretty remarkable for an official regulator. They called it “the worst gangmaster ever.”
But losing the licence didn’t automatically mean justice for the workers. The criminal process was slow, the evidence was complex, and the men who’d actually lived through the abuse were scattered across the country and, in some cases, back in Lithuania.
It took years of civil litigation, led by the law firm Leigh Day on behalf of the workers, before the case reached the High Court. In April 2019, the court ruled that DJ Houghton Catching Services, its director Darrell Houghton, and company secretary Jackie Judge were all liable for serious contractual and statutory breaches, including systematic underpayment, unlawful fees, and the withholding of wages. Crucially, the court found Houghton and Judge personally liable—meaning they couldn’t hide behind the corporate structure.
And then there’s an additional layer that makes this case really stand out. The workers’ legal team also brought claims against the GLAA itself, alleging that the regulator had failed in its duties by not acting sooner on information it held about conditions at DJ Houghton.
To be clear, these claims are alleged regulatory failures, and at the time of recording their status remains unresolved. But yeah—victims of a gangmaster felt the need to sue not just the gangmaster but also the watchdog that was set up to protect them from gangmasters.
The company had been operating for years, supplying chicken catchers to farms that fed into household-name supermarket brands, while workers slept in vans and had their wages docked for daring to complain. Somewhere between the licence, the inspections, and the supply chain, something had gone badly wrong.
Operation Fort: Slavery at Industrial Scale
If DJ Houghton showed how bad a single gangmaster could get, Operation Fort showed how deep the problem could run—and how far into mainstream British business it could reach.
Between 2012 and 2017, a family-based Polish organised crime group operating out of the West Midlands trafficked and exploited hundreds of their own countrymen in what would eventually become the largest modern slavery prosecution in UK history. The operation was sophisticated, sustained, and deeply cynical.
The gang targeted vulnerable people back in Poland—specifically seeking out individuals who were homeless, struggling with addiction, recently released from prison, or simply desperate enough to believe promises of a better life in England. They offered £250 to £400 a week, plus food and accommodation. For someone sleeping rough in Warsaw or Kraków, that sounded like a lifeline.
What waited for them in the West Midlands was something very different.
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Victims were packed into overcrowded, squalid houses, sometimes ten or more to a property, with little heating, minimal furniture, and food that was often past its sell-by date. The gang controlled almost every aspect of their lives. Bank accounts were opened in victims’ names but managed by gang members. Wages were paid into those accounts and then systematically siphoned off.
Benefit claims were filed and collected by the network without the victims’ knowledge or consent. After all the skimming was done, many workers were left with as little as £20 per week from jobs that were paying full wages to the accounts the gang controlled. Some received even less.
Now, these weren’t workers in some off-the-books operation down a back alley. The gang placed their victims into legitimate jobs, through mainstream recruitment agencies, at recognisable businesses. Farms, food processing plants, recycling centres, parcel warehouses—the kind of workplaces that sit right in the middle of ordinary British supply chains. The workers had real employment contracts and real National Insurance numbers. Everything looked perfectly normal. The exploitation happened around the edges of the formal employment system—in the housing, the bank accounts, the benefit claims, and the constant psychological control that kept victims too confused and frightened to seek help.
West Midlands Police estimated that the network had around 400 potential victims over the five-year period, though 92 were formally identified during the investigation, ranging in age from 17 to their 60s. The gang’s estimated profit was more than £2 million. In July 2019, eight members of the network were convicted under the Modern Slavery Act and given substantial prison sentences, along with Slavery and Trafficking Prevention Orders designed to restrict their activities after release.
The Independent Anti-Slavery Commissioner’s review of Operation Fort, published in June 2020, was blunt. The victims had been placed into first-tier supply chain roles—meaning they were working directly for companies that supplied major brands, not buried three or four layers deep in some opaque subcontracting arrangement. The recruitment agencies that placed them hadn’t spotted the signs, or hadn’t looked hard enough. Red flags that should have raised alarms—like a single interpreter accompanying multiple workers to registration appointments, or wages from several employees flowing into the same bank account—were either missed or simply ignored.
The Commissioner’s report warned that if organised slavery could operate at this scale, for this long, within the licensed and regulated parts of the UK economy, then no company could credibly claim its supply chain was clean based on paperwork alone.
And that warning landed at an awkward time for the UK government, because by 2019 Britain already had a piece of legislation that was supposed to be dealing with exactly this kind of problem. It was called the Modern Slavery Act 2015, and it had been described—by the government that passed it—as “world-leading.” So yeah—let’s see how well that worked out, shall we?
Spoiler alert: not well.
”World-Leading” Law Meets a Messy Reality
The Modern Slavery Act received Royal Assent in March 2015, and at the time it really was a big deal. The UK became one of the first major economies to consolidate all its slavery and trafficking offences into a single piece of legislation, with life sentences for the worst offenders, new prevention orders that could restrict convicted individuals even after release, and the creation of an Independent Anti-Slavery Commissioner to oversee the national response. The then-Home Secretary, Theresa May, championed the Act personally and wasn’t shy about it—this was, she said, “world-leading” legislation. For a while, a lot of international observers agreed.
But the centrepiece that attracted the most attention from businesses was Section 54—the transparency in supply chains clause. It required any commercial organisation with an annual turnover of more than £36 million to publish a yearly statement setting out what steps, if any, it was taking to ensure modern slavery wasn’t occurring in its operations or supply chains. The idea was elegant: force big companies to look at their own supply chains, put what they found in writing, and let public scrutiny do the rest. Investors, consumers, and journalists would read the statements, compare them, and apply pressure where companies fell short.
Elegant in theory. In practice… not so much.
The Act didn’t specify what the statements had to contain, didn’t require companies to actually do anything beyond publishing them, and imposed no penalties for filing a vague or boilerplate statement. So that’s exactly what a lot of companies did. Researchers reviewing the statements found that many were short, formulaic, and essentially meaningless—reading more like a legal compliance tick-box exercise than a genuine assessment of risk. Some companies recycled the same statement year after year with the date changed. Others published statements that amounted to “we have a policy against modern slavery,” which is a bit like saying “we have a policy against bad things happening.” Nice to know, but not exactly actionable.
The Act also established the UK’s formal system for identifying and supporting victims: the National Referral Mechanism, or NRM. If someone was identified as a potential victim—whether by police, border officials, charities, or employers—they could be referred into the NRM, which would assess their case and, if they were recognised as a victim, grant access to support services like housing, counselling, and legal assistance.
By 2022, the NRM was receiving around 17,000 referrals a year, with labour exploitation consistently the most common category. That sounds like a system that’s working. But the process was agonisingly slow, often taking months or even years to reach a decision, and survivors regularly fell through the gaps. Some were left in limbo so long that they became homeless or were re-trafficked before a decision was even made.
And then there’s the gap between what the NRM was processing and the scale of the actual problem. Walk Free’s Global Slavery Index estimated that approximately 122,000 people were living in modern slavery in the UK in 2021. The NRM handled 17,000 referrals the following year. Even accounting for wide margins on those estimates—the vast majority of people trapped in forced labour, domestic servitude, or trafficking were never being identified at all.
Independent reviews of the Act—conducted in 2016 by Caroline Haughey and again in 2019 by a panel led by Frank Field, Maria Miller, and Baroness Butler-Sloss—all pointed to the same cluster of issues. Not enough enforcement. Not enough training for frontline professionals to spot the signs. And not enough teeth in the supply-chain provisions to make companies take them seriously.
The UK had built itself a genuinely ambitious legal framework and then hadn’t invested the resources or the political will to make it work. Prosecutions remained low relative to the estimated scale of the problem. Corporate statements were largely decorative. And the people actually being exploited in fields, factories, car washes, and care homes across the country were mostly invisible to the system designed to protect them. The law was on the books, but enforcement was just kind of another matter entirely.
Brexit, Labour Shortages and New Visa Traps
Now, while Parliament was passing laws and commissioners were writing reviews, something else was happening that would reshape the entire landscape of low-wage labour in the UK: Brexit.
When Britain left the European Union, one of the immediate and entirely predictable consequences was that the supply of Eastern European workers who’d been picking, packing, and processing British food for two decades started to dry up. EU nationals no longer had automatic right to work in the UK, and many of the Romanians, Bulgarians, and Poles who’d previously filled seasonal farm jobs decided it wasn’t worth the hassle of navigating a new immigration system for a few months of backbreaking work in a Lincolnshire field. Then COVID hit on top of that, locking borders and grounding flights at exactly the moment when crops needed harvesting. By 2021, the labour shortage in UK agriculture was severe enough that farmers were warning of fruit rotting unpicked, and the government needed a solution fast.
That solution was the Seasonal Worker Scheme. It had been quietly piloted in 2019 with just 2,500 visas. The concept was simple enough: issue short-term visas allowing overseas workers to come to the UK for up to six months of agricultural work, managed through a handful of licensed “scheme operators” who would handle recruitment, visa sponsorship, and placement on farms. After Brexit exposed the scale of the labour gap, the government expanded the scheme rapidly—scaling it up to around 30,000 visas in 2021 and pushing toward 47,000 by 2023, according to Walk Free’s analysis. That’s a nearly twentyfold increase in four years. What could go wrong?
But here’s the catch:
When the scheme was small and drawing workers mainly from countries with established migration routes to the UK, the risks were manageable. As it scaled up, the recruitment net widened dramatically, pulling in workers from Indonesia, Nepal, Kyrgyzstan, Tajikistan, and other countries where the average income is a fraction of what it is in Britain—and where the local recruitment industry is, let’s just say, not always tightly regulated.
Workers in these countries were being recruited by local brokers who charged substantial fees for arranging the paperwork, the visa, the flight, and the placement—fees that often went well beyond what was legal under local law, let alone UK law.
FLEX, the Focus on Labour Exploitation charity, reported that three-quarters of seasonal workers surveyed had borrowed money to cover the upfront costs of coming to Britain, with some paying anywhere from £2,000 to £5,000 before they’d set foot on a farm.
And the structure of the visa itself created its own trap. Seasonal Worker visas are tied to the scheme operator that sponsors them, meaning workers can’t simply leave one farm and find another job if conditions are bad. In theory, there are processes for transferring between operators. In practice, workers who barely speak English, who are thousands of miles from home, and who owe more money than they’ve ever seen in their lives aren’t exactly in a strong negotiating position.
The visa also offers no path to settlement or long-term residency, so workers know from day one that they’re temporary, disposable, and replaceable. If they make trouble, they get sent home—still carrying the debt.
Researchers at FLEX and the Landworkers’ Alliance had a term for this combination of factors: “hyper-precarity.” Which is an academic way of saying… everything about your situation conspires to keep you trapped. Immigration status, debt, employer dependency, and geographic isolation all reinforce each other to create conditions where forced labour can flourish without anyone technically breaking the rules of the visa system. Nobody confiscates a passport.
Nobody locks a door. The debt and the visa do the work instead—and from the outside, the whole arrangement looks perfectly legal. Even government-sanctioned.
The Guardian’s reporting in 2022 brought some of these dynamics into sharp focus. Nepali workers described paying thousands to agents in Kathmandu for farm jobs in Kent, only to find that hours were short, conditions were poor, and the promised earnings were nowhere near enough to cover their debts. Indonesian workers told similar stories—massive upfront payments to brokers, gruelling work on arrival, and the constant threat of being sent home early if they didn’t meet targets or didn’t keep quiet.
One labour provider at the centre of several of these complaints—which we will leave unnamed (for legal reasons)—was at the time one of the largest operators in the Seasonal Worker Scheme, supplying workers to farms across the south of England. Following investigations, they eventually lost both its Home Office sponsor licence and its GLAA licence in 2024, though the company maintained it had done nothing wrong and that any illegal fees were charged by overseas agents outside its control.
That defence captures the central problem with the entire scheme. The UK government designs a visa programme. Licensed operators recruit workers through overseas brokers. Those brokers charge illegal fees that leave workers in debt bondage before they even board the plane.
And when it all comes to light, everyone points at someone else. The operator blames the overseas broker. The broker is in Indonesia or Nepal, beyond the reach of UK regulators. The GLAA can investigate what happens on British farms but has no jurisdiction over what happens in a recruitment office in Jakarta.
And the workers—the workers are just stuck in the middle, owing money they can’t repay.
Debt in the Polytunnels
We’ve talked a lot about systems and structures, so let’s bring this back down to what it actually feels like to be inside one of these arrangements.
The following accounts are drawn from testimonies reported by the Guardian, FLEX, and the Landworkers’ Alliance between 2022 and 2024. Details have been kept general to protect identities, but the patterns are consistent across dozens of cases.
Let’s imagine a man in his early thirties from a rural village in Central Java. He’s got a wife, two young kids, and a small plot of land that produces just enough to get by. A local recruitment agent approaches him with a brochure showing workers in a green English countryside, smiling, holding punnets of strawberries.
The agent explains the deal: six months of farm work in Britain, earning more per week than he’d make in two months back home. The catch is the cost—the visa application, the medical check, the flight, the agency fee—it all adds up to around £3,500. He doesn’t have that kind of money, obviously. So he borrows from his brother-in-law, and takes out an informal loan from a local moneylender at an interest rate he tries not to think about too carefully.
By the time he boards the plane to London, he’s carrying more debt than he’s ever had in his life.
He arrives at the farm in southern England and the work starts immediately. Strawberry picking, bent double in polytunnels that trap the heat like greenhouses, filling punnets against a target that seems designed for someone with four hands. The accommodation is a shared caravan on the edge of the farm, basic but liveable, with rent deducted automatically from his wages. For the first few weeks, the hours are decent and the maths almost works—if he keeps this pace up for the full six months, he can clear his debts and bring home enough to make the whole gamble worthwhile.
Then the season slows down earlier than expected, and hours start getting cut. Three shifts a week becomes two, then one. Some weeks, after the accommodation deduction, he’s taking home almost nothing. He asks the farm supervisor about more hours and gets a shrug.
He thinks about complaining to the scheme operator, but other workers warn him that people who make noise get sent home early. And going home early, still deep in debt, with nothing to show for the sacrifice his family made—that’s the one outcome he can’t face.
Or how about a woman from Nepal. She pays around £4,000 to a Kathmandu-based agent, borrowing most of it from relatives and a local cooperative. She’s told she’ll be picking fruit in the English countryside for six months, with accommodation and transport included. When she arrives, the work is real and the farm is legitimate, but the targets are relentless and the supervisors have no patience for workers who can’t keep up.
She’s fast, but not fast enough, and within five weeks she’s told her contract is being terminated early due to “performance.” She’s put on a flight home with a fraction of what she was promised and a debt that will take her family years to repay.
The Financial Times reported in 2023 that many seasonal workers were arriving with debts that effectively turned their entire stay into a race against interest payments. The workers who got a full season of hours could sometimes break even. The ones who were dismissed early, or given too few shifts, or hit with unexpected deductions—they went home worse off than when they started, carrying shame as well as debt. Several workers told researchers they couldn’t face their families, that the failure felt personal even though the system had been stacked against them from the beginning. Others described being afraid of the brokers they still owed money to, particularly in cases where the fees charged were illegal and the broker had every reason to keep quiet about the arrangement.
And through all of this, the strawberries still made it to the supermarket shelf, neatly packaged with a nice little Union Jack on the label.
The Watchdog on a Diet: GLAA Under Fire
So we’ve established that the GLAA has a massive job. It licences labour providers in the food and agriculture sectors, it has police-style powers to investigate labour exploitation across the wider economy, and it’s supposed to be a key part of the UK’s response to modern slavery. Sounds like a serious organisation doing serious work. So let’s talk about what it actually has to work with.
In March 2024, the Guardian reported that the GLAA’s budget for the 2024-25 financial year had been set at approximately £6.25 million. That’s down from roughly £7.7 million five years earlier—a real-terms cut of almost £2 million once you factor in inflation. At the same time, the authority’s remit had expanded significantly since its 2016 rebranding, covering not just the original four food and agriculture sectors but labour exploitation across the entire economy. More work, less money. You can probably guess how that’s been going.
But it’s the staffing numbers that really tell the story. According to the same reporting, the GLAA had around 21 compliance inspectors tasked with monitoring hundreds of licence holders who collectively supply an estimated 520,000 or more workers across the regulated sectors alone.
Yep. Twenty-one inspectors. Half a million workers.
That’s before you even count the GLAA’s broader investigative responsibilities in unregulated sectors, where exploitation reports have been rising sharply, particularly in social care following the introduction of the Health and Care Worker visa. Even if every single inspector did nothing but conduct site visits five days a week, fifty weeks a year, the coverage would be a fraction of what’s needed to create any meaningful deterrent.
And people within the GLAA know this. When the organisation gave evidence to the House of Lords Modern Slavery Act committee in 2024, officials were remarkably candid about the resource constraints they were operating under. The message, stripped of the diplomatic language, was straightforward: we don’t have enough people, we don’t have enough money, and the problem is growing faster than our capacity to deal with it.
External critics were blunter. The Guardian quoted one anti-slavery campaigner who summarised the funding situation with a line that’s hard to forget: “If you want to abuse your workers, that’s fine.” The point being that with inspection rates this low, the rational calculation for a bad employer was simple—the odds of getting caught were vanishingly small, and even if you did get caught, the consequences were often less expensive than the profits you’d made from the exploitation.
The government’s response to these criticisms has followed a fairly predictable pattern. Ministers point to one-off injections of “transformation” funding, to policy reviews and strategy documents, and to the broader suite of enforcement bodies that work alongside the GLAA. The argument is that the GLAA doesn’t operate in isolation and that the overall enforcement picture is bigger than any single body’s budget. Critics counter that the other bodies are just as stretched, that the fragmented landscape makes coordination slow and patchy, and that one-off funding doesn’t solve a structural problem.
You just can’t run a sustained compliance and investigation programme on money that arrives in sporadic lumps and has to be spent by the end of the financial year.
Meanwhile, the GLAA’s own annual reports show a growing gap between the number of intelligence reports it receives—which have climbed steadily as awareness of modern slavery increases—and its capacity to act on them in a timely way. The authority is increasingly forced to triage, focusing its limited resources on the most severe and high-profile cases while lower-level exploitation—the kind that affects the most workers and sits in that grey zone between “bad job” and “forced labour”—goes largely unchecked.
For the workers at the sharp end, the ones in the polytunnels and the packhouses and the care homes, a regulator that doesn’t have the resources to actually regulate isn’t much of a regulator at all. No surprises there.
Parliament Wakes Up (Again): Lords Review
In October 2024, a House of Lords select committee published a report with a title that told you almost everything you needed to know before you’d read a single page. It was called “The Modern Slavery Act 2015: becoming world-leading again,” and that word “again” was doing an enormous amount of heavy lifting. The implication? The UK’s response to modern slavery had once been genuinely impressive—and had since deteriorated to the point where the country needed to start catching up with itself.
The committee was cross-party, included peers with backgrounds in law, policing, social policy, and international development, and had spent months taking evidence from GLAA officials, survivor support charities, and academic researchers.
Their conclusions were pointed. The enforcement landscape was fragmented and under-resourced. Multiple bodies shared overlapping responsibilities and none of them were adequately funded. The GLAA was singled out as a regulator whose remit had grown far beyond its capacity.
But the committee’s criticism went wider than any single body. They argued that the entire system for identifying, supporting, and protecting victims had been weakened by recent legislative changes that prioritised immigration control over victim protection.
That last point gets to the heart of a tension that’s been building in UK policy for years. In 2022 and 2023, the government introduced new immigration measures—most notably through the Nationality and Borders Act and the Illegal Migration Act—that tightened the criteria for who could access the National Referral Mechanism and what protections they’d receive once inside it. The stated aim was to prevent the NRM from being “abused” by people making false claims of modern slavery to avoid deportation.
The effect, according to the Lords committee and a wide range of charities and legal experts, was to make genuine victims more afraid to come forward. Reuters reported in early 2025 that anti-slavery organisations were seeing exactly this, with frontline workers describing migrants who’d rather stay in exploitative situations than risk engaging with an immigration system they no longer trusted.
The government issued its formal response on 16 December 2024. It accepted some recommendations, including commitments to review aspects of the NRM process and explore better coordination between enforcement bodies. But it pushed back on the structural criticisms, defending the immigration legislation and insisting that the existing framework, with targeted improvements, could deliver an effective response. Ministers pointed to rising NRM referral numbers as evidence that the system was working—an argument that critics found somewhat circular, since higher referrals could just as easily indicate a growing problem as an improving response.
Charities working directly with survivors were cautiously positive about the Lords review but frustrated by the pace of change. The Salvation Army, which runs the government’s contract for adult victim support in England and Wales, warned that survivors were continuing to fall through gaps, particularly during the long delays between NRM referral and a final decision. FLEX and the Anti-Trafficking Monitoring Group focused on the specific intersection of visa policy and exploitation, arguing that tied visas in both the Seasonal Worker Scheme and the Health and Care Worker route were creating exactly the conditions the Modern Slavery Act was supposed to prevent.
In March 2025, MPs debated the tenth anniversary of the Modern Slavery Act in the House of Commons, and the tone was notably less celebratory than it had been even three years earlier. Members from both sides acknowledged that referrals were rising, prosecutions remained low, and the promise of “world-leading” legislation had not translated into world-leading outcomes. Several MPs specifically raised the issue of seasonal workers and gangmaster-linked exploitation. The debate ended without a vote or a binding commitment—fairly standard for these kinds of parliamentary occasions—but the fact that it happened at all, ten years after a law that was supposed to solve the problem, said something about how far the gap between aspiration and reality had grown.
”Slavery Over There” vs “Slavery Over Here”
There’s a particular image that tends to come to mind when most people hear the phrase “modern slavery.” It usually involves a sweatshop somewhere in Southeast Asia, or a clothing factory in Bangladesh, or children working in a mine in sub-Saharan Africa—somewhere far away, shocking, safely distant from your own daily life. And those things are totally real.
But they’ve also become a kind of mental shortcut that lets people in wealthy countries assume the problem is fundamentally over there. That it’s somebody else’s government failing to act.
The UK’s own data tells a very different story.
When you look at the National Referral Mechanism figures, labour exploitation consistently ranks as the single most common form of referral. In 2022, it accounted for around 30% of all NRM cases, ahead of sexual exploitation, domestic servitude, and criminal exploitation. And the sectors that keep showing up? Agriculture, food processing, construction, car washes, nail bars, hospitality, and increasingly, social care.
These are industries that operate on every high street and in the supply chains of every major supermarket in the country.
The GLAA’s own intelligence work, particularly its 2018 problem profile, mapped out the demographics. A significant proportion of identified victims were EU nationals—mainly from Poland, Romania, and Lithuania—working in exactly the low-wage, gangmaster-supplied sectors we’ve been discussing. But they weren’t the only ones. The profile also flagged UK nationals being exploited, particularly in county lines drug operations where young British men were forced to transport and sell drugs under threat of violence—a form of modern slavery that doesn’t involve immigration at all.
Vietnamese nationals were heavily represented in nail bars and cannabis cultivation. Albanian and Nigerian nationals appeared across multiple exploitation types.
And here’s another uncomfortable truth: many of the people being exploited in the UK are here legally. They’re EU citizens who arrived before Brexit with a right to work, or visa holders on seasonal worker permits, or even British-born individuals targeted because of addiction, homelessness, or mental health vulnerabilities.
The popular assumption that modern slavery primarily affects undocumented migrants isn’t just incomplete—it actively obscures the scale of the problem. Operation Fort proved how dangerous that blind spot can be: hundreds of Polish workers exploited through entirely mainstream recruitment channels while holding legitimate employment.
The grey area matters, too. Not every terrible job meets the legal definition of modern slavery, and researchers have consistently warned against inflating the numbers. But those same researchers point out that the structural conditions enabling slavery—debt, tied housing, employer dependence, fear of immigration enforcement, isolation—are present in a huge number of low-wage workplaces that never make it into the NRM statistics.
So Who’s Responsible?
Alright, so let’s ask a rather obvious question. When a punnet of strawberries reaches the supermarket shelf and the people who picked it were trapped in debt, earning below minimum wage, or dismissed before they’d worked long enough to cover their recruitment fees—whose fault is that, exactly?
The honest answer is that responsibility is layered, and almost everyone involved has found a way to point the finger at someone else.
At the really nasty end, you’ve got the criminal gangmasters and traffickers—the Lin Liang Rens and the Operation Fort networks—who deliberately recruit vulnerable people and exploit them for profit. Nobody disputes that those people are culpable. When they’re caught and convicted, they go to prison. But they’re also the easiest targets, the ones the system is most comfortable punishing, and focusing exclusively on them lets everyone else off the hook.
One step back, you’ve got the labour providers and recruitment agencies—some licensed, some not—who supply workers to farms and food processors. In theory, these organisations are regulated by the GLAA and required to meet licensing standards. In practice, as we’ve seen, a licence doesn’t guarantee that workers are being treated properly, and the layers of subcontracting and overseas brokerage create convenient gaps where accountability disappears. The UK-based operator says the illegal fees were charged by an agent in Indonesia.
The Indonesian agent isn’t answerable to British regulators. And the worker in the middle just knows they’re £4,000 in debt and nobody’s taking responsibility for it.
Then you’ve got the supermarkets and food brands—the companies whose logos actually appear on the packaging. Operation Fort’s independent review made it painfully clear that exploitation was occurring in the first tier of supply chains serving major retailers, not buried five layers deep in some impenetrable web of subcontractors. The retailers involved all had modern slavery policies, compliance teams, and supplier codes of conduct. None of it caught what was happening.
The fundamental dynamic driving this part of the problem is price. Supermarkets compete fiercely on cost. That pressure flows down to suppliers and growers, who pass it to labour providers, who pass it to workers. Everyone along the chain is squeezing the margin, and the people with the least power absorb whatever’s left.
And behind all of it sits government, which designs the visa schemes, sets the enforcement budgets, and writes the laws. The Seasonal Worker Scheme was built to solve a real labour shortage, but it was built in a way that front-loads financial risk onto workers and ties them to single employers—creating the structural conditions for debt bondage without anyone having to actually break the law. The GLAA was given an expanding remit and a shrinking budget.
The Modern Slavery Act was passed with fanfare and then left without the enforcement resources to make its provisions meaningful. At every stage, the policy choices that enable exploitation have been made in Whitehall, not in a field in Kent.
Now… it’s not all broken, and not everyone is failing.
Some retailers have started trialling “employer pays” recruitment models, where the cost of bringing a seasonal worker to the UK is borne by the company that benefits from their labour rather than the worker themselves. FLEX and other NGOs have been pushing this approach for years, and the logic is simple: if workers don’t arrive in debt, they can’t be debt-bonded.
Several union-backed worker support centres have sprung up near major farming areas, offering advice, translation, and a safe place for seasonal workers to report problems without fear of retaliation. And the GLAA, for all its resourcing constraints, has conducted operations that have genuinely disrupted exploitation and led to real prosecutions—its officers aren’t the problem, and many of them have been vocal about needing more support.
But the structural fixes that researchers, charities, and even the House of Lords have been calling for remain largely unimplemented. A single, properly funded labour enforcement body covering all sectors. Mandatory “employer pays” recruitment across all visa schemes. Portable visas that let workers change employers without losing their immigration status.
Meaningful penalties for companies whose supply chains contain exploitation—not just a requirement to publish a vague annual statement. And a firewall between labour rights enforcement and immigration enforcement, so that workers can report abuse without fear of being deported before their case is heard.
Twenty-one people drowned in Morecambe Bay in 2004, and the country said “never again.”
Twenty years later, the sands are quiet but the exploitation has moved indoors—into polytunnels and packhouses and poultry sheds and care homes, carried there by visa schemes and recruitment chains that span half the globe. Blame getting shifted around as much as the people.
Key Takeaways
- The UK’s Seasonal Worker Scheme leaves migrants thousands of pounds in debt before they begin work, trapping them in exploitative conditions.
- The Gangmasters and Labour Abuse Authority oversees roughly 520,000 workers with only 21 compliance inspectors and a shrinking budget.
- The Modern Slavery Act’s supply chain transparency requirements lack penalties, allowing major companies to file meaningless boilerplate statements.
- Tied visas prevent seasonal workers from changing employers, creating ‘hyper-precarity’ where debt and immigration status enforce compliance.
- Twenty years after the Morecambe Bay disaster prompted reform, exploitation persists through legal visa routes and licensed operators rather than solely criminal networks.
Scandal Editorial
The Scandal editorial team researches, verifies, and structures investigative stories across the Power, Fame, Money, and Cover-Ups desks.
Frequently Asked Questions
What happened at Morecambe Bay on February 5th, 2004?
At least 21 Chinese cockle pickers drowned on the sands of Morecambe Bay after being sent out in the dark by gangmaster Lin Liang Ren, who ignored warnings about dangerous tides. Most couldn’t swim and barely spoke English. The disaster led to the Gangmasters (Licensing) Act 2004 and creation of the GLA.
What is the Gangmasters and Labour Abuse Authority (GLAA)?
The GLAA is the UK’s regulator for labour providers in agriculture, horticulture, shellfish gathering, and food processing/packaging. Originally created as the Gangmasters Licensing Authority (GLA) in 2005 after Morecambe Bay, it was rebranded in 2016 with expanded police-style powers to investigate labour exploitation across the entire economy, though its resources did not significantly increase.
How much debt do seasonal workers typically arrive with in the UK?
According to 2024 Guardian reporting, Indonesian workers paid upwards of £2,000 in official visa and travel costs, with some allegedly paying an additional £1,100 or more in broker fees. FLEX reported some workers paying £2,000 to £5,000 before arriving. Many sold livestock, borrowed from family, or took informal loans at painful interest rates.
What was Operation Fort?
Operation Fort was the largest modern slavery prosecution in UK history. Between 2012-2017, a Polish organised crime group trafficked and exploited around 400 vulnerable Polish nationals, placing them in legitimate jobs through mainstream recruitment agencies at farms, food processing plants, and warehouses. Victims were left with as little as £20/week while the gang made over £2 million. Eight members were convicted in July 2019.
What is Section 54 of the Modern Slavery Act 2015?
Section 54 is the ‘transparency in supply chains’ clause requiring commercial organisations with annual turnover over £36 million to publish yearly statements on steps taken to prevent modern slavery in their operations and supply chains. However, the Act didn’t specify content requirements, mandate actual action, or impose penalties for vague statements, leading many companies to file boilerplate documents.
How many compliance inspectors does the GLAA have?
According to March 2024 Guardian reporting, the GLAA had approximately 21 compliance inspectors to monitor hundreds of licence holders supplying an estimated 520,000+ workers across regulated sectors alone. The budget was approximately £6.25 million for 2024-25, down from roughly £7.7 million five years earlier.
What is ‘hyper-precarity’ in the context of seasonal workers?
Researchers at FLEX and the Landworkers’ Alliance used ‘hyper-precarity’ to describe how immigration status, debt, employer dependency, and geographic isolation combine to trap seasonal workers. The tied visa prevents changing employers, while massive recruitment debts create conditions where forced labour can flourish without anyone technically breaking visa rules.
What did the House of Lords report in October 2024 conclude about UK modern slavery policy?
The report titled ‘The Modern Slavery Act 2015: becoming world-leading again’ found the enforcement landscape fragmented and under-resourced, with the GLAA’s remit grown beyond its capacity. It criticized recent immigration legislation (Nationality and Borders Act, Illegal Migration Act) for prioritizing immigration control over victim protection, making genuine victims afraid to come forward.
What was DJ Houghton Catching Services and why was it significant?
DJ Houghton Catching Services was a Kent-based company supplying chicken-catching crews to farms. The GLA revoked its licence in 2014, calling it ‘the worst gangmaster ever.’ Workers were transported in overcrowded vehicles, sometimes slept in vans, earned below minimum wage, and faced unlawful fees and wage withholding. In April 2019, the High Court found the company and its directors personally liable for systematic underpayment and breaches.
Workers also brought claims against the GLAA itself for failing to act sooner.
What sectors are NOT covered by the original GLA licensing regime?
The original Gangmasters (Licensing) Act 2004 only covered four sectors: agriculture, horticulture, shellfish gathering, and food processing and packaging. Construction, hospitality, car washes, nail bars, and care homes were not covered, leaving significant gaps in enforcement that the 2016 expansion to GLAA attempted to address.
Sources
- Original Scandal video: Gangmasters: The UK’s Hidden Slavery Problem
- Hero image source by openverse, cc0.


