Skip to main content

S1E6 – To find out why modern slavery persists in the private security sector we talk to James Sinclair, Executive Director of Ethical Innovations and one of the Co-Founders of FSI Worldwide, an ethical recruitment company with its roots in the private security space. Why have modern slavery and the private security sector become intertwined and what can be done to stop such practices in the future? James, a practicing lawyer and serial entrepreneur who is also currently pursuing a PhD on this subject, shares his insights.


This podcast was originally published September 3, 2020

Welcome to the sixth episode in ICoCA’s podcast series Future Security Trends: Implications for Human Rights. I’m Chris Galvin, and I’ll be in conversation today with James Sinclair, a lawyer, an entrepreneur, a researcher and the executive director of Ethical Innovations, to discuss the future of slavery, private security and the human cost of cost cutting.

James, you’ve developed a deep interest and expertise in issues of modern slavery, particularly as it pertains to the private security industry. So, can you tell us how the world of private security and modern slavery are intertwined?

I’ll do my best. And first of all, hi Chris, and thanks for having me. I mean, the world of security and slavery have been intertwined for millennia. The idea of slavery and war is not a new one. The the way in which what we might call modern slaves and I think there are some difficulties with that terminology which can touch on later if you like, but this idea of sort of modern globalized labor exploitation and its intersection with private security is a relatively modern phenomenon. I mean, just touching on quickly, if I can, the ways in which contractors have have interfaced with war obviously has quite an interesting history in and of itself. If we go back to the years of the privateers before the kind of monopoly of violence was taken over by the state. But actually, I’ve just been doing some research on the number of contractors that are in the battle space. And it’s massively expanded in the last hundred years. I think the First World War 200 odd troops for each contractor. Second World War was more like 50 troops to one contractor, by Vietnam it was 7 to 1, it was 1 to 1 in many parts of many times during the Iraq second Iraq War and then more than 1 to 1 in Afghanistan in terms of contractors to troops. In fact, it’s a lot more than that now. So, there is a sort of an interesting history. it’s been supercharged a bit in the last 20 years or 30 years or so as a result of several intersecting phenomena, globalization, outsourcing and we might call the sort of neoliberal approach to economics where governments are increasingly unwilling to undertake activities themselves and want to outsource as much of their activities as they can.

Security is an obvious one because there are lots of security companies and I suspect people listening to this will be well aware of the history of private security companies and how they come about, but obviously, since 1990 and the sort of retrenchment from the Cold War, there’s been a lot of more militarily trained people looking for work. A lot know the expansion of the professionalism of private security as an industry has meant that governments have more options in terms of finding private security guards to do things for them. And you have a lot of countries in the world where there are weak law enforcement, there’s weak labour law and so you have a kind of a perfect storm for a bit of a race to the bottom on contract price and consequentially on worker welfare and on other issues. And recruitment for private security roles often happens in poorly governed spaces and this is something I’ll guess I’ll come back to a bit later if you want; but, when we’re talking about private security guards being recruited from places like Nepal or Kenya or Uganda, the initial recruitment, which is where a lot of the exploitation that we sometimes refer to as modern slavery or parts of modern slavery happens in very poorly governed spaces and so it’s very difficult to necessarily understand or control what’s going on at that point. And when you have razor-thin commercial margins, there’s not much of an incentive to look too hard at it.

Just one question on those numbers. You mentioned 1 to 1 troop to contractors in Iraq, and more than that in Afghanistan. Is that troops to private security contractors or contractors generally, because obviously there are many logistical companies and others involved?

That’s actually a really helpful clarification. So, we’re talking about overall contractors. So, you’re right. There is a definite distinction to be drawn there. So, as you say, particularly I think since the first Gulf War, there’s been a huge push towards outsourcing of all kind of non-core warfighting tasks. So, a lot of people know, since the LogCAP contracts were put together, I think initially in Somalia and then for the first Gulf War, a lot of the tasks, the Laundry or DFAC or sanitation or what have you have all been outsourced. So, yes, those numbers include those guys. But even so, it’s a pretty solid one-way track from over the last hundred years. The area I’m particularly looking at in terms of my research is sort of recruitment for diplomatic security work. So, both the UK and the US have been outsourcing their diplomatic security services for 20, 30 years. And increasingly, that is that’s a role that’s undertaken by the big private security companies and only in extremis you find troops intervening in those sorts of circumstances.

Now, you founded the Fair Labour Alliance and you co-founded FSI Worldwide, which is a recruitment company whose mission is to bring an end to modern slavery within the private security sector. So, can you tell us about FSI company model and maybe some of the challenges that it’s faced?

I should just clarify, I don’t work for FSI anymore, but anything I say should be taken with a slight pinch of salt because I haven’t really had any involvement with them for a couple of years. But I was there at the start and we co-founded it in 2006 largely because we wanted to find good jobs for ex-Gurkhas. And I’m not ex-military myself, I’m a jobbing lawyer, so what do I know about these things? But, I had some mates who were ex-Gurkha officers who were working in Iraq at sort of 2005-6. And what they saw was a bit disturbing for them, they saw that the kind of exploitation of the third country national workers and they saw the issues around Gurkha recruitment from Nepal becoming really problematic. So, we decided we wanted to set up a recruitment company that would recruit third-country nationals in the way that you and I might like to be recruited. So people selected on merit and properly insured, properly looked after, managed well, not having had to pay money for their jobs, which is still, unfortunately, a revolutionary concept, having proper leave provisions, being managed in their own language, in a sort of culturally sensitive way and all that sort of stuff.

Initially, we got some pretty good traction in the market. We did some good work with several private security companies, Gardaworld has always been a strong supporter of the company. We had various other contracts and we thought, perhaps rather naively at the time, that when the governments of the US and the UK and the various governments that were involved in that theatre of war became aware of the widespread nature of particular things like bonded labour and the sort of associated labour exploitation events that go on around that. Once they were aware of that, they would want to kind of clean ethical recruitment alternative. And we saw a sort of twin opportunity, we saw an opportunity to do some good from an ethical perspective, but frankly, we also saw a business opportunity. We thought, well, if the market is moving to a more ethical place, then let’s be the ones who get in there first. Hasn’t quite worked like that, I have to say, because FSI is still relatively small and there hasn’t been a sort of race into the marketplace, as we were hoping. Most of the recruitment for the private security sector, as with most other sorts of TCNs, is still largely based on the employee pays principle rather than the employer pays principle and all of the associated exploitation that comes with it.

Just to explain what FSI did that was different was that we set up our own recruitment structure in toto. So, whereas almost every other company that is recruiting, whether it’s security guards or chefs or whatever, they will rely on networks of agents and subagents and sort of local fixers who go out and find willing job seekers, and then they bring them in and they have their passports processed for travel, etcetera. Now, we identified that this network, this subagent network, was the really problematic element because that was where the sort of first element of exploitation was going on. What we sometimes refer to as the first handshake at the village level. Once that is corrupt or corrupted, everything else that flows afterward is very difficult to clean up. So, we felt it was really important to have a fully integrated recruitment system with our own people in villages who were rigorously selected so that we were not sort of leaving ourselves open to bribery or other forms of exploitation. And frankly, we just didn’t trust anybody. He was fairly paranoid about making sure that we didn’t allow ourselves to be exploited. But that’s an expensive thing to do, putting together a vertically integrated recruitment network. As a result, we found it difficult to compete in the marketplace because, frankly speaking, the people we were competing against were making money hand over fist in illegal and unethical recruitment fees.

And I’m sure most of your listeners will be aware of this. But, the norm for private security guards, if they’re looking for work, is somewhere like in Afghanistan, to pay somewhere between 3 and 5000 USD for their job. Now, most job seekers coming from Nepal, Kenya, or Uganda won’t have that kind of money lying around. So, they will have to borrow it and they borrow it at very high rates of interest and so all of this stuff compounds to create a debt bond, which is where the term bonded labour comes from. That debt bond then hangs over them, so it’s not just that they have to repay the money, it’s that whilst that debt is outstanding, they really don’t have any leverage to complain about their terms and conditions of employment. So, and I should say generally speaking, in the private security world, those terms and conditions are better than they are for unskilled manual workers and know where the problem is really severe. If you’ve got people going to work on construction sites in the Gulf or in rubber factories in Malaysia, and they have 3 or 4 or $5,000 worth of debt hanging over them plus the interest. And they owe that money to moneylenders who, frankly speaking, know where their families live. The chances of them complaining about any aspect of their work is zero because they cannot afford to lose that job because their debt is linked to the job. Lose the job and the debt is payable in any event, so they’re in real trouble.

So, we saw all of this happening. We thought, well, this this isn’t good, so let’s try and find a way of cleaning up these supply chains. But it’s really tough when the market is 95, 96% plus based on a sort of exploitative model. And if you’re a couple of Brits wandering into a marketplace and saying “Yeah, we’re here to clean it up”, well, good luck with that because it’s quite a mountain decline. And as a result, particularly when you’ve got, dare I say it, law enforcement, judges, politicians, all kind of lined up on the people who are all taking money. And I mean, this isn’t just conjecture. We’ve had people arrested in quite senior political and administrative positions in labour source countries who are sort of in on this business. So, it’s a really tough nut to crack, but ultimately if we’re going to be serious about trying to clean up labour exploitation, not just in the security business but across the piece, then a lot more investment, a lot more time and effort needs to be spent on the initial recruitment process.

And ultimately what you’re saying is that those costs need to be incurred by the clients themselves. At the moment, this system is the clients are getting away with not having to incur the recruitment costs.

Well, so that was what was true initially. In the early stages of the Iraq and Afghanistan conflicts, that was definitely true. It’s not so true anymore, partly because the US government has to say it really sort of led the way on the improvement to the federal acquisition regulations, which essentially ring fence, a requirement for security companies to pay for the recruitment of their personnel. And they’ve been very clear that not paying recruitment fees is a sort of key, key indicator of bonded or forced labour, because how else are these people going to be recruited? So, it is very uncommon now for companies to demand workers for free in the security space, I should say, or also in the space where you have the US and UK contractors directly recruiting people, they will now almost always insist that they have to pay something for recruitment. The problem used to be exactly as you identified that companies didn’t pay for recruitment and that has changed in relation to a lot of Western companies. It is still the norm when it comes to construction companies in Saudi, Qatar, or Dubai. They’re just not paying for their workers because they never have and they don’t see why they should have to. And so that, of course, is an institutionalized bonded labour problem from the start. It’s slightly different in the security space, let’s say, because of the change of the rules and because of more emphasis being placed on trafficking in person provisions in the US particularly, you will now have companies paying for recruitment.

So, the exploitative model has shifted from one where the recruiter who sits in the middle is basically just taking money from the recruits. Now he’s taking money from both the security company and the recruits because he’s the security company and said, well, we have to pay for our recruitment. So, here’s $300 a man or whatever it is that they’re paying, which the recruiter says “thank you very much, and I absolutely promise you I’m not taking money from the recruits”. And then as night follows day, it still happens anyway. I should say there is a certain amount of complexity in some of this stuff because it really does depend on what jurisdiction you’re talking about recruiting for. It depends on particular types of companies involved, the sort of work that you’re going for, and where they’re being recruited from. But, I don’t want to generalize about it, but there are essentially a couple of models, one of which is the bargain basement employee pays model, which is still absolutely the norm across most of the Middle East and places like Malaysia where it’s a pure exploitation model. Then you have this sort of hybrid model of what looks on the surface to be compliant becauseyou can see the paper trail of money going from Western security company to local recruiter and then a sort of clean bill of health apparently given by the local recruiter in terms of the recruits and how they’ve been recruited. And if you were ever to ask those recruits, have you paid illegal recruitment fees, of course, the answer will be no. Whether or, in fact they have or not is a much more difficult question because you’d only find that bit out if you were to if you were to really do a proper audit or a surveillance job on that first handshake that I spoke about earlier, the interface at the village level between the subagent and the recruit, because that is where it goes on.

Being slightly generalizing, most of my experience and my expertise comes from Nepal, but a lot of this is true for many other labour source countries. But there is a sort of web of deceit that goes on. And the recruiter who’s the licensed clean guy sitting in Kathmandu in this case, can sort of plausibly deny any knowledge of what goes on at the village level. And they kind of like it, though. There was a there was a push years ago back in 2010-2012, for subagents to be licensed as well as the central recruitment agencies. But, that kind of fell apart for several reasons. Firstly, it was just too many of them. Secondly, the central agents really didn’t want to be on the hook for who their subagents were and had to pay fees for them. So, they just weren’t registering them and they were carrying on using them anyway. And, there is a sort of a dance of death going on because the law enforcement people don’t really want to know because they’re often being paid off on the side. The agents, the central agents, certainly don’t want any of this being regulated because they can plausibly claim that their supply chain is clean, even though they’re not looking into it and there’s a very good chance that they’re also benefiting from the illicit payments that are being made. So, there’s a whole kind of web of stuff going on here which most audits will never uncover and unless you’re really looking at it in depth, unless you put some effort and some time and some money into uncovering it, you’ll never see. And it’s also there’s just one final point to note, which is that and this is a slightly difficult point to make, for the vast majority of people who are paying for jobs and who are then suffering all the exploitation, that comes on the back of that, they don’t see this as problematic. Now, that shouldn’t be an excuse not to do anything about it. There are plenty of people who think that it should be an excuse not to do anything about it. But, it is the norm and in many cases, third-country national workers see the payment of a fee to secure a job as a kind of form of job guarantee. So, “I’ve paid my three and a half, $4,000 or whatever it is, so I will therefore definitely get this job”. And so, agents who are taking this money think, well, he has paid, so he’s definitely going to go. The employer thinks, well he’s paid so he’s going to keep his mouth shut and he’s going to work hard. So it kind of works for everyone in the piece.

What it doesn’t work for clearly is the sort of respect for international human rights and for the rule of law, because in every place these practices are illegal and, in some cases, they’re taken seriously, in some cases they’re not. But the norm of this stuff is really quite complex to uncover. And as I say, it shouldn’t be a sort of council of despair and let’s not do anything about it because it’s not perceived as problematic. But we do need to recognize the fact that for a lot of the people involved in this business, this illicit business, it is not considered out of the ordinary and not in many cases considered problematic.

Now I’d like to kind of hone in on this compliance issue and the question of audit. And I should explain to folks that you are currently pursuing a PhD at the moment. And so, you have some real in-depth kind of research experience in this. I’d be interested to hear your thoughts about the procurement processes that govern the recruitment and management of these third-country nationals and what oversight mechanisms currently are in place to monitor and control the practices. Are these practices sufficient or are they lacking?

Well, it’s difficult to be generalized about the comments here because each jurisdiction obviously has its own rules. I can really only speak with any kind of authority, I suppose, in relation to the UK setting because that’s the jurisdiction that I’m looking at and have been looking at. I’m also a practicing English lawyer, so I have a little bit of sort of general legal understanding. So, if I can just restrict my comments to the UK. The history of this is sort of vaguely interesting, so I’ll just situate it slightly if you like. But there again, as many of your listeners will be aware, in the 1990s there was a kind of free-for-all in the private security game. We had the Sandline affair, we had Executive Outcomes, and all the rest of it, which we all know about. And that led to a situation in which, towards the end of the 90s there was quite a lot of disquiet, certainly in UK circles about quote-unquote mercenary activity. And so that led to something called the Legg Report, which was actually the UK government’s investigation into the Sandline affair as to whether or not the FCO was aware of what was going on. That report made certain recommendations about how the industry should be overseen or regulated. And at that point, so sort of 1998-1999 there was quite a groundswell amongst UK parliamentarians for a fairly sort of stiff regulatory regime here because they recognized that private security, armed private security activity is a sector with significant risk attached to it and therefore it should be properly, properly monitored.

Now of course, what happened was 9/11, and the world sort of tilted on its axis, and then following quickly on from that, you had the invasion of Afghanistan and then Iraq. So, this process of thinking about how to regulate private security kind of went into abeyance, in fact, went into abeyance for six years or seven years. But there was a green paper, which is sort of an early stage policy paper printed by the government in 2002, which set out six potential options for regulation of UK-based PMCs engaged in activities overseas and from a sort of and they ran everything from a kind of outright ban to the sort of softest of self-regulation and for options in between. And there was the sort of debate, there was an outreach process and an industry was involved in that. And rather conveniently, I suppose you might say that period in which the discussion was being held about what to do coincided with the busiest period of both Iraq and Afghanistan in terms of private security activity. And there is at least some evidence to suggest that that’s not coincidental. So, in essence, during that period, there was very little in the way of kind of legal structure around any of this stuff at all.

Then in 2009, finally they got around to thinking about what to do. And they put in place this sort of regime of voluntary standards, which was the kind of softest of the options set out in the Green Paper. And that was done for several reasons. Obviously, by then we were into the aftermath of the global financial crisis. So, it was perceived to be no money left to get involved in an expensive regulatory regime. There was a perception that private security, UK private security companies had kind of done quite well in Iraq and Afghanistan, that it was an area that the UK was quite good at and therefore they should try to encourage and not sort of burden with regulation if you want to call it that. So, we ended up with this sort of very light voluntary standard scheme of which of course the International Code of Conduct is one part. The one standard, which is an American standard, was also adopted along with ISO1878. So, this sort of web of standards became kind of the industry norm. And of course, the intention was to try and encourage companies to behave better and to adopt recognized international management standards in their activities.

It’s fair to say that the professionalism of UK-based private security companies has certainly improved since the 1990s. There’s no doubt about that. If you look at the way in which they are run, the professionalism of the boards, the kinds of people who sit on the boards of these companies, there’s definitely a marked improvement in their kind of responsibility, etcetera. So, slightly careful here, because from an operational perspective, there’s an awful lot that a lot of private UK-based private security companies have done that has been really good. Lots of examples of companies that have and individuals working for private sector companies who have acted in an exemplary way in the battlespace. So, I certainly don’t want to suggest that there’s been from a practical perspective some sort of failing. By and large, when they’ve been called upon to defend positions or to help out, they’ve done so in a very professional manner. That’s certainly worth pointing out.

In terms of my area of interest, the kind of bonded labour issues that underpin labour exploitation within private security supply chains, the voluntary standards mechanism has been, I think, a failure because the reliance on kind of voluntary standards and audits to mark against those standards has not been able to penetrate the kind of web of deceit that sort of set out for you a few minutes ago, this idea of what goes on in ungoverned spaces or poorly governed spaces in rural parts of labour source countries. And to be honest, a system of voluntary standards where there is a sort of commercial imperative to get things done quickly and cheaply, because, that’s what that’s what outsourcing is. It’s, quote-unquote, efficient because margins are necessarily thin if you’ve got competitive tenders, and that means there isn’t really the sort of bandwidth to go engaging in lengthy and expensive and comprehensive audit processes, etcetera. So, this kind of race to the bottom almost guarantees that there won’t be any meaningful oversight of that difficult and hard-to-spot problem. And of course, there isn’t. And so, when it comes to recruitment for private security, third-country national recruitment of private security, it is now as it ever was. I haven’t seen any evidence of any improvement, I haven’t seen any changed practices really amongst the recruiters and there seems to be, I dare say, a sort of blindness amongst many of the private security companies, many of whom kind of get the problem and they know what’s happening. But, if you speak to them quietly, they’ll say, “Well, we just don’t have the budget for this, and if we were to build the budget in for it, we would be commercially uncompetitive”; So, it’s not going to happen. And again, many of many of them will justify it by saying, “Look, these guys expect to pay for their jobs, they are otherwise well looked after; So, what’s the problem?” Others will say “It is a problem and we try we try our best to prevent it from occurring on our projects; but, it’s very hard and we can’t necessarily get right to the bottom of the supply chain because it’s remote and it’s difficult and expensive”. All of which is perfectly fair, but it comes back to the question of whether should there be more government intervention. And actually, I’m not necessarily advocating for a sort of massively statist approach here where you have formal, heavy-handed government regulation that may or may not work. But, even within the current system, you could do things that would make it better. You could mandate types of audits and you could pay for types of audits. So, rather than relying on security companies having to find from their own budgets money to pay for their own audits to audit against voluntary standards, the government could be a bit more insistent and say, “Look, if you’re going to recruit from countries that have a well-known reputation for labour exploitation, then okay, but you need to do the following to satisfy us that you have ensured that there are no abuses in your supply chain and we will pay for the in-depth audit process that will allow you to identify that and mitigate against it”.

Now, of course, there are some problems with that because the government part of the joy of outsourcing from a government perspective is that you don’t have to think about this stuff. You get someone else to do it and you pay them a fee and that’s that sort of job done. You get it off your desk. So, the idea of wanting to get more involved and start peeling back the onion and seeing what’s what, that’s yeah, there’s going to be a lot of reluctance there because there’s also issues around liability. What do you do if you find all this stuff? Do you fire the company? Do you give them a cure notice in American language? Do you ban people from recruiting from particular countries? I mean, there’s all sorts of issues that then arise. But, the oversight mechanisms are weak, the regulatory mechanisms are weak. That doesn’t necessarily mean that the outcomes from a kind of operational perspective have been bad. In many cases, they’ve been quite good, but from a human rights perspective, it’s pretty negative.

And so, where does the future lie in all this? I mean, how can these mechanisms be strengthened? Do we need new mechanisms? I mean, you mentioned potentially much greater government regulation, but how can we ensure that this practice of modern slavery, particularly in the sector of private security, doesn’t just continue on?

It’s a really difficult question. And there is no silver bullet. Let’s be clear about that. The people who talk about technology and say technology will solve it. Well, in my view, technology is at least as likely to make the problem worse or better, because if you introduce technology into an existing corrupt system, you’re quite likely just to make it all more efficiently corrupt. But so we’re talking about principally a corruption issue, a global political economy issue, an exploitation issue, and you can really only start to solve it with time, effort, commitment, and money. Let’s be clear. If governments wanted to really solve this problem, then they could do so by allocating funds, by being much more detailed about requirements for recruitment. In certain countries the companies charged with the recruitment would then have a clear responsibility to be much more thorough about what they do. And what I find slightly curious about this is that the UK government, the US government, all the governments around the world, they know what’s going on in labour-source countries. This is not a surprise to them to hear that bonded labour is rampant in the recruitment sector in Nepal or in various other countries. This is not new, so if you are accepting bids from companies who are telling you that they are going to be recruiting from those countries, then it’s kind of incumbent on you to say, well, hang on, we have passed laws in this country, the Bribery Act, the Modern Slavery Act, just to give two examples that specifically outlaw the kinds of practices that are rampant in this country.

So, from a public policy perspective, we think that it’s unwise for you to do that. But if you’re going to do that, then here are some heightened, sort of barriers over which you have to jump in order to satisfy us that this is kosher because at the moment, what seems to have happened from a government perspective is they pass some laws and then sort of put the laws in the drawer and look the other way because there’s zero funding for the kind of enforcement mechanisms and there’s no real follow up. So, this sort of oversight mechanism not really working now from a company perspective, it’s sort of similar, we did talk at FSI about the three eyes, which is insist, invest, and inspect. And the insistence comes from the top, from the leadership, from generating kind of norms of practice within a company. This is how we behave. This is how we want to look after our people. Actually, I’d have to say, just pausing there for a second, within the military or private security ex-military community, I’ve always found there to be a real camaraderie with other former military personnel. And, they don’t like the fact that their, former comrades are being exploited in this manner and they would really like for it not to be happening.

But of course, the “insist” part is just the first bit. You then need to invest and inspect and the invest bit is pretty obvious. You’ve got to you’ve got to put your money where your mouth is and you’ve got to be prepared to put in place the processes, procedures, people to get to the bottom of it and then you need to keep in the “inspect” phase. You’ve got to keep looking at your supply chain and investigating it and not trusting anybody and that all costs money, it costs time, and ultimately, that’s what that’s what you need to do. And as I said, I fear that we suffer a little bit, certainly in the UK, from what I sometimes call trophy legislation syndrome, where a government passes an act of parliament and then considers that job done and sort of moves on to the next question. And so, you speak to a lot of politicians now about quote unquote, modern slavery And as I say, I have some very significant issues with that term, but leaving that to one side, from their answers, you would be forgiven for thinking that the Modern Slavery Act 2015 solved all the problems. It certainly did not. But, it is because an act of parliament is passed that seems to be it when actually that’s the beginning rather than the end of the process. And then I’d like to see much more bilateral discussions going on between the UK Government and their counterparts in labour source countries are actually trilateral discussions between the UK government, say Nepal government, and then say the government of Qatar to do more to ensure that migrant workers are not being exploited in commercial supply chains. So, I guess my answer is that it’s difficult, but it’s not impossible. We’ve shown with FSI that it’s perfectly doable if you put the time and effort and money in. And actually, you get a much better result and apart from anything else in terms of building loyalty amongst the people that you recruit, it’s much better if you can not exploit them. If you can recruit, as I said at the very beginning, you recruit them as you and I would like to be recruited, you manage them as you and I would like to be managed. Guess what? There’s a huge amount of loyalty and respect that then follows and that translates back into the bottom line because FSI has a very low turnover rate of staff. But no, not least because it treats them well, which is not rocket science.

Well, James, thank you so much for sharing these insights. If I’m to summarize in a couple of words, I would say, from what you’re saying, the emphasis really needs to be on these final two, more investment and more inspection if we’re to ultimately solve this issue. But thanks for sharing these insights today, and we look forward to hopefully seeing your PhD thesis someday soon and more of your work.




The views and opinions presented in this article belong solely to the author(s) and do not necessarily represent the stance of the International Code of Conduct Association (ICoCA).