“During an inspection round, I always also check the accommodation, if the workers allow me to. When I enter the basement, and I can clearly see mattresses, bedclothes and a fridge or microwave or a rice cooker, well, at that point you can start asking, ‘So, how long are your workdays?’.”
Read this article in Norwegian on Arbeidsliv i Norden
The quote is from a Finnish health and safety inspector and is used in the fact sheet on labour crime, labour exploitation, and health and safety.
The fact sheet and checklist are aimed at labour inspectors, the social partners and other actors, to help them identify breaches of health and safety regulations that might be linked to labour crime and the exploitation of labour.
INTEGRATE – a Nordic research programme on labour crime
- The project’s full name is “INTEGRATE. Integrative Approaches to Labour Exploitation and Work-related crime: Knowledge, translation, transfer and exchange in the Nordic Context”.
- A collaborative project between researchers at HEUNI in Finland, the Department of Sociology of Law at Lund University in Sweden, and the research foundation Fafo in Norway.
- The project has resulted in a report and several practical tools, such as checklists and videos.
- All materials are available on the project’s website.
- The project is funded by the Nordic Council of Ministers.
The tools were developed as part of the INTEGRATE project, funded by the Nordic Council of Ministers and implemented by HEUNI together with Fafo in Norway and Lund University.
Lacking a common language
Natalia Ollus is the director of HEUNI in Helsinki. This spring, she has visited Stockholm and Copenhagen several times to talk to key stakeholders about the results from the Nordic INTEGRATE project.
“Our hope is, of course, that people will start using the checklists,” says Ollus.
In her presentations, the HEUNI director explains that we are not talking about a new phenomenon. She points to more than 20-year-old Nordic news items talking about the exploitation of foreign workers.
This is HEUNI
- Short for The European Institute for Crime Prevention and Control, affiliated with the United Nations.
- The European regional institute in the UN’s network of crime prevention and criminal justice programmes.
- An independent research institute, funded in 1981.
- Based in Helsinki.
But there is no common Nordic model for how to fight labour crime, says Ollus. There is also no common terminology.
We talk about social dumping, the grey economy, forced labour and modern slavery, human trafficking, exploitation of labour and labour crime.
The Nordic countries use different terms. That alone is a challenge, says Ollus.
“We wanted to use the project to explore the links between labour crime and occupational health and safety.
“One of the main problems in the Nordic region is the lack of a common Nordic model for how to monitor labour crime.”
Three Nordic models
There are three separate models in the Nordics in terms of monitoring migrant workers’ labour conditions.
Labour inspection model
- Finland and Norway: The labour inspectorates monitor the working conditions of migrant workers.
- Finland: The authorities have a duty to report any exploitation to police and can refer victims to support services.
Trade union model
- Sweden and Denmark: Trade unions monitor wages and working conditions for workers.
Hybrid model
- Iceland: Formalised cooperation between trade unions and authorities since 2025.
Sensitive question for Sweden and Denmark
Natalia Ollus cautiously questions the model being used by Sweden and Denmark.
“Who monitors wages and working conditions for non-unionised migrant workers?” asks Ollus.
She points out that occupational health and safety authorities in these countries have no mandate to control wages and working conditions or to check whether foreign workers are being exploited.
That is why the project wants to look at how existing health and safety regulations can be used to detect possible labour exploitation.
Within the existing mandate, inspectors can, for instance, ask where the workers live, who help them with documentation, whether they are in charge of their own passports and who pays their wages.
“Exploitative situations can be detected by using the indicators in the checklist,” says Ollus.
She believes one of the biggest challenges for Sweden and Denmark is that nobody is following up the working conditions for workers who are not trade union members.
“This is a sensitive issue, because it can be seen as a criticism of the Swedish and Danish model. That is not the intention. The problem is that many foreign workers for various reasons are not organised. And who will then follow up their working conditions?”
According to Ollus, this quickly turns into a political discussion. That is precisely why the project wants to develop a tool that can be used within today’s framework.
“The idea is that the health and safety framework can also be used to identify labour exploitation and labour crime, even without an explicit mandate. This has resulted in this checklist,” she says.
Too many ticks? Do more checks!
The fact sheet and checklist are results from conversations held in several focus groups where more than 70 experts from the whole of the Nordic region have participated.
“We think to begin with, the checklist – perhaps especially for Swedish and Danish authorities – can help identify situations that could indicate labour exploitation, without inspectors having to go beyond their mandate and ask more in-depth questions about wages, hours and working conditions.
“The idea behind our project is to look at the connections between health, occupational health and safety, labour crime and labour exploitation.”
“The checklist allows the users to tick several boxes. If there are enough ticks, you might ask yourself whether the problem is bigger than just a work environment issue and perhaps part of a bigger one – labour exploitation?”
The project has produced factsheets and checklists in the Nordic languages and in English. It comprises eight themes and a total of 52 control points.
The fact sheet “Work-Related Crime, Labour Exploitation and Occupational Safety” explains key concepts and describes what labour exploitation is, what risks foreign workers face and how the exploitation might be linked to work environments.
It also describes how the Nordic countries are trying to handle the risks.
The checklist identifies issues ranging from deficiencies linked to working hours, work clothing and equipment, workplace safety, living conditions, as well as signs of psychosocial stress.
It also provides advice for what to do if you see signs of breaches of occupational safety or work-related exploitation, and tips for how inspectors and authorities should engage with foreign workers who might have been victims of exploitation.
National contact details are also provided.
Watch and learn – videos included
The project has also resulted in a series of short videos showing how Nordic countries are dealing with labour crime.
The countries’ video titles indicate their themes:
- Norway: Norwegian perspectives on good practices in preventing work-related exploitation
- Denmark: QR business card – a way to reach out to vulnerable foreign workers in Denmark
- Sweden: A-krim centre and cooperation between authorities
- Iceland: The role of trade unions in preventing work-related exploitation
“Each country uses the videos to talk about promising practices. There are two examples from each country, in that country’s language plus an English version of all of the videos. The idea is to learn what is being done in other countries,” says Ollus.
The videos have already racked up quite a number of views.
“We haven’t marketed them a lot, so we’re positively surprised that many have already seen them.”
Higher on the political agenda
During her “tour” of the Nordics this spring, Natalia Ollus has seen a clear awakening around the fact that labour crime is a problem in the Nordic region and that something has to be done about it.
“There’s an increasing understanding that labour exploitation affects our European and Nordic societies – finally. But there’s still a debate about how to define it and how to address it,” says Natalia Ollus.
The INTEGRATE project recommendations
- Strengthen monitoring of working conditions for immigrant workers
- Monitor and regulate occupational health and safety risks more effectively
- Introduce administrative fines and penalties
- Strengthen the enforcement of existing criminal provisions
- Introduce residence permit options for exploited migrant workers
- Improve information-sharing with migrant workers
- Strengthen the role of public procurement in combating labour exploitation
- Companies should reduce supply chain complexity and strengthen their own oversight
She sees that politicians are giving the issue higher priority, that more measures and resources are being directed that way and that more concrete action plans are emerging.
“The phenomenon is getting far more attention in all of the Nordic countries now than before.
“Most of the Nordic countries take this seriously. That is very positive.”
