When staff accommodation becomes an exploitation risk

A seasonal worker is living in accommodation connected to their job. Colleagues notice unfamiliar visitors coming and going. The worker becomes withdrawn.

Other residents say they no longer feel safe. There are rumours of drug activity, intimidation or people staying in the accommodation who should not be there. Management may see this as a property issue, misconduct issue or breach of accommodation rules.

But what if something more serious is happening? What if the worker is being exploited?

What is cuckooing?

Cuckooing usually refers to a situation where criminals take over or use another person’s home or accommodation for criminal purposes. It is often associated with county lines drug activity, but it can also involve wider criminal exploitation, intimidation, financial abuse, sexual exploitation and coercive control.

The person living in the accommodation may appear to be allowing others in. That can be misleading.

They may be frightened, groomed, threatened or controlled. They may fear retaliation. They may also fear losing their job, accommodation, immigration status or income.

Criminals who engage in this type of exploitative conduct can be extremely manipulative. Employers should make their own assessment of the circumstances and be mindful that the victim may have been pressured into making statements that exonerate their abuser.

The Crime and Policing Act 2026, which comes into force on the 29 June 2026, creates a new criminal offence of exercising control over another person’s dwelling without their consent for the purpose of enabling the dwelling to be used in connection with the commission of specified criminal activity, typically drugs, sexual offences and weapons offences. The offence will carry a maximum penalty of five years’ imprisonment plus financial confiscation proceedings.

Why farming and hospitality employers should pay attention

Cuckooing is often discussed as a housing or policing issue. In farming and hospitality, that framing is too narrow.

Accommodation may include farm cottages, caravans on agricultural land, seasonal worker accommodation, hotel staff accommodation, pub accommodation, accommodation attached to restaurants or rural venues, holiday park accommodation, or shared houses arranged by an employer or labour provider.

These arrangements can be entirely legitimate, but they can also create vulnerability.

Workers may be isolated, young, low-paid, seasonal, migrant, sponsored or agency workers. They may have limited English, limited transport and limited local support. They may depend on the same arrangement for both work and housing and that dependence can make it harder to report exploitation.

Why this is both an employment and criminal/regulatory issue

This is not just an HR problem. It is also not just a criminal law problem.

It sits at the intersection of employment law, safeguarding, criminal exploitation, modern slavery, health and safety, regulatory compliance and reputational risk. From an employment perspective, employers need to consider worker welfare, disciplinary fairness, modern slavery indicators, discrimination risks, health and safety, immigration or sponsorship issues, and the wider duty to act reasonably once concerns are known.

From a criminal and regulatory perspective, employers may need to consider whether criminal activity is taking place on or around business-linked premises, whether police or safeguarding services should be involved, and whether the business has adequate systems to identify and escalate risk.

It is a criminal offence to knowingly allow premises to be used for producing, supplying, or consuming controlled drugs, with penalties ranging from fines to imprisonment. (Section 8 of the Misuse of Drugs Act 1971). Liability arises if the individual knew or had reasonable grounds to suspect that their premises were being used for illegal drug activity.

It is also an offence for the lessor or landlord of any premises or his agent to let the whole or part of the premises with the knowledge that it is to be used, in whole or in part, as a brothel, or, where the whole or part of the premises is used as a brothel, to be wilfully a party to that use continuing. (s34 Sexual Offences Act 1956)

Some employers take a line that the less they know the better, in the hope this will protect them from liability, others are afraid of being perceived as interfering with their employees or tenants’ privacy. A criminal investigation will however look at what an employer ought reasonably to have known from the circumstances.

Section 254 of the Crime and Policing Act 2026

The new section 254 of the Crime and Policing Act 2026 allows an organisation to be held criminally liable for offences committed by senior managers acting in the actual or apparent scope of their authority. Criminal liability of an organisation therefore no longer depends on whether wrongdoing can be traced back to the board. It depends on how decision making is exercised throughout the organisation. This will be particularly relevant in relation to health and safety law, modern slavery and environmental law.

Aside from the risks of criminal prosecution for the employer, a criminal investigation on the employer’s premises, or prosecution of employees may attract unwanted negative publicity for a business. Investigations and negative publicity may also impact the future ability of the business to tender for contracts.

If the premises or employer is subject to any licensing regimes there may be safeguarding duties as a condition of the licence, and the police may report concerns that will affect the continuation or renewal of the license.

Warning signs employers should not ignore

Employers may not see an obvious exploitation issue at first. They may see behaviour that looks like nuisance, misconduct, anti-social behaviour or a breach of accommodation rules.

Warning signs may include:

1. Unauthorised visitors repeatedly attending worker accommodation.
2. Increased traffic to and from accommodation at unusual hours.
3. Workers appearing frightened, withdrawn or controlled.
4. Workers being reluctant to speak without another person present.
5. Other residents saying they feel unsafe.
6. Unknown individuals staying overnight.
7. Reports of drugs, intimidation, threats or violence.
8. A worker no longer appearing to control their own living space.
9. Wages, bank cards, phones, passports or documents being controlled by someone else.
10. Unexplained absences, lateness or behaviour changes.

None of these signs automatically proves cuckooing, but they should prompt questions.

Why a disciplinary response may be risky

One of the biggest mistakes an employer can make is to treat the worker as the problem without considering whether they may be a victim.

A worker may appear to have breached accommodation rules, allowed unauthorised visitors in, caused disruption or failed to report concerns.

However, if they are being coerced, threatened or exploited, a purely disciplinary response may be unsafe and unfair.

Before taking disciplinary action, employers should ask:

1. Can the worker speak freely and safely?
2. Are there signs of coercion, intimidation or control?
3. Are there safeguarding or modern slavery indicators?
4. Are other workers at risk?
5. Would eviction, suspension or dismissal increase the risk?
6. Should police, safeguarding or specialist advice be sought?

Employers may still need to act quickly, but the action should be informed, proportionate and documented.

Practical steps for employers

Farming and hospitality employers who provide, arrange or control staff accommodation should consider:

1. Reviewing accommodation agreements, house rules and visitor policies.
2. Giving workers safe and confidential ways to report concerns.
3. Training managers to recognise signs of exploitation, coercion and cuckooing.
4. Keeping records of accommodation concerns, checks and welfare conversations.
5. Reviewing labour provider due diligence.
6. Having a clear escalation plan for police, safeguarding, HR and legal advice.
7. Avoiding automatic disciplinary action where exploitation may be present.
8. Remembering that “the worker let them in” may not be the end of the enquiry.

Final thought

Cuckooing in staff accommodation is uncomfortable to talk about and that is precisely why employers should talk about it.

Where accommodation is tied to work, exploitation risk is not just a private housing issue.

It is a workplace risk. It is a regulatory risk. Put simply, it is a risk employers cannot afford to ignore.