By Michael Pollitt

This week, 200 years after Britain abolished slavery as a trade and institution, the UK’s domestic labour laws were compared to a country in the top ten for human rights abuse.

"It’s worse than Saudi Arabia," an anonymous Filipino woman said of her life as an overseas domestic worker in Britain. “They treat me like a prisoner. They never even give me a single pound. I’m starting working around 4.30 in the morning, until 1 o’clock in the morning. I’m sleeping only in the kitchen. I’m crying the whole time that I’m lying on the floor.”

The ITV documentary, Britain’s Secret Slaves, aired on Monday, spoke to several women in a similar position. They are the victims of a much-maligned 2012 anti-immigration initiative, which removed the right for migrants on the domestic worker’s visa to change their employer in the UK. This left foreign domestic workers highly vulnerable to exploitation. Since the regulations changed in 2012, Kalayaan, a UK charity working to support the rights of migrant domestic employees, has reported a doubling of physical abuse by employers.

The domestic worker’s visa is designed for cleaners, chauffeurs, cooks and nannies from outside the European Union, who are accompanying overseas employers to the UK. Many go to the household staff of wealthy foreign diplomats. Most of the overseas domestic workers interviewed by Human Rights Watch last year had come with their employers to the UK from the Arabian Gulf.

The Saudi comparison might seem hyperbolic. True, Saudi Arabia is home to one of the most traditional Islamic legal systems in the world. The 2015 Forced or Involuntary Labour Index ranks the Kingdom of Saudi Arabia sixth in the world for human rights violation. Yet, it has been noted that, where they relate to the rights of domestic workers, the legal systems of our respective kingdoms are not so incompatible.

Like Qatar, which came under international pressure last year for labour exploitations in its World Cup development project, Saudi Arabia uses the kafala system of foreign labour. Kafala (from the Arabic for ‘sponsorship’) stipulates that migrant workers can only enter Arab Gulf states through a pre-arranged sponsor (kafil). Employees thereafter remain bound to their sponsor for fear of becoming an illegal immigrant.

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Sponsors therefore commonly exercise inordinate control over the recruitment process, working conditions and movement of their domestic staff, who comply for fear of being deported to their home country. Something not dissimilar to the earliest forms of chattel slavery is the result. Asian embassies in Riyadh and Jeddah have recorded thousands of complaints from domestic workers forced to work around 18 hours a day, with no day off, and often without pay.

The unflattering comparison with the UK is well documented, but is slavery here really “worse than Saudi Arabia”? Surely that ITV interviewee was getting carried away. This is, after all, the home of abolitionism.

Yet, the Saudi government has shown itself to be slightly more responsive to moral pressure on the issue. The Saudi Shura Council passed a bill improving legal protections for migrant domestic workers in 2009 and the Saudi labour ministry proposed an outright ban on the kafala system in 2012. Although these proposals turned out to be little more than hot air, they at least reflect a willingness on the Saudi government’s part to acknowledge there is a problem.

This contrasts unfavourably with the position adopted by the UK government, whose latest refusal to amend the new domestic worker’s visa described its negative impact as “tiny”. The statistics would suggest otherwise. Of the overseas domestic workers in the UK who came forward for help last year, 62% were paid no salary at all, compared with 14% on the pre-2012 visa; 96% were not allowed out of the house unsupervised, compared with 44% under the old system; and 74% faced psychological abuse, compared with 28% before 2012.

One obvious solution would be to formally abolish the system that ties overseas domestic workers to one employer. However, unlike the governments of Bahrain and Qatar, the UK government seems hesitant to do so. A compromise, therefore, might be to replicate the provisions already available for victims of domestic abuse on the UK partner’s visa, who can apply for three months leave to remain, while they resolve their situation or make arrangements to return home.

If Saudi Arabia decides to review its treatment of domestic workers, as it seems to be reviewing its treatment of bloggers, we could see it overtake Britain on domestic abolitionism. Either way, the issue remains unresolved in both countries. So before we compare ourselves too haughtily with the Islamic legal systems of blogger-flogging petro-states, we ought to consider that our legal provisions are no longer as incompatible as water and oil.

Michael Pollitt works as a researcher in the House of Commons. He tweets at @MJPollitt.