Modern Slavery and human trafficking is often hidden in plain sight, right in front of us.  The victims could end up working in car washes, nail bars and restaurants.  It’s important to be able to spot the signs. 

 

Under the Modern Slavery Act 2015 public authorities have a legal duty to report cases of suspected victims of slavery or human trafficking to the Home Office. Read the statutory guidance  here: Modern slavery: how to identify and support victims - GOV.UK (www.gov.uk) 

 

Trafficking is the movement of people by means such as force, fraud or deception with the aim of exploiting them. Human trafficking is often referred to as "modern day slavery."

 

• The act: recruitment, transportation, transfer, harbouring or receipt of persons. 

• The means: threat, force, coercion, abduction, fraud, deception, abuse of power or of a position of vulnerability; the giving or receiving of payments or benefits to achieve the consent of a person having control over another person. 

• The purpose: exploitation. 

 

Trafficking people is a criminal offence. The fact that the adult consents to the intended exploitation is irrelevant where any of the means (above) have been used.

   

Trafficking of children requires only the "act" and "purpose" above. The "means" does not have to be shown. 

 

• people facing poverty in countries of origin 

• people who are already victims of abuse in countries of origin and believe this behaviour of abuse, power and control to be 'normal' and for some it offers an improvement in their living conditions 

• learning disabled adults or children 

• orphaned children with no family support networks 

• minority groups 

• many victims have little or no education and are unable to read or write 

• socially excluded 

• dysfunctional families 

• those who won't be missed 

 

Possible indicators of abuse 

A person may be a potential victim of trafficking if one or more of the factors set out below is present when interviewed. Please note this list is not exhaustive:

Indicators of trafficking	• distrustful of authorities  • expression of fear or anxiety  • signs of psychological trauma (including post-traumatic stress disorder)  • the person acts as if instructed by another  • injuries apparently a result of assault or controlling measures  • evidence of control over movement, either as an individual or as a group  • found in or connected to a type of location likely to be used for exploitation  • restriction of movement and confinement to the workplace or to a limited area  • passport or documents held by someone else  • lack of access to medical care  • limited social contact  • limited contact with family  • doesn't know home or work address  • perception of being bonded by debt  • money is deducted from salary for food or accommodation  • threat of being handed over to authorities  • threats against the individual or their family members  • being placed in a dependency situation  • no or limited access to bathroom or hygiene facilities
Indicators of forced labour	• employer or manager unable to produce documents required when employing migrant labour  • employer or manager unable to provide record of wages paid to workers  • poor or non-existent health and safety equipment or no health and safety notices  • any other evidence of labour laws being breached  • no or limited access to earnings or labour contract  • excessive wage reductions  • dependence on employer for a number of services for example  work, transport and accommodation  • any evidence workers are required to pay for tools, food or accommodation via deductions from their pay  • imposed place of accommodation
Indicators of domestic servitude	• living with and working for a family in a private home  • not eating with the rest of the family or being given only leftovers to eat  • no proper sleeping place or sleeping in shared space for example the living room  • no private space  • forced to work in excess of normal working hours or being 'on-call' 24 hours per day  • employer reports them as a missing person  • employer accuses person of theft or other crime related to the escape  • never leaving the house without employer
Indicators of sexual exploitation	• adverts for sexual services offering women from particular ethnic or national groups  • sleeping on work premises  • movement of women between brothels or working in alternate locations  • women with very limited amounts of clothing or a large proportion of their clothing is 'sexual'  • only being able to speak sexual words in local language or language of client group  • having tattoos or other marks indicating 'ownership' by their exploiters  • person forced, intimidated or coerced into providing services of a sexual nature  • person subjected to crimes such as abduction, assault or rape   • someone other than the potential victim receives the money from clients  • health symptoms (including sexual health issues)  • signs of ritual abuse and / or witchcraft (juju)  • substance misuse

 

 

Discussing the situation or seeking advice from a specialist agency may be useful. The Salvation Army has been commissioned by the government to provide specialist help including safe housing to victims. They can be contacted on their 24 hour helpline Telephone: 0300 3038151. There are a limited number of agencies who are empowered to report the victims circumstances themselves to the National Referral Mechanism (NRM) using the standard required form. These agencies are called first responders and include, Local authorities, UK Border Agency, National Crime Agency, Refugee Council, New Pathways, Gangmasters Licensing Authority, UK Police forces, Barnardo's, Migrant help, Kalayaan, Home Office, Medaille Trust, Salvation Army, Unseen, NSPCC.

 

Being a first responder, public authorities have a duty to refer ALL potential victims of Modern Day Slavery to the Home Office by following this link, Report modern slavery. Do not assume that other parties will make the referral if they are already involved. 

 

For adult victims, there is a national system for reporting which involves reporting the information to a section of the National Crime Agency called the NRM (National Referral Mechanism) and secondly accessing specialist help from the Salvation Army. Consent must be obtained from the person to refer them to the NRM. Where the adult does not give consent to raise the referral, you MUST STILL refer them under the Duty to Notify regulations 2015 following the same link. 

 

The information that must be provided within a notification has been set out in the Modern Slavery Act 2015 (Duty to Notify) Regulations 2015. The notification must not include information that identifies the victim or enables the victim to be identified if they have not consented to the referral. 

 

Duty to Notify form is to be completed where the person has not given consent to a referral to the NRM.

 

This information should be provided as soon as practicable. Unless there are exceptional circumstances, this should be within a month of encountering a victim.  Where a victim needs assistance it is essential to access help from the Salvation Army without delay. The Salvation Army now has a dedicated team to provide assistance with completing the NRM notifications. Salvation Army will also be automatically notified once a NRM notification is raised and can help supporting the victim. 

 

• Referral to the NRM will need to be made first but the Salvation Army can assist with this if the agency referring is not a first responder. 

• The Salvation Army can conduct immediate needs and risk assessments by phone, or face to face. 

• The Salvation Army and its partner agencies can also provide accommodation, often at short notice. Accommodation is usually provided out of area, to protect the individual. 

• If no need for accommodation is identified, the Salvation Army can advise what outreach support it can provide. Outreach support is available where the individual already has suitable accommodation or is eligible for accommodation from another source. 

• Where adults identified as potential victims have children who are not victims of trafficking the Salvation Army will accommodate the children with their parent/s. 

• The Salvation Army can, if necessary, arrange for urgent medical needs to be met and for the individual to be transported to a place of safety. 

• Once the potential victim enters the Salvation Army service, he / she is allocated a support worker and has a comprehensive assessment and support plan. 

 

• Make an anonymous referral which will help the police to understand the level and type of trafficking and may link into other cases they are investigating. 

• Give the victim advice about sources of support.  Here is a good advice leaflet for the victim which is available in different languages and can help you reassure the victim about what help they can receive. 

 

Once the NRM receive a referral they will make a provisional decision as to whether the individual is a victim of trafficking or not within 5 days. The Salvation Army will normally wait for this decision before providing assistance unless help is needed urgently. After making their provisional decision the NRM then undertake their own formal investigation. This is known as the "recovery and reflection period". They will make a final decision regarding whether there is sufficient evidence of trafficking usually after a minimum of 45 days. During this time the victim is eligible for help from the Salvation Army which includes longer term planning/advice.

 

• a referral cannot be made to the NRM unless the adult gives informed consent to the referral. Duty to Notify should still be completed in this case. 

• support is provided centrally, not locally by the Salvation Army and its partner agencies. It includes the right to protection from retaliation, intimidation and the risk of being re-trafficked; compensation; counselling and legal advice 

• the individual should also be told that, during this 45 day period no action shall be taken to remove the individual from this country 

• assistance to the individual shall be provided irrespective of whether the potential victim is willing to act as a witness in criminal proceedings against the alleged perpetrator 

• you should explain to the individual that if he / she, after the 45 day period has expired, is not found to be a victim of trafficking, and has no other lawful entitlement to remain, there is a risk that the individual may not be able to remain in this country 

• you must engage the services of a suitable interpreter

• be aware that the individual may not realise he /she is a possible victim of trafficking. For example, sex workers may believe they are in love with their trafficker; may have feelings of dependency towards the perpetrator or may be accepting of their situation. They may not realise that their treatment is abusive or, potentially, criminal 

• the alleged perpetrator may have threatened the individual (or the individual's family "back home") with violence or financial repercussions if the individual exposes the trafficking to the authorities 

• it is possible for workers to challenge an NRM decision either provisional or final if they believe certain relevant factors have not been properly considered/ taken account of. It may be helpful to discuss the decision and reasons for challenging it with the NRM or Salvation Army or seek legal advice 

 

You should presume that an individual has capacity to consent to a referral to the NRM. 

BUT If there is a reasonable belief that the person lacks capacity to make an informed decision (unable to use, retain or weigh up the information to consent to a referral), you should make a best interests decision and refer to the NRM on behalf of the individual. You MUST also complete a capacity assessment. Capacity is time and decision specific. 

 

A child does not need to consent to the referral into the NRM. Once a potential child victim is identified, you should immediately contact Children's Services and request a social worker to complete the NRM referral form. Unaccompanied child victims of trafficking need specific assistance and support due to their situation and particular vulnerability. 

 

Children's services contact:

Telephone: 020 7527 7400 or email csctreferrals@islington.gov.uk

 

• access to interpretation and translation 

• help to access medical treatment, counselling and legal advice 

• support to engage with criminal proceedings against the alleged trafficker or to claim compensation 

• support to move on effectively from the service. This may involve practical support to return home (if the victim chooses) or to secure housing, state benefits, employment, education and training  

 

An individual can be referred into the NRM and Salvation Army even if he/she is no longer being trafficked, provided there is evidence that he/she has been trafficked in the past. 

 

Each case will be dealt with individually, depending, for example, on the victim's individual circumstances level of trauma that has been suffered and level of need. If a victim wishes to return to his/her own country, the Salvation Army can assist with this.  If the victim wishes to remain in this country, the Salvation Army can provide practical assistance, such as help with applying for benefits, housing etc

 

If, after the recovery and reflection period has expired, the individual is not identified as a victim of trafficking, there is no obligation, either centrally or locally, to continue providing assistance and support to that person (unless there are other statutory obligations to do so). Remember to record your decisions, reasons for your decisions and any action taken.

 

Some adults are at greater risk of modern slavery due to their age, disability or ill-health.  In all cases of trafficking, forced labour or domestic servitude, a safeguarding concern must be reported if the victim is an adult with care and support needs as defined in the Care Act 2014. Find Your Islington | Islington Adult Social Care First Point of Contact . It is essential to keep the person at the centre of a safeguarding enquiry and consult with them about what is important to them.  This is in line with the Making Safeguarding Personal approach.

 

Seek advice from Adult Social Services by completing the safeguarding concern form Find Your Islington | Islington Adult Social Care First Point of Contact

Alternatively, call the Human Trafficking Helpline UK, which was set up by the government as part of a campaign to end modern slavery. This is mainly intended for the general public to report possible concerns’ and seek advice or help. But professionals can also use the helpline.

 

The Home Office has launched a Modern Slavery Training programme for First Responders that provides guidance on how to spot the signs of modern slavery, and what to do when you come across a potential victim of modern slavery. This can be accessed here. You are encouraged to complete this online training. 

 

The Islington Modern Slavery Board was one of the first to be set up in the country.  We are proud to be part of the working together with local partners in improving awareness and local modern slavery responses.

 

The Human Trafficking Foundation grew out of the All-Party Parliamentary Group on Human Trafficking and Modern Slavery with three objectives which can be summarised as: 

• Shaping policy and legislation 

• Providing a sustained and collective voice in fighting modern day slavery 

• Identifying opportunities for new and different types of intervention 

 

The Human Trafficking Foundation has some very useful resources on their website on a range of topics.  Topics covered include guidance for Ukrainian nationals arriving in the UK and for hosts under the Homes for Ukraine scheme Ukraine Response — Human Trafficking Foundation 

 

• Lincolnshire Safeguarding Adults Board review into large scale modern slavery: LSAB - Large Scale Modern Slavery in Lincolnshire – Lincolnshire County Council

• Skills for Care videos to support health and social care employers, especially when recruiting internationally.

• The Local Government Association published guidance on modern slavery has been developed specifically for council officers leading and working in homelessness and housing services.

• The Gangmasters and Labour Abuse Authority site – which works to prevent exploitation of workers and vulnerable people.

• The Salvation Army has many resources on their website, including many case studies: Supporting survivors | The Salvation Army

• There is more information and guidance about the NRM on the government website: Support for modern slavery victims

• This useful leaflet has a quick guide on the Duty to Notify and a flowchart to help understand the process.