Examination of witnesses

Eleanor Lyons, Alex Murray and Phillip Holliday.

Q52 The Chair: I welcome you to the 16th meeting of the Joint Committee on Human Rights. As the name of the committee implies, we comprise 12 members drawn from both Houses of Parliament, six from the House of Commons and six from the House of Lords, and from a variety of different political traditions. Today is our 16th meeting of this session, and we will be hearing from three witnesses as part of our inquiry into modern day slavery and supply chain transparency. We have received over 800 pages of written evidence and 20 of those submissions will now be published on the committee’s website, with many more to follow as we near the point of writing our report and advising Parliament and the Government of our findings and recommendations.

Today we will hear from Ms Eleanor Lyons, who is the Independent Anti-Slavery Commissioner, Mr Alex Murray, who is the director of threat leadership at the National Crime Agency, the NCA, and Mr Phillip Holliday, who is the central region director of Border Force. We welcome all three. They will be helping us to delve deeper into the nature of modern day slavery within the supply chains, the very things that feed into the commodities that we buy in our shops, stores and online.

During today’s hearing, members will have the opportunity to analyse how the UK’s current legislative and regulatory framework is responding to the risks of forced labour in supply chains and explore the potential impact of approaches such as import bans and mandatory human rights due diligence.

The Office of the Independent Anti-Slavery Commissioner was established by the Modern Slavery Act 2015. The commissioner is tasked with encouraging good practice sharing among all those with a role to play in tackling every aspect of modern slavery and human trafficking within the United Kingdom. The NCA is the UK’s lead agency against organised crime, human, weapon and drug trafficking, cybercrime and economic crime that crosses regional and international borders. It houses the National Economic Crime Centre, a multiagency centre established in 2018 to deliver a step change in the UK’s response to economic crime, building on the Joint Money Laundering Intelligence Taskforce. Border Force is a law enforcement command within the Home Office. It acts to secure the United Kingdom’s borders and to oversee the entry of goods and people into the United Kingdom. Border Force carries out customs duties, searching for and confiscating goods deemed to be illegal or harmful.

None of these bodies, it should be pointed out, holds clear responsibility for addressing forced labour in supply chains, and the committee will explore how the duties to investigate and monitor forced labour should best be met and whether new statutory approaches and new oversight might be needed.

Let me briefly say something about our three witnesses. Eleanor Lyons, the Independent Anti-Slavery Commissioner, is the UK’s independent commissioner established by the Modern Slavery Act 2015 to encourage good practice sharing among all those with a role to play in tackling every aspect of modern slavery and human trafficking in the country. Prior to becoming the commissioner, Eleanor was Deputy Children’s Commissioner, advocating and championing the rights of children in England, but particularly those who were vulnerable in care or in contact with social services.

Mr Alex Murray, the director of threat leadership in the NCA, joined as director in September 2024. His role sees him leading the agency’s modern slavery and human trafficking threat leadership team, among others. He is a former temporary chief constable at West Mercia Police, where he previously undertook both uniform and CID roles. He has also led teams in the Metropolitan Police, including cyber, modern slavery and human trafficking and online child sexual exploitation. Alex has experience within both counterterrorism and intelligence as a senior investigating officer.

Mr Phillip Holliday, the central regional director of Border Force, has responsibility for activity at all central region maritime ports, airports and postal depots. He has the national strategic lead on rail freight, fast parcels post and inland preclearance and is the operations lead on digital passenger services. Phillip is the Home Office national stakeholder, the lead with easyJet and Ryanair, and on people matters he is the Border Force disability champion. Working for Border Force and its predecessor organisations for some 37 years, he has been in his current post since 2011.

Let me begin with the questions, after which I will turn to my colleague Dr Peter Swallow to open up some questions on enforcement. I would like to ask about protecting British consumers. My first question is to Mr Murray and then I will turn to Ms Lyons. Is profiting from forced labour an economic crime or a crime against humanity, or is it both?

Alex Murray: Yes, I think that you bang the nail on the head, Chair; it is both. Clearly, it is an economic crime. What is the motivation behind people involved in modern slavery? It is largely economics, either realising the value of owning a slave or treating someone unfairly and profiting from that. Similarly, it is clearly a human rights abuse of having someone’s liberty taken away from them and everything that comes with that.

The Chair: That is clear and sharp. Thank you very much for that response. Let me turn to Ms Lyons. Do you think that it is likely that goods linked to forced labour are being sold to British consumers in the United Kingdom today?

Eleanor Lyons: Sadly, it is the case that goods made with forced labour are currently being sold to consumers across the country. I think that consumers themselves would be very concerned about it, but the onus cannot sit with them to make this change. We need businesses to show leadership in this space, and some already are. Alongside that, I think that it is time also that the Government act to catch up with international partners and introduce new legislation to put in place more protections to stop goods linked with forced labour coming into the United Kingdom.

The Chair: Thank you very much. We will delve deeper into some of what you have said to us already, but I turn now to Dr Peter Swallow.

Q53 Peter Swallow: Mr Murray, are our existing legislation and statutory powers available to the National Crime Agency strong enough to allow companies and individuals to be held accountable for criminal activity linked to profiting from forced labour?

Alex Murray: That is a very good question. We largely operate under the Modern Slavery Act 2015, but also the Proceeds of Crime Act, where the definition of money laundering is very helpful. Under Section 329, anything that has been obtained from a criminal endeavour, such as forced labour or modern slavery per se, can be conceived as money laundering. The legislation is there. Proving forced labour in a supply chain, as you have seen in all your previous committee meetings—I have had the privilege of reading some of the notes from them—is very difficult to demonstrate. That will always be a challenge for law enforcement.

Peter Swallow: In making that easier for you, should the Government be looking to reform the Modern Slavery Act or introduce new legislation, or both?

Alex Murray: One of my teams specialises in modern slavery. They think that the Modern Slavery Act is really progressive and that it was ground-breaking. I think that to a large extent it was and it was world leading. Obviously, there are people here better qualified than me to comment on it. It is not necessarily a problem with the legislation but the interpretation and adoption of the legislation by all law enforcement agencies. Modern slavery can be treated as modern slavery, or it could be dealt with under different legislation controlling prostitution, assaults, all sorts of different things. Different law enforcement agencies will have different approaches to adopting that legislation.

The Chair: Thank you. Mr Sobel wants to ask you more about enforcement, and then we will return to my colleague Lord Murray.

Q54 Alex Sobel: This may be one for Mr Murray and for Ms Lyons as well. We had the news overnight that some of the members of the committee were pursuing GB Energy. First of all, Ms Lyons, do you feel that current enforcement of the existing legislation concerning the prevention of modern slavery and supply chains is effective?

Eleanor Lyons: There are different pieces of legislation that aim to tackle forced labour and supply chains, which all touch different elements of the problem we are talking about. We have the Modern Slavery Act, which 10 years ago, as Mr Murray has mentioned, was world leading. It put the conversation in boardrooms and it saw businesses step up their game in tackling transparency in supply chains. We have seen responsible actors respond to it. However, when we are talking about forced labour, that piece of legislation lacks teeth. It lacks accountability. We also have not seen strong enforcement when it comes to making bad actors respond.

We of course also have other pieces of legislation, such as the Procurement Act and the Proceeds of Crime Act, but what we are missing is one overarching piece of legislation in this country that makes it clear that goods with forced labour will not be tolerated in the United Kingdom. When it comes to the operation of it, enforceability matters. I therefore welcome the committee’s work and the changes to the Great British Energy Bill. As part of the amendments that the Government have made, we really need to see that come to fruition now and to have meaningful impact on not sourcing goods made with forced labour.

Alex Sobel: Just on that point, the Government are going to put down an amendment that effectively means that GB Energy will have to enforce measures to ensure that slavery and human trafficking are not taking place in its business supply chains. Do you think that that will be effective?

Eleanor Lyons: I hope that it will be effective. It is important that this amendment has been laid, and there is a job for us all to hold the Government to account on that amendment. There are learnings we can take from other international partners in this space where they have had things such as rebuttal presumptions and the burden of proof not sitting on government and procurement officers to demonstrate that goods are made with forced labour. It is a very welcome step and I hope it will make a big difference.

Q55 The Chair: I think that we have all been struck that the principal author of the 2015 landmark legislation, as it was then, Baroness May, Theresa May, has made it clear that she thinks that there needs to be a review and reform of that Act. To just delve a bit deeper into what you have just said, should there be a completely new Act or can Section 54 and so on be reformed, maybe with the insertion of a rebuttable presumption that you have just mentioned? What more should be done?

Eleanor Lyons: My view at a big-picture level is that the Modern Slavery Act is largely fit for purpose. It is a good piece of legislation. It has led the way and has been used by the NCA and other partners to make a real difference in this space. There are some parts of the Act, though, such as Section 54 and the transparency and supply chain section, that need to be looked at again and we need new legislation in that space. We probably need a whole new piece of legislation in the form of mandatory human rights due diligence to echo what we have seen the EU and what some of our other European partners are doing. I would not want to reopen the whole piece of legislation without looking at all the other sections of victim support and making sure that it can still do its role in that space, but when we look at Section 54, it needs new powers and new teeth added to it in a legislative form.

The Chair: Thank you very much, and thank you for being so publicly supportive of the all-party amendment that has led to the Government tabling their amendment in lieu of the ping-pong amendment, as it is described, that came back from the Commons. We are making progress, but it is incremental all the time. It is therefore very helpful to hear from people like you telling us what really needs to be done next. Let me turn to my colleague Lord Murray to ask the next round of questions.

Q56 Lord Murray of Blidworth: I want to turn the conversation to confiscation at the border, so this question is in the first part directed at Mr Holliday. To what extent could approaches for intercepting criminal property that are used at the border, such as for counterfeit goods, be used to confiscate goods linked to forced labour?

Phillip Holliday: At the moment there is no legislation that would allow us to do that. We work on behalf of HMRC and the Intellectual Property Office as regards counterfeit goods. The important thing to draw out is that for counterfeit goods, the value that Border Force brings is in looking at goods that are quite clearly counterfeit. We are looking at the quality of the goods and we can do that from physical inspection, whereas in extending it to forced labour goods, we will always have difficulty identifying it. How would we know by looking at a set of goods whether they are manufactured using forced labour? At the moment, we do not have any legislative vehicle for forfeiture and we would not be able to use the counterfeit goods legislation for that.

Lord Murray of Blidworth: On the Proceeds of Crime Act, there is an argument that could be advanced, is there not, that modern slavery is a crime and the money made from the sale of those goods would amount to a crime sufficient to use those powers?

Phillip Holliday: It is interesting you should raise that because, before the hearing, I was chatting to my NCA colleague, Mr Murray, and we were talking about the proceeds of crime. Indeed, Border Force does use the Proceeds of Crime Act when it is intercepting criminal cash outbound at the border. What we have not previously used it for is asset forfeiture and other goods that may be associated with crime. My understanding is that if we were asked to intercept something on behalf of another law enforcement body such as the NCA, we would be permitted to seize those goods at the border.

Lord Murray of Blidworth: You would be more comfortable having some fresh powers rather than relying on existing powers. Is that where you are?

Phillip Holliday: As I say, until I had this conversation with my NCA colleague this morning, I was not aware that it was potentially an option, so it is something that we could consider.

Lord Murray of Blidworth: Perhaps I might ask my kinsman, Mr Murray, to give us the NCA’s view on that.

Alex Murray: This comes under, as we mentioned, money laundering legislation. Obviously, you cannot own anything that has profited from a criminal offence, of which labour or sexual exploitation would be. I think that it is a legitimate position for us to go away and work with Border Force and HMRC to say, “Would this be a position that you could use at the border?” One thing that we do in the NCA is attempt to lead the system in the battle against slavery. We bring all agencies together. We have performance objectives. We do a lot of operations that I hope we will have an opportunity to speak about later. Border Force is a member of that, so we can work through that with Border Force.

Lord Murray of Blidworth: To what extent do you think there could be identification of goods linked to forced labour derived from intelligence that you have which is then circulated to other authorities?

Alex Murray: That is a good question. Again, to refer back to your last session, you heard lots of evidence on how difficult it is to understand supply chains, particularly international supply chains, and how goods themselves can be laundered. If you have a widget from area A, has it been aggregated by a wholesaler in area B and then purported to be a legitimate item that then arrives at the border? There will not be an item that says, “This was made by forced labour” so somehow you need to deduce that it has been made by forced labour. It is an intelligence question, and I know that the Border Force intelligence agency, HOI, is very good at fusing data and making assertions and directing personnel. Similarly, HMRC has lots of capability in that space. It would be a challenge for intelligence agencies, which people would try to get around, but it is a challenge that I think we should stand up to.

The Chair: Mr Swallow has a supplementary on this.

Q57 Peter Swallow: Mr Murray, I want to ask for clarity on whether those powers under proceeds of crime would be exercisable regardless of whether there was evidence of the use of modern slavery in this country and supply chains here or in goods imported from overseas where there was evidence that that had been the case in other jurisdictions.

Alex Murray: It is a good technical question. I am tempted to say yes, just because when I think about the Modern Slavery Act, unlike POCA, it applies to any slavery anywhere in the world. You would like to think that the predicate offence, which is slavery anywhere in the world, as defined by the Modern Slavery Act, would therefore justify Section 329 of POCA where you come in and say that is money laundering.

Peter Swallow: This is untested ground, as it were?

Alex Murray: No, it is not untested, it is just not in my brain. It may be untested, but it is a technical, legal question that I would need to get back to you on.

The Chair: It would be very helpful if you could write to the committee about that because we would want to include a reference in our report.

Alex Murray: Yes, I will.

The Chair: Thank you. Just before we leave that and I turn to Ms Campbell, who will ask you some more questions around financial reporting, can I ask about the Proceeds of Crime Act that you have referred to? We heard evidence from Rahima Mahmut from the Uyghur organisation, who had successfully gone to the High Court and won using the proceeds of crime legislation. Do we see that as an increasing route for the pursuance of people who are bringing goods made by slave labour into the United Kingdom? Secondly, does Border Force have sufficient capacity, not commitment but capacity, to deal with all these new routes that we are told are opening up using small regional airports and railway links across Europe, bringing in goods in container lorries and so on? It is not just a question of theoretical supply chains. These are large amounts of goods. What capacity do we have to track this stuff down?

Alex Murray: As a small correction, I believe that it was the Court of Appeal that made the distinction on what is considered by law a defence to Section 329 of the money laundering Act, which is adequate consideration. That means a good is not cleansed just because you paid a reasonable amount for it. I welcome that, by the way, and it is useful. That provides a lot of clarity for businesses on what adequate consideration is, which is helpful.

Phillip Holliday: Chair, you raised an interesting question there and there are two elements to the answer. One is around the competing priorities that Border Force currently has, and then there is also the practical realities, the logistics of applying these controls at the border.

On the priority side of things, we currently work on behalf of about 20 different organisations at the border. Some of those are using our own powers, some are doing things on behalf of others and some represent others but use their own powers, so it is quite a complex picture in itself. There is also a question around whether ports are the right place. They are a natural pinch point, and you can see the attractiveness and why ports might be chosen. They are also very busy spaces and a lot goes on in a port. The other thing we need to be mindful of is the impact on legitimate flow of cargo. There is always that tension that we are operating within.

On the way that border controls are set up in the United Kingdom, you might recall that back in 2009 the UK Border Agency was set up with a subset of HMRC. We moved across, 4,000 of us, to the Home Office to create the UK Border Agency, which then became Border Force, merged with the Immigration Service. That was essentially to provide an operational, feet-on-the-ground, physical response to examinations of goods and people at the border. However, HMRC remains the customs authority for the United Kingdom. It retains the policy on customs. All import entries that contain the information about where the goods have come from and who the importer is also go into HMRC. Some of the goods cross the border without a formal entry being put in. It is often that the goods come in under different processes, such as for inward processing or various other reliefs. They get taken to a trader’s premises and then an import entry might be put in at that point. HMRC also does a lot of work post importation and lots of paperwork checks.

There is a question around if import controls were appropriate, where that would best be placed, or best be done. There is the power to seize in situ. If goods get transported to a trader’s premises, the Government have the power to seize those goods in situ, which avoids problems around damages potentially being incurred at ports. It also avoids significant demurrage costs and the costs that ports impose on goods that are detained within the port environment.

Then, to swing back to the original point around our priorities, like all government organisations we are reducing in size. We have to make difficult decisions around our priorities. We weigh up all these various priorities. There are things that we have had to turn down of late while we focus our efforts on the high-threat, high-harm stuff that is targeted on our border.

The Chair: That is helpful. Thank you very much. Let me turn now to Ms Campbell and after that we will hear from Lord Dholakia.

Q58 Juliet Campbell: My question is for Mr Murray. There is an established financial reporting regime where there is an obligation on relevant institutions to share suspicious activity reports. These are shared with law enforcement in cases of suspected wrongdoing. Could the SARs regime be extended to include cases of suspected forced labour?

Alex Murray: It should do and it does. It is a criminal offence. The UK FIU, the Financial Intelligence Unit, shares information with designated bodies to say, “These are the signs of human trafficking and forced labour that you should look for, and when you see it, please send us a suspicious activity report”. Suspicious activity reports for modern slavery and human trafficking come in every day, thousands of them every year, which the UK FIU looks at. Then when it senses that there is a significant case, it will give it to the relevant law enforcement agency.

Training is given by the UK FIU to banking and other regulatory agencies on how to spot modern slavery and human trafficking. It is a bit of a challenge because a lot of it is in cash, as we know, but I am glad to say that thousands and thousands of SARs are given to us every year with modern slavery and human trafficking as a marker from it.

Juliet Campbell: Do you think that using that intelligence would help us to reduce money laundering and disrupt that criminal activity?

Alex Murray: Yes, to a certain extent, and it has done. We make hundreds of disseminations, largely to police forces, saying, “Here is a suspicious activity report. It looks like there is some modern slavery going on here. Please can you investigate?”

The real challenge, as many of us will know, is that for low complex modern slavery human trafficking issues, cash is king. There is Hawala banking. There is underground Chinese banking. There are things like exchanging goods: I will buy a nice watch and I will take it and sell it in another country. This is the challenge for us and it is in fact why the NCA co-ordinated work with trading standards and police forces in March, only last month, to raid all sorts of high street establishments which we had suspicions about being cash rich, which could be from money laundering for any crime type, including modern slavery and human trafficking. In fact, across the country, 97 people were safeguarded who were potentially victims of human labour abuses. Money was seized and we found cannabis farms; these were all places like barber shops, vaping shops, beauticians and nail bars—places that we have seen that deal in cash, where people can launder their own proceeds through, in any case, and exploit people working in them.

The Chair: Thank you. Obviously, there is a lot of money being made in this, and Lord Dholakia wants to ask you about that.

Q59 Lord Dholakia: My question is also directed to Alex Murray. Is addressing profit made from forced labour a proprietary threat under the NCS strategic plan?

Alex Murray: Yes, it is. Modern slavery and human trafficking is a threat made clear to us by our director-general but also by the Home Secretary. It is a primary threat that we deal with; so, yes, it is associated. The illicit finance associated with modern slavery and human trafficking as an explicit adjunct to that is not, but with any investigation or priority area that we look at, like modern slavery and human trafficking, there will always be a financial angle to it.

There is an example of a UK Nigerian nurse—I do not know if you recall this one—who was taking people from Nigeria and using them as sex workers in Europe, but she was profiting here. The investigation was conducted by the NCA and £180,000 was taken from her that she had made from that illegal criminal operation. Although illicit finance is not explicitly a priority for modern slavery and human trafficking, modern slavery and human trafficking is and, as an adjunct to that, illicit finance is associated with it.

Q60 The Chair: Before we return to issues concerning potential solutions, can I ask Mr Holliday a question about the UK’s sanctions regime and whether perhaps that should be used against those who are engaged in selling goods linked to forced labour?

Phillip Holliday: It is not an area that I am very familiar with, I am sad to say. I know that, on UK sanctions, we are looking at outbound strategic exports. We do manage controls on that. I am not aware of how those powers might be used for inward-bound goods.

The Chair: Ms Lyons, have you been able to give this any thought?

Eleanor Lyons: Are you referring to things like import bans, essentially?

The Chair: Yes, potentially.

Eleanor Lyons: Import bans can be an important enforcement tool when it comes to tackling goods entering the United Kingdom with forced labour. I think that it is something the UK Government should be looking at, and I have been speaking to them about it in role for the last year and a half. Which specific bit were you referring to?

The Chair: I do not want to go deeper into that because I know that Sir Desmond Swayne will ask you in a moment more about import bans. I was thinking more about the sanctions regimes generally that the UK has in place around individuals who are found to have committed various other crimes. Do you feel that this should be part of that package of things that could be done against people who commit modern slavery violations?

Eleanor Lyons: It is absolutely worth looking at it within the sphere of what tools we have to stop forced labour goods entering the United Kingdom. If we are going to tackle this problem effectively, we need to look at trade deals, sanctions, import bans, new legislation in the form of mandatory human rights due diligence, every tool that we can possibly use, because it is such a complex area that touches the actions of multiple different government departments and government bodies.

The Chair: Thank you. We will turn now to Sir Desmond, who will take this issue further. After that we will hear from Baroness Lawrence.

Q61 Sir Desmond Swayne: I am interested in this question of import bans and whether such bans might make the plight of victims even worse. Is that possible? How would it be possible?

Eleanor Lyons: A lot of thinking needs to go into preventing unintended consequences when it comes to import bans. One unintended consequence can be that we cut off a supplier, the workers lose out and a new supplier pops up and is used instead, but it may still have similar risks. There are ways around that, though, when worker remediation is built into import bans and strong structures are in place, when initially they encourage businesses and suppliers to work closely with workers and to make sure that they address some of those problems and risk areas.

On the whole, import bans are important when we are looking to have an enforcement tool and need to make it clear that other actions have failed in this space. This is particularly important in areas where there is state-sponsored forced labour. On the whole, they can do more good than harm when they are effectively implemented. However, if we look at other international partners, whether it be America or the EU, they have adopted different models for how they would go about an import ban. We can learn stuff from those different partners that we would maybe take forward in a piece of UK legislation.

Sir Desmond Swayne: If we got to the stage where we were going to have an import ban and you had to enforce it, Mr Holliday, what would be the practical implications for your organisation and its resourcing?

Phillip Holliday: The first question is about who is best placed to manage this process. As I mentioned earlier, the information on what the goods are and where they come from—assuming it is correctly declared, of course—goes to the national clearance hub at Salford, which is HMRC’s import entry centre. In turn, it applies profiles and can identify entities of interest and countries and places of origin.

The question then is what value is added by, say, Border Force examining those goods at the border, as opposed to the goods maybe being inspected by way of looking at the paperwork, asking for proof of origin and how they have been manufactured? As I said earlier, Border Force was set up where doing a physical examination would confirm or deny that something is of interest. If it is an illicit substance, if it is cocaine or whatever, we can clearly find it is cocaine. If it is counterfeit goods, by examining it we can confirm whether it is of inferior quality and we can make a judgment around whether that is counterfeit goods. From an HMRC perspective, if we think the goods might be misdeclared, we can examine the goods to see whether they are declared correctly and their description matches what is on the import entry. When it comes to this particular subject, the question is whether the best way of enforcing it is by Border Force examining the goods. What more would we gain from doing that?

The challenge you then have is that, by examining the goods at the border, you add to the volume of interventions that are already carried out at the border. It is not just by Border Force but by the Animal and Plant Health Agency and all the various other organisations that operate at the border. If we come to seize the goods, how do the seized goods get stored? There are then the associated costs that the ports impose on the importers while they are stored.

A constraining factor is the examination facilities. The amount of infrastructure available in ports is quite limited and all the various agencies have competing demands. The bottom-line question would be: what is the optimal way of confirming the origin of the goods? It probably is not a physical inspection of the border. It is probably looking at the paperwork and identifying individuals of interest through the paperwork as opposed to examinations.

Sir Desmond Swayne: Clearly, examining it will not tell you how it was made—or it is unlikely to—so you would be looking at some sort of intelligence resource. Would that be the National Crime Agency?

Alex Murray: Yes. How do you determine where something is from and whether it is from human trafficking or labour abuse? That is the question. As you have seen from previous testimony here, it can be scientific, DNA-related, which itself is often quite contested. Does it come from a part of the world where you may say, for example, the majority of goods are from forced labour? Otherwise, we have to work back and understand how this supply chain operates, which would be an intelligence operation either for Home Office intelligence that serves Border Force, for HMRC intelligence, or indeed for NCA, which also has intelligence officers.

Sir Desmond Swayne: Would it be fair to say that an import ban is far from straightforward?

Eleanor Lyons: It is fair to say that it is far from straightforward. However, we have seen it operationalised in other countries. It is resource-intensive, as we have heard from Border Force. However, we have seen that, where it works well, such as with the CBP in America, it is because it also works in conjunction with listening to law enforcement and listening to NGOs, with data sharing and partnerships with other organisations that can help support the work of Border Force. It is a big ask for Border Force to do it alone. It also needs to be complemented with other measures such as corporate accountability and strong labour market enforcement domestically, but it is potentially a tool that this Government should be looking moving forward.

We need to ask ourselves the question because, if the EU and America are doing this, we do not want to be a dumping ground for all the goods that are not going into those markets. We need to look at that.

The Chair: Thank you. Baroness Lawrence has a supplementary on this. Then we will hear from Mr Afzal Khan.

Q62 Baroness Lawrence of Clarendon: You have answered part of my questions already and so I will go to a short one. How could an import ban be resourced and enforced, for example, from penalties charged to corporations and importers? That is to Mr Holliday.

Phillip Holliday: Is your question how could the import ban be reinforced with penalties?

Baroness Lawrence of Clarendon: How could it be resourced and enforced through penalty charges to corporations or importers?

Phillip Holliday: It is a great question, probably not one for me to answer. The Department for Business and Trade possibly may be able to answer that because it has been looking at penalties. It could potentially be a revenue stream, to potentially offset. That is all I can advise. I have no expertise or knowledge of this area.

Baroness Lawrence of Clarendon: Any other colleagues?

Eleanor Lyons: I have spoken to the Department for Business and Trade about what penalties could be in place when looking at the issues of import bans. There is a general reluctance to introduce them due to some of the constraints that we have spoken about, but they are useful for making it clear to companies and businesses that are bad actors potentially or have forced labour in their supply chains that this is unacceptable practice.

One thing that businesses respond well to is charges against their bottom lines. That is why the measure of having penalties in place can complement an import ban. Some of our other partners have looked at this area and have some penalties in place. Stuff like money laundering is taken so seriously by businesses because they understand, at a corporate C-suite level, the consequences of having money laundering within their business.

The challenge we have when we are talking about forced labour is there is not as clear a consequence for businesses in this space. The Government need to make it clear that it is an unacceptable practice. I will caveat that, though. I have worked with some businesses that are leading the way in this. They go further than the Government ask them to. Of course, their international supply chains are affected by international legislation and they go above and beyond what the United Kingdom legislative framework currently demands.

Baroness Lawrence of Clarendon: Mr Murray, do you have anything to add to that?

Alex Murray: I cannot comment on import bans, but I can provide a parallel insight. One threat area I look at is firearms. We have demonstrated that a type of firearm called a top venting blank firearm, a blank firer, can be easily converted to become a live firearm. Therefore, it is illegal. We have spoken in the firearms world to the importers to say, “You are now importing illegal firearms and, if you continue, we will prosecute you”. They have stopped. All those illegal firearms coming into the UK that are easily convertible are no longer coming into the UK. It is a parallel insight, but whether we should have bans and the capacity and the punishments are probably, as my colleagues have said, not for the NCA to comment on.

The Chair: Thank you very much. Mr Khan and then we will hear from Mr Tom Gordon.

Q63 Afzal Khan: Ms Lyons, in your view, should the UK impose mandatory human rights due diligence on British companies and, if so, should this apply to companies of all sizes or should the UK follow the EU’s approach to big companies only?

Eleanor Lyons: The United Kingdom Government should introduce mandatory human rights due diligence. In my mind, this is the bare minimum of the new legislation that we need to tackle this issue of forced labour.

As I have outlined, lots of businesses—and lots of leading businesses—are calling for this, too. I work with businesses that want the Government to introduce this legislation. They want a level playing field and for their efforts tackling forced labour in their supply chains to be acknowledged and for those who are not doing it to address those problems within their supply chains. It should be applicable to businesses of all sizes, including SMEs. I work with SMEs that would welcome that legislation as long as it is proportionate, risk-based and in line with the UN guiding principles in this space.

The EU’s approach to phasing in the legislation is right. They are going after big companies first and then legislation will be applied to the SMEs two or three years later. That is the right way to go about it. We absolutely need this legislation and we are behind in not having it in this country.

Q64 Tom Gordon: This is to Mr Holliday. How has the newly enforced Procurement Act impacted your own organisation's procurement activity? Has any training been given on how the Act should impact organisational decision-making?

Phillip Holliday: In short, that is not my area of expertise as I am here representing Border Force operationally. I know that, within the Home Office, that Act has been enacted, but I have no briefing on how it is applied within the wider Home Office. Sorry, it is not my area of responsibility.

The Chair: Can I press you on that? I was involved in amendments to the Procurement Act at the time and particularly the impact that it could have on issues around modern slavery. Would it be possible, returning to the point Mr Gordon has made to you, for you to write to the committee subsequently if you can establish any information about how the Procurement Act has impacted on the work of Border Force or indeed might add as well to the NCA and whether you have noticed any significant differences that have occurred since the enactment?

Phillip Holliday: Yes, I can.

The Chair: Thank you.

Alex Murray: In the NCA, our procurement department has done quite a lot of socialisation in the wider NCA around what has changed and what is required. An internet presence and knowledge drop videos have demonstrated what the Procurement Act is, what it is here for, the simplifications required to ensure that we do not have forced labour in our own supply chain in the NCA. The Government in fact have quite a few good knowledge drop videos on the Procurement Act, which is useful.

The Chair: That is helpful to know, thank you. It is Baroness Lawrence now and then we go to Mr Sobel.

Q65 Baroness Lawrence of Clarendon: My question is to Ms Lyons. Will public procurement decision-makers be able to implement the provisions of the Act effectively, for example the new discretionary exclusion criteria, which enable companies with unethical practices to be excluded from tenders?

Eleanor Lyons: It is important that public procurement is free from forced labour in the supply chains. That was one thing that was missing from Section 54 of the Modern Slavery Act. It has only recently been commenced in the last couple of months, so we are waiting to see the impact of it.

For me, one of the big learnings from the Modern Slavery Act is that how things are enforced and applied as legislation matters. I have read the provisions in the Procurement Act that apply to modern slavery and human trafficking and the policy notes that go with it. I have some concerns about the clarity and how easy it is to understand what steps procurement officers should take. I have concerns that, for instance, it is discretionary whether a business or supplier should be disbarred. It should be mandatory if we find evidence of forced labour in supply chains that they cannot supply to the Government or public bodies. They also speak about elements such as self-cleaning. It is not clear what self-cleaning looks like for the businesses, in my mind. It puts quite a big burden of proof on the procurement officer to make those decisions.

A couple of things need to be done. We need the strong training that we have heard the NCA has in place. The guidelines in the policy notes need to be clear. There needs to be strong leadership from the Government, the Cabinet Office and the procedural review unit that complements how the Procurement Act is now rolled out for it to have a meaningful impact in this space.

In my mind, we will wait to see how effective it is, but at the moment we are lacking some clarity in this space. Some elements in it, such as criminal threshold of modern slavery and human trafficking, are all well and good, but the prosecution rate under the Modern Slavery Act at the moment is around 2%. It is not easy to demonstrate a criminal threshold of forced labour. We have heard about the complexities in supply chains. Again, that is quite a high bar for disbarment when it comes to that Act. I potentially want to keep an eye on that, and I will be in my role.

Baroness Lawrence of Clarendon: Following on from that, you have mentioned some of what you think should be done. What can be done to ensure the Act’s new provisions are used to deliver effective impacts? What would you suggest that the Government need to do to make sure that is done?

Eleanor Lyons: Ultimately, the Government need to show strong leadership and accountability in this space. I am pleased that the Government have now made changes to the Great British Energy Bill and accepted those amendments, but it needs to be made clear that, as an absolute baseline, the Government do not want goods made with forced labour in any of their public procurement. This sits within the Cabinet Office’s remit. We need the CDL to take real leadership in this space and make sure that the Procurement Act and its rollout is a priority for that department.

The Chair: Thank you. We will return later to this question of who takes the lead and what they need to do about it, but let us go to Mr Sobel.

Q66 Alex Sobel: Mr Murray, data intelligence sharing is crucial to stop the flow of illicit goods into the UK. I know that in your Manchester office you host a branch of Interpol that works in this area. Do you feel that there are ways to improve collaboration, supply chain data and intelligence, first, to provide information to companies and the public around the flow of goods that may involve forced labour and, secondly, to identify wrongdoing at a domestic and international level?

Alex Murray: Thanks. The UK FIU is part of the Egmont group of FIUs that operate in 170 countries around the world. It is probably one of the busiest FIUs for passing intelligence to and receiving intelligence from other countries on all criminality and finance associated with it, including modern slavery and human trafficking. The number of requests that we make of Interpol and Europol and them of us is significant. I am pleased to say that we share an awful lot of intelligence.

Your point was less about intelligence sharing around modern slavery and human trafficking and more about supply chains. You are right that, because of the opaqueness of supply chains, the amount of intelligence that comes our way like, “This is a supply chain which has forced labour in it” is not abundant. In fact, when it does, rapid action is taken.

For example, you may have heard that, at the end of last year, Cambridgeshire Constabulary did a great operation on forced labour within some well-known fast-food restaurants. In fact, those fast-food restaurants were employing people perfectly normally but they were being coercively controlled by an individual back in a flat where all their money was taken from them. Cambridgeshire was able to respond and eliminate forced labour from that supply chain. However, it feels quite rare to be able to say, “This is a supply chain where we can demonstrate on a balance of probabilities that something nefarious is going on.” But whenever that sort of intelligence is received, it should be acted on and communicated far and wide.

Alex Sobel: What are the typical limits on data sharing, for instance, through GDPR security concerns? Are people who enact forced labour, either domestically or through the supply chain, utilising our laws to hide it? Do we need to improve data sharing?

Alex Murray: It is a good question. There are exemptions when crime is taking place, from a GDPR point of view, but a huge amount of industry in all law enforcement agencies and businesses ensures that you are data protection compliant and that can add inertia in the system. Law enforcement used to say “dare to share”, but law enforcement is also concerned about breaking the rules because they enforce the rules. There is a probably a cultural reticence because of a fear of breaching the Data Protection Act, which is unnecessary because there are exceptions in the Data Protection Act for sharing on crime. Whenever nefarious activity is suspected, we should and companies should be telling law enforcement, and we should be telling other countries. To a large extent, we do.

It is a good question to ask. If businesses suspect that there is forced labour in their supply chain, what do they do? As we heard earlier, there will be good actors, the wilfully ignorant and bad actors. All industries will have a complete spectrum as far as that is concerned.

The Chair: Thank you. Many of us followed the work that you did in Cambridgeshire and are full of admiration of the successes secured there in exposing what was being done and helping some of the people who were victims and now survivors of modern slavery. Ms Campbell wants to return to that issue.

Alex Murray: Yes. I might say that was the Cambridgeshire Constabulary and brilliant work by them, not the NCA. I would not want to take credit for that.

The Chair: Take credit where it is given and do not worry too much. Thank you.

Q67 Juliet Campbell: It was brilliant work anyway. This is a question for Ms Lyons. How do you think a survivor advisory council would benefit the development of policies in this area?

Eleanor Lyons: This is an important thing that needs to happen. We absolutely need to have a survivor advisory council established in this country. It is important because some of the legislation that we have been speaking about focuses on the harm once it has happened, but we want to be able to prevent some of this harm happening.

The best way to do that is to listen to survivors themselves and to understand what led them to be in this situation of forced labour and what help, care and support they would have wanted as part of their recovery journey. Our international partners do that and they want us to do it. Survivors themselves have told me that they want it. I have put a business case to the Government that they need to establish a survivor advisory council and I hope that they will take it forward.

Juliet Campbell: Do you anticipate that the business case that you submitted to the Home Office for a survivor advisory council will be successful?

Eleanor Lyons: I hope that it will be successful. I have also spoken to the Foreign Office and other wider government departments about this because it is absolutely critical that we hear workers’ voices and make sure that we are remediating them as part of any action that we take to tackle forced labour. I would appreciate any efforts that anyone can make to encourage the Government to establish one.

Juliet Campbell: What barriers would prevent the survivors’ important voices being heard?

Eleanor Lyons: One barrier that I am currently coming across with the Government is that it is clear from survivors themselves and from the OSCE and other partners that I have spoken to that, rightly, survivors want to be renumerated for their valuable contribution to a panel. The Government are currently a little bit reticent about how they would go about doing that, but it is important that a trauma-informed panel is established and that the valuable contribution that survivors make is recognised. That should not be a barrier to the establishment of a panel.

Juliet Campbell: I have a final question. You have said that international agencies have done this. How have they overcome those barriers?

Eleanor Lyons: We have seen in America the former trafficking in persons ambassador Cynthia Dyer did it, and so has Kari Johnstone within the OSCE. They have overcome these barriers by making sure they established panels that offer renumeration and pay to survivors and have a clear remit; and that survivors have clear guidance and fair and open competition with applications, and also understand that their work is meaningful and they are leading to bigger change.

Every survivor who I have spoken to in this space wants to make sure that they are helping others who may still be in horrific situations of forced labour. They want the opportunity to help create change and be part of legislative change and policy reform. It is completely right that we give them that platform.

The Chair: I have the distinct impression that you would like to encourage the committee and its recommendations to support the establishment of the survivor advisory council. After the hearing is over, if you feel we could usefully make further points, please feel free to add to what you have said to us today.

Eleanor Lyons: Yes. Thank you. I am pleased that came through.

The Chair: It did, successfully. As I said, take credit, even if it belongs to others. We have two more questions on the issue I said we would return to about leadership. I invite Mr Khan to start with this and then Dr Swallow.

Q68 Afzal Khan: This question is to you, Ms Lyons, again—you are getting a good share of the questions. Where should the ultimate responsibility sit for ensuring that the UK market is free from goods linked to forced labour?

Eleanor Lyons: It is the case that we need to all take responsibility in this area, but I speak to two main actors. We need clear leadership and responsibility from the Government in this space. There needs to be clear legislation and a clear framework for businesses to abide to. We also need businesses to make sure that they look at their supply chains and at what they can do to prevent forced labour occurring and then address risks in their supply chain.

Consumers do care about this. We cannot put responsibility on consumer actors but, from everything I have seen, consumers respond to wanting goods to be made without forced labour. They want to be able to trust businesses that they are buying goods that are made ethically.

Afzal Khan: Mr Murray, how could a cross-government approach, including the Home Office, the Department for Business and Trade, the FCDO and DESNZ, be aligned to address the issues of forced labour in supply chains?

Alex Murray: That is a good question, which I do not feel massively qualified to answer as an NCA operative, albeit this committee in itself is indicative of a great response and a cross-party approach. I hope that your recommendations are taken seriously.

Leadership is also important in law enforcement from a modern slavery and human trafficking point of view because, more often than not, it is a crime you have to uncover and then work hard to keep your victims with you—to pick up on the victims point that you raised earlier. It takes discretionary effort when you have a lot of demands on your time. From a value-based point of view, senior police leaders and law enforcement officials across all the agencies also need to demonstrate leadership and, to a large extent, have. We have seen increased prosecutions, albeit at a low level, over the past 10 years.

Eleanor Lyons: Where leadership should sit across government is a big issue and it is part of the reason that we see a lack of clarity about what the UK is doing to tackle forced labour. There needs to be clear leadership from No. 10 and the Cabinet Office at a bare minimum, but the Home Office owns the modern slavery policy and the modern slavery statements; the Department for Business and Trade owns the Fair Work Agency, a single enforcement body and trade deals; and the Foreign Office owns soft power. When I speak to all of these departments, as I do regularly, they often do not know what is going on in the department next door.

The Government need to lay out a clear strategy about what they are doing in this space and it needs to be owned by the absolute leaders in the Government—No. 10 and the Cabinet Office—because this is one area where individuals’ human rights are affected. It is a baseline expectation of the Government that they should put protections in place, in my mind.

The Chair: Thank you very much. All of you mentioned the international collaboration and co-operation that is required to tackle this effectively. I know Dr Swallow wants to ask you about that.

Q69 Peter Swallow: Yes, thank you. Mr Murray, to start, which global bodies and institutions is the UK engaging with to address the issue of forced labour supply chains? You have already mentioned Interpol and Europol, but are there others?

Alex Murray: Within Europol there are different subsets of agencies and one organisation is called EMPACT, which we are part of. We lead the modern slavery part of EMPACT in relation to online issues, particularly associated with adult sex work sites, and also some of the illicit finance associated with modern slavery and human trafficking. Those are important. We also have a close relationship with Five Eyes communities.

Bilateral relationships are also strong through the NCA. We have a strong network of international liaison officers in the NCA across the majority of significant countries where this would be an issue. That allows for good bilateral relationships and engagement, as well as Interpol and Europol.

Peter Swallow: Are you working with NGOs and others working in this space from a human rights perspective?

Alex Murray: We have relationships with those NGOs and my modern slavery human trafficking team has relationships. They are not formalised in the way that they were three or four years ago when there was a whole series of strong network; they have somewhat disintegrated, but you are probably better qualified than me to say that. Many NGOs are in this space. I have been out to Cambodia with police officers with Hope For Justice, for example, an organisation that campaigns against human trafficking. They do exist and we have those relationships, but they are not as formal as you might imagine.

Peter Swallow: Ms Lyons, perhaps you could add to that.

Eleanor Lyons: In my role, I work with a lot of international partners because it is critical to our efforts to tackle forced labour. This is a global problem and affects everyone in this space. One sad advantage of us falling behind is that we can take a lot of learnings from how other countries have chosen to introduce new legislation and which things they would take forward and encourage us to do.

Peter Swallow: Please expand on that.

Eleanor Lyons: For instance, when it comes to mandatory human rights due diligence, we have seen it applied at a national level in France, Germany and the Netherlands, and now it is at an EU level. We should look at introducing that. We are behind. It comes into power officially in 2027, so we need to act now to make sure that we catch up on that. Talking about import bans, the EU is again doing that and the United States has been doing that under the Uyghur Forced Labor Prevention Act. That is, again, something that they would encourage us as a country to look at and make sure that we are echoing some of the legislation.

We were talking about some of the challenges of import bans earlier. We could, for instance, look at the EU model and whether we want to do import bans product by product with or whether a rebuttal presumption like in America is a better route forward. That strong international partnership and working is important in this space.

Q70 The Chair: Thank you. There will be a moment at the end for a round-up and for all three of you to give us a couple of asks if you had a wish list of the most important things that we could recommend. Perhaps if you want to include that as one of your priorities, I am sure we would be happy to engage with it.

You mentioned earlier that, if we do not act, we could become a dumping ground for other countries, but you also praised those companies that you said have a higher standard even than the law requires. I personally felt encouraged by that.

It begs a question, to my mind. May I ask Mr Murray from the NCA how common is it for you to receive tip-offs from companies and corporations that are concerned about forced labour in their own supply chains?
Does the NCA want to encourage more of that reporting?

Alex Murray: Unfortunately, it is uncommon. We receive referrals and we then decide whether we will investigate. We have a tasking mechanism where we ask a force to investigate when we receive that form of intelligence. It is a rare occurrence from actual companies themselves, but we often receive referrals from whistleblowers, victims and advocacy groups or people on the ground who are advocating for those individuals—but less so from businesses.

The Chair: It is helpful to hear that. Mr Sobel wants to come in, but Baroness Lawrence caught my eye first.

Q71 Baroness Lawrence of Clarendon: I follow on from what Ms Lyons was saying about other countries being so far ahead and that we are just not there. What sort of recommendation would you give to us as a committee to put forward to the Government if you believe that we are so far behind? We are a couple of years away from 2027 and things are happening now. What would you suggest?

Eleanor Lyons: For me, as a bare minimum, we need mandatory human rights due diligence legislation. That absolutely needs to be introduced on the statute books. We of course saw Baroness Young of Hornsey’s Private Member’s Bill last year in this area. That is needed to make sure that we have as a bare minimum at least a signal that is unacceptable to have goods entering the United Kingdom that are made with forced labour, and that we also encourage businesses to look at prevention in their supply chains as well as looking at risks. At the moment, the Modern Slavery Act asks individuals to report on things that have already happened, but we need legislation that incentivises businesses to be clear about what they are doing to prevent goods being made with forced labour. We also need a level playing field so that good businesses are rewarded and we encourage other businesses to up their game in this space. That is my main recommendation.

Q72 Alex Sobel: Following on from that, thinking about the debate we had on my amendment and Sarah Champion’s amendment on the GB Energy Bill in the Commons, one point that the Minister made both in the Chamber and privately was that GB Energy was too narrow a vehicle to stop forced labour and slavery supply chains. The solution that was posited—which is still a solution and I want your view on it—was that we should use the Procurement Act 2023 debarment list to debar companies from supplying the whole of the public sector when it has been identified that they use forced labour in the supply chain.

It would be useful to hear your view on that approach; it is also just public procurement and the previous answer is a much broader scope. In updating the legislation, should we also use the debarment list or do you think that it will be superseded if we have new legislation?

Eleanor Lyons: You have touched on a critical issue, which is that we have the Modern Slavery Act, the Health and Care Act and the Procurement Act. We have lots of different pieces of legislation at the moment that do different things, whether it is asking private companies to publish modern slavery statements, the Procurement Act with a discretionary debarment list or the Great British Energy Bill looking specifically what will be procured in that space.

We are missing one clear overarching piece of legislation across businesses, public procurement and wider organisations that makes clear that the expectations are for goods made with forced labour not to enter this country. That matters because, with each of these pieces of legislation, how they are enforced and how they come into practice matters for their impact. Each of these pieces of legislation, whether it is the Health and Care Act looking at the NHS, has regulations. They are rolled out and they need to be understood and applied. Then you have the Procurement Act and that needs to be done for procurement officers. I look at local authorities across the country. Most of them are unaware of some of the provisions that are in place.

I welcome each new bit of legislation and things are going in the right direction, but legislation needs to be more than a signalling tool and needs to be put into practice. That is the challenge we have with it being in different pockets at the moment, in my mind.

Q73 The Chair: Thank you very much. You will be relieved to know that we are coming to the end of the session. First, thank you very much indeed for the contributions you have made. They have been wonderful.

You realise that we have to now distil everything that you have said to us today, everything we have heard in other oral sessions and 800 pages of written evidence into some reasonable recommendations to the Government. If you were in our shoes and you could have a wish list of a couple of things, what would be your priorities? I will start with Mr Murray and then Mr Holliday and then Ms Lyons, having given her a short breathing space between her last replies. Distil into a couple of short, sharp points what you would urge us to do.

Alex Murray: I cannot underestimate the importance of shining a light on this issue. It is one of cultural awareness across business, law enforcement and politics. Rather than a specific legislative requirement that might come from Ms Lyons, for me it is a case of amplifying the fact that this exists. We need to keep our eye on it, do more and focus on it. It is one of government narrative and public narrative.

Phillip Holliday: For me, it is about trying to anticipate the challenges of whatever approach we propose. For example, we talked earlier about the supply chain and how opaque that is and how difficult that is to prove. Whatever we can do to heighten that and bring that to the fore in whatever proposals are made is one area.

Then I would also link in something that I did not cover in my evidence around anticipating the inevitable challenges to seizures. Last week, I concluded a 10-year case in the High Court, where someone challenged a seizure that we made at the border. They were claiming damages of £7.75 million. We were initially supported by the magistrates’ court, which said it was a good seizure. The Crown Court supported us and so we destroyed the goods. The High Court disagreed and said to the importer, “No, you can have your goods back”, but we had destroyed them. We need to anticipate the unintended consequences and where it might go.

Rebuttal presumption might be one measure, for example, if we were making recommendations, where the onus is put on others as opposed to law enforcement. Otherwise, we will be on the back foot the whole time, trying to argue about the supply chain and that they were goods that were correctly subject to forfeiture.

We all know that criminal and civil proceedings have different standards of proof. Maybe we need to look at whether it might be a lower standard of proof if we think that civil action is the right way forward. That still sends a strong message that your goods may be subject to forfeiture. I am looking through the lens of someone who has recently lived and breathed it and also trying to anticipate how the Government broadly would enact any changes moving forward.

The Chair: That was helpful. We have had quite a lot of evidence about the experience from the United States on rebuttable presumption. If you want to share with us further information after the committee meeting is over, feel free to add to what you have said. Thank you. The last word, please, Ms Lyons.

Eleanor Lyons: I welcome the committee’s focus on this area. It is critical. We need the Government to be encouraged to take clear leadership in this space and, at a bare minimum, introduce mandatory human rights due diligence legislation. Any solutions need to include survivors’ voices and worker remediation as part of that package. I would welcome survivor advisory panels being established as part of the policy-making legislative framework.

The Chair: Thank you very much indeed. Let me repeat my thanks to each of our witnesses today for sharing their extraordinary expertise and their wisdom with us today. It has been greatly appreciated. We will have our last oral session on this issue on 7 May, when we hope to have a ministerial response from the Government. Then we will get on to the drafting of the report and recommendations to the Government.

Those who follow the proceedings of this committee might be interested to know that next week, the Lord Chancellor, Shabana Mahmood, will be here to give evidence to us. We will ask her about a lot of the issues that we have been discussing over the preceding Wednesdays when these sessions have examined a whole range of issues. We will also ask questions around modern day slavery and human trafficking and so a further chance next Wednesday will also arise. With those words, it falls to me now to conclude our proceedings.