(HUM0033)

Written Evidence from the Helen Bamber Foundation

Introduction

1.       The Helen Bamber Foundation (HBF) is a specialist clinical and human rights charity that works with survivors of trafficking, torture and other forms of extreme human cruelty. Our work alongside survivors shows us that, with early and appropriate care and support, they can build the strength to move on with their lives. Our multidisciplinary and clinical team provides a bespoke Model of Integrated Care for survivors which includes medico-legal documentation of physical and psychological injuries; specialist therapeutic care; a medical advisory service; a counter-trafficking programme; housing and welfare advice; legal protection advice; and community integration activities and services.

2.       HBF works to prevent the re-trafficking and further exploitation of survivors, with each department working collaboratively to identify and reduce potential risks for our clients. This includes using trauma-informed methods of working to establish and maintain a professional relationship of trust, conducting a specialist trafficking assessment and evaluating needs and risks on an on-going basis. We take steps to reduce pre-existing and arising risks through, for example, ensuring a person is receiving quality legal advice to give the best possible chance of a grant of leave to remain or ensuring they have access to appropriate housing and can move from accommodation with known risk factors (for example, so-called ‘hotels’)). Our multi-disciplinary clinical team seeks to address the physical and mental health problems that our clients are experiencing via medical advice and specialist trauma-focused therapeutic care. We also offer community, education and integration activities and a social support network to aid individual recovery, wellbeing and independence.

3.       While organisations like HBF do everything they can to fill the gaps left by state support, it is only with substantial systemic change that the UK will be able to tackle modern slavery/human trafficking. It is only by ensuring that survivors are identified and supported properly that we can break cycles of re-exploitation and crime against survivors. Individual support and access to services is essential if victims of trafficking are to be confident enough to provide evidence to police; help to dismantle criminal slavery networks and prevent more people from becoming victims. This requires a focus on the prevention of re-trafficking as a core part of any modern slavery strategy. It requires efforts to ensure that asylum and trafficking systems function properly and without delay, treating all those within them fairly and humanely, providing long-term support and protection.

4.       This submission addresses all of the questions outlined by the Committee, with a particular focus on the systemic change required to reduce the risk of survivors of trafficking who have come to the UK from abroad being subject to further exploitation or re-trafficking. While this evidence was being drafting, the government published its Illegal Migration Bill. If passed, this Bill will strip those fleeing war, persecution and human rights abuses of their right to seek safety this country. It will, as emphasised by the UNHCR, amount to an asylum ban on those who arrive irregularly and will prevent access to vital support for survivors of trafficking and modern slavery. The impact of the Bill is examined briefly below, but we would direct the Committee to our briefings for Second Reading for more detail, available here: Briefings on the Illegal Migration Bill 2023

5.       HBF also endorses the evidence submitted by the Taskforce on Victims of Human Trafficking in Immigration Detention (which HBF chairs) and the Anti-Trafficking Monitoring Group

What is the scale and nature of human trafficking?

6.       The survivors[1] with whom HBF works have been trafficked to the UK from abroad, or have experienced trafficking while en route to the UK. The top five countries of origin of our clients who are survivors of trafficking are Albania, Nigeria, Vietnam, Eritrea and China, and 63% are female, 36% are male. They predominantly experience labour and sexual exploitation as well as often being held in domestic servitude.

7.       HBF’s clients will generally either be referred into the National Referral Mechanism (the NRM) - the framework designed to identify and protect victims of trafficking and of modern slavery - and/or will claim asylum. The trafficking experience of survivors, and risks of being re-trafficked should they be forcibly returned to their country of origin, can form part, or all of the grounds for their claim. It is through these systems that the survivors we work with will be able to access support, assistance and protection.

8.       In 2022, 16,938 potential victims of modern slavery were referred to the NRM, the most common non-UK nationalities being Albanian, Vietnamese, Eritrean, and Sudanese. 16,821 first stage (’reasonable grounds’) and 6,189 final (‘conclusive grounds’) decisions were made – 89% of conclusive grounds decisions were positive, finding that the individuals were victims of trafficking.[2]

9.       In the same year, 74,751 people claimed asylum in the UK, with the eight most common countries of origin being Albania, Afghanistan, Iran, Iraq, Syria, Afghanistan, Bangladesh, Sudan and Eritrea. 18,699 initial decisions on asylum applications were made and 76% were grants of asylum, humanitarian protection or alternative forms of leave. 51% of appeals against a refusal of asylum were allowed (meaning the Home Office was asked to reconsider their decision). [3] There is no published data on how many people seeking asylum are survivors of trafficking nor how many are in both the asylum system and NRM, but 93% of HBF clients who are survivors of trafficking are in both systems.[4] Some survivors have claimed asylum but do not wish to be referred to the NRM for a range of reasons, including concerns that it would delay a decision being made in their asylum claim; the ability to seek/obtain preferential leave through another route; lack of understanding/awareness of the NRM (which may be but is not necessarily related to mental health problems associated with the trafficking experience); and/or having heard negative things about the process and the support available.

10.   It is clear, therefore, that NRM figures are not sufficient in themselves to assess the scale of trafficking in the UK. Furthermore, many survivors are not able to escape or are too frightened to bring themselves to the attention of authorities. This is especially the case for those who have been trafficked to the UK from abroad – roughly three quarters of all victims.[5] Victims with insecure immigration status frequently feel unable to report their abuse and exploitation to authorities, for fear of serious personal consequences including their information being shared with immigration enforcement, and/or being arrested, criminalised, detained indefinitely and ultimately forcibly removed from the UK to a country where they fear persecution/re-trafficking.[6] Hostile responses from the UK authorities is something that traffickers will often use as a threat to subjugate victims and instil fear so that they do not dare to escape or seek help. An over-reliance on people self-identifying as victims of modern slavery and the lack of effective vulnerability screening at all stages of the asylum process (including upon transfer into detention) also means opportunities to identify and protect victims are frequently missed.[7] Often, front-line services do not have the appropriate skills or resources to recognise and successfully respond to victims of trafficking, resulting in many falling through the gaps in service provision. It is also the case that many accredited First Responders for the NRM lack appropriate training for this vital job.

11.   In addition, the statistics do not take into account the numbers of people who are re-trafficked. Re-trafficking is generally understood as a situation whereby a survivor has experienced and left one or more trafficking crimes and later re-enters or is forced into another trafficking situation – this may be initiated by the victim’s original traffickers, or by new perpetrators who target them due to their vulnerability.[8] There is no international or national monitoring of either the occurrence of re-trafficking or individuals' risk. At HBF we estimate that at least a third of the survivors of trafficking we work with are at a high or moderate risk of further abuse, exploitation or re-trafficking.

How effective is the UK’s approach to discouraging the demand that leads to trafficking?

12.   The government’s stated response to ‘criminal gangs’ has focussed on introducing increasingly restrictive and punitive immigration policies, including a number of measures in the Nationality and Borders Act 2022 making it harder for survivors to access the NRM;[9] the Rwanda scheme that has made no exception for any kind of additional vulnerability, including being a survivor of trafficking;[10] and the Illegal Migration Bill that would effectively block survivors of trafficking from protections under the asylum and trafficking systems. This is not the way to discourage the demand that leads to trafficking. In fact, preventing people from accessing the very systems that might provide them with support and protection serves only to leave them more vulnerable and at risk of exploitation or re-exploitation. As outlined above, fears of being reported to the authorities – with the possibility of being detained and/or removed – makes it easier for traffickers to keep people in exploitative conditions.

13.   A particularly concerning example of this ‘policy of exclusion’ has been the government’s focus on Albanians arriving in the UK via the English Channel. Inflammatory rhetoric has been repeatedly used about Albanian nationals, with, for example, the Home Secretary stating that "the truth is that many of them are not modern slaves and their claims of being trafficked are lies."[11] This is despite close to half (49%) of all Albanian nationals seeking international protection being granted asylum in 2022 with the grant rate being at an even higher 87% for Albanian women and children.[12] Furthermore, Albanians made up the most common nationality among small boat arrivals that were referred to the NRM in 2022, accounting for 55% of this group.[13] By the end of 2022, the Home Office already made a positive decision in 90% of Albanians claims who arrived on a small boat and received a reasonable grounds decision.[14] Research on the situation of trafficked men and boys from Albania further highlighted risk factors included poverty, low education, suffering from physical or mental disabilities, domestic violence and/or sexual abuse within the family or a pre-existing blood feud, being LGBT and for children, being Roma or Egyptian or homeless.[15]

To what extent do support services meet the needs of victims who have been trafficked in or to the UK? 

14.   Support for survivors of trafficking should be long-term and tailored to each individual in order to meet needs which have arisen both from their experience of exploitation, and subsequent or preceding needs which make them vulnerable to re-trafficking.

15.   While a survivor is waiting for their conclusive grounds decision they are entitled to financial support, support worker contact and safe house accommodation, but the provision of this is, in HBF’s experience, inconsistent and often dependant on the support provider and the support worker allocated as to how effective this will be. See below for more on accommodation.

16.   Currently when a person receives a positive conclusive grounds decision they are entitled to at least 45 calendar days further ‘move-on’ support. If a person is considered to have ongoing support needs they must request it under the Recovery Needs Assessment (RNA) process, the mechanism through which survivors of trafficking in England and Wales have their ongoing support needs assessed and provided for. A research report by the Anti-Trafficking Monitoring Group (ATMG), ‘One Day at a Time’,[16] of which HBF is a member, indicated that this system is failing survivors. The report found that the RNA is exceptionally complex, inefficient and unclear, and that support is being provided for an inadequate amount of time.

17.   Due to pressures on support workers under the Modern Slavery Victim Care Contract (MSVCC) and flaws in the system itself, survivors are being exited from the support system while they still have significant outstanding needs, resulting in destitution and in some reported instances individuals being re-trafficked or exploited further. The report made a number of key recommendations on how the process could be improved, however since its publication HBF has witnessed the situation worsen, with a high number of our clients being exited from the support system as soon as they receive a positive conclusive grounds decision and before a decision is made as to whether they should be granted temporary leave to remain, often not even entering the RNA process. This is a pivotal time for survivors who feel they are being ‘dropped off a cliff edge’ with their financial support, support worker contact and in some instances safe house accommodation all being stopped and without anyone to help them with this transition. It is often left to HBF to try and fill this gap.

18.   Recommendation:

• The government’s commitment of 12 months’ support for all victims with a positive Conclusive Grounds Decision should be enacted and for victims returning to their country of origin, the government must ensure there is wraparound support available to prevent re-trafficking.[17]

Accommodation

19.   The survivors supported by HBF are often placed in accommodation that is unsuitable, unsafe and potentially harmful. Potential victims of trafficking referred into the NRM may have access to temporary accommodation,[18] but there are not enough ‘safe houses’ to meet the need. In our experience it is extremely difficult to secure an appropriate safe house place, particularly in London and this often requires a large amount of advocacy from HBF staff. Many of our clients are instead housed in ‘contingency’ asylum accommodation, including hotels, for prolonged periods. More than 37,000 people seeking asylum are currently stuck in hotel accommodation,[19] which is damaging to their health and well-being, often causing worsening depression and increasing suicidal ideation.[20] HBF has worked with a number of people housed in former military barracks, including survivors of trafficking, and this form of ‘quasi-detention’ has been widely condemned as ‘prison-like’ and highly re-traumatising for survivors of torture, trafficking or other serious forms of violence.[21]

20.   Inappropriate accommodation increases the risk of (re)exploitation - recent research found evidence of visible, large-scale accommodation in hostels, hotels and houses of multiple occupancy being targeted by traffickers.[22] There is a lack of welfare and vulnerability assessments involved in the allocation of accommodation for people vulnerable to exploitation.

21.   Recommendations

• The government should abandon plans to create institutional ‘accommodation centres’ modelled on the use of Napier Barracks, and undertake further work with local authorities to move people out of hotels. It should ensure that sufficient, safe accommodation is available in the community with access to healthcare, legal advice and other services.
• The government should better resource safe house provision, with clear guidance provided on how and to whom such housing is allocated.

Financial subsistence

22.   In HBF’s experience, the low rates of financial support provided to our clients can cause them considerable distress and significantly worsen their physical and mental health problems.[23] While enduring long delays in the asylum and NRM systems (waiting for months or years for decisions - see below), survivors remain in a situation of poverty, dependency and low socio-economic status. The prolonged inability to work, to provide for themselves or their family, or to start to move on with their lives means that survivors are more likely to be targeted for exploitation, take up work in exploitative conditions and/or get into debt.

23.   Low levels of financial support and the lack of the right to work often mean that survivors are unable to meet their essential needs. Those who are successfully referred into the National Referral Mechanism and/or asylum systems receive subsistence payments, but these can be extremely low – people in the asylum system are forced to live on just £6.42 per day, or a staggering £1.30 a day if accommodated in full-board hotels.

24.   Once a person receives a positive conclusive grounds decision their financial needs will be assessed under the RNA process. The ATMG’s research on this process found that financial support was the first strand of support to be stopped, placing survivors at a heightened risk of destitution and re-trafficking. It was also reported that often a rigid approach was taken as to what would assist with a person's recovery, with requests being regularly refused because they were not considered to be related to ‘a need arising out of a person's trafficking experience’. Often these assessments were not taken in a trauma informed way and no criteria or training is given on how to determine how a need arises from a trafficking experience. This approach shows a failure to comprehend that support under the NRM and RNA is to aid recovery, and not simply to provide daily essentials.

25.   Recommendations

• The government should set asylum support rates at a level that allows for an acceptable standard of living - at a minimum they should be 70% of the rate for mainstream benefits. 
• All survivors of trafficking with a positive final (‘conclusive grounds’) decision from the NRM should be automatically granted support, including leave to remain and recourse to public funds, for at least 30 months with a route to settlement.

Legal aid

26.   In HBF’s experience, positive immigration/asylum decisions are often dependent on the quality and knowledge of legal representatives and services who advocate for survivors. Survivors of trafficking require individual support throughout these arduous procedural systems and assistance with providing the requisite evidence to substantiate their case, including medical evidence. [24] However, the very low funds paid for this work and the failure to increase the rates over the past two decades has resulted in the decimation of the legal aid sector. Recent research showed that 90% of support workers helping survivors struggled to find legal advisors for their clients in the past year, with almost half reporting delays of six months or longer.[25] Half of asylum applicants are unable to access legal aid representation.[26] The crisis in legal aid leaves survivors without access to lawyers equipped to work on their cases. Others may resort to paying private lawyers and may get into high levels of debt for services which are often sub-standard due to the lack of regulation in the private sector. The problem is particularly severe for those trafficking survivors with severe mental health problems whose capacity to navigate the NRM and asylum systems may be limited.

27.   Recommendations

• Legal Aid rates should be increased in line with inflation, and all cases should be paid at an hourly rate so that legal aid is sustainable[27] and providers can afford to continue this vital work.[28]
• Immigration advice and advice on identification should be in scope for legal aid prior to entering the National Referral Mechanism (NRM) and legal aid should not be means-tested for potential and confirmed victims of modern slavery.

Immigration status and leave to remain

28.   HBF supports many survivors of trafficking who are forced to spend years in limbo, waiting for NRM and asylum decisions including reconsideration outcomes, appeals and judicial reviews. 67% of HBF clients have been waiting for over two years for their initial asylum decisions. The situation is worse for survivors of trafficking who are in both the asylum and NRM systems, as it has been shown that asylum decisions for those with a NRM referral are seven times more likely to take longer than 12 months than asylum decisions without a NRM referral.[29]

29.   At the end of 2022, the total number of cases awaiting an initial decision was 132,182 (relating to 160,919 people), over three times more than the number of applications awaiting an initial decision at the end of 2019.[30] Final (conclusive grounds) NRM decisions are currently taking an average of 17 months.[31]
 

30.   These delays are worsened by the ‘inadmissibility’ and ‘differentiation’ processes under the Nationality and Borders Act 2022. The Home Office, if it decides a person has travelled through a “safe country” on their way to the UK, may consider their asylum claim ‘inadmissible’ and try to send them to a different country. However, they are often unable to and instead this creates a 6-month delay before that individual can then enter the asylum system. Under the new ‘differentiation’ scheme, Home Office must now make another decision once status is granted, as to whether someone is a group 1 or group 2 refugee (depending on how they entered the country).  If someone is deemed a group 2 refugee, a shorter grant of leave (permission) to remain in the country is given with fewer rights. There is no timeframe for this decision, leaving people in another unknown period of limbo. 

31.   Even when they are conclusively recognised as a victim of trafficking in the NRM, survivors must wait for further decisions as to whether they should be granted leave to remain and whether their existing support should continue. While the Home Office is able to grant them temporary leave, this is rarely done.  In 2020 to 2021, over 1,750 adults subject to immigration control were confirmed as victims of trafficking[32] but just 150 adults were granted discretionary leave as a result – less than one in ten.[33] Less than five children were granted discretionary leave in the same period.[34] These figures are even lower than the previous four years (2016 to 2019), when just 521 adults (and even more shockingly just 28 children) were granted discretionary leave to remain in the UK. [35],[36] In many instances where leave is granted, this is often the result of extensive evidence being submitted several months after the positive conclusive grounds decision is made and is often only for 12 months with no route to settlement.

32.   Under the Illegal Migration Bill this situation will be significantly worse. Under this Bill the vast majority of those arriving outside the very limited existing ‘safe routes’ will be blocked from protection. Survivors from countries such as Afghanistan, Eritrea, Sudan, Iran and Syria, including children arriving on their own, will instead be left living in limbo for years, unable to claim asylum and access any form of secure status. With no returns agreements in place and no-where to remove them, survivors will either be held indefinitely in the already overstretched and problematic immigration detention estate or left to languish in Home Office-run accommodation.

33.   The Bill will also remove protections for survivors of trafficking and modern slavery, a response to false and wildly misleading claims from the government that the National Referral Mechanism is ‘being abused’. Survivors of trafficking will of course continue to come to the UK by irregular routes because a core aspect of human trafficking is the movement of people and the use of threat, force or fraud and the abuse of vulnerability to do so. Others will continue to travel to seek safety and may be trafficked during, or following their journey. The only key difference being that people are less likely to attempt escape and less willing to be identified, doing nothing to alleviate the issue. Preventing them from accessing support plays straight into the hands of traffickers, who will use fear and isolation to keep people trapped in exploitation and exploit others. 

34.   Our work with survivors of trafficking has shown that continued uncertainty has a significant negative impact on their mental health. It is only once granted leave to remain in the UK, with the sense of safety and security that this brings, that survivors are truly able to benefit from therapeutic care and begin to recover from the trauma they have experienced. A lack of a secure immigration status results in not only ongoing instability and fear of forced return, with significant mental health impacts, but also poverty, destitution and isolation as it prevents survivors from working, accessing services and being able to rebuild their lives. This in turn increases their vulnerability to abuse, exploitation and re-trafficking.

Recommendations

• Proposals in the Illegal Migration Bill that would introduce a de facto ban on the asylum system and the protections offered by the NRM should be abandoned.
• The government should recruit, resource and train decision makers adequately to ensure that NRM and asylum decisions are made in a timely manner.
• The government should remove new processes that cause further delay in asylum decision making and leave refugees in less secure positions, including provisions on inadmissibility of asylum claims and differential treatment.
• All survivors of trafficking with a positive final (‘conclusive grounds’) decision from the NRM should be automatically granted support, including leave to remain and recourse to public funds, for at least 30 months with a route to settlement.

What evidence is there, if any, that the National Referral Mechanism process is being exploited by individuals seeking asylum in the UK?

35.   While survivors of trafficking brought to the UK are struggling to receive the support they need to recover and rebuild their lives, the political rhetoric around trafficking victims has become increasingly hostile, with the government frequently claiming that victims of slavery are ‘abusing the system’.[37] During the passage of the Nationality and Borders Act 2022 through parliament, the government alleged that people are falsely claiming to be survivors of trafficking ‘late in the process’ in order to ‘frustrate immigration action’ and to secure their release. This was used to justify concerning measures in the Act[38] designed to make it harder to be identified as potential victim harder and reduce protections for victims.

36.   There is no evidence to support these assertions. The Statistics Regulator publicly reprimanded the Home Office for misusing modern slavery data,[39] following a sector-wide letter,[40] stating that the available figures did not support the claim that people were ‘abusing’ the UK’s framework for recognising trafficking survivors.[41] Instead, rising trafficking cases were more likely to indicate growing awareness of the system among ‘first responder’ organisations like the police. HBF regularly sees clients who are afraid and anxious about being referred into the NRM, as explored above, and so it is highly likely that there are many more survivors who either do not know about the NRM and/or do not wish to be referred due to the impact of their trauma.

37.   The UN Special Rapporteurs have also issued a strong joint statement on the government’s hostile rhetoric and unevidenced claims about survivors of trafficking, warning that such rhetoric not only imperils protection for victims of trafficking, but may also embolden human traffickers.[42]

38.   HBF’s October 2022 report, ‘Abuse by the system: survivors of trafficking in immigration detention’,[43] highlighted that over 90% of people referred to the National Referral Mechanism as potential victims of trafficking are subsequently confirmed as victims. Every day, we see cases where people who have been trafficked have not been identified and have been treated as criminals rather than victims - locked up, suffering significant physical and mental harm as a result. One case shared in the report involved a young main detained after having be forced to work in a cannabis factory for two years. In immigration detention, his mental health suffered to the point that he was placed on suicide watch. After four years, he was eventually granted refugee status and awarded substantial damages following a claim for false imprisonment, which included medico-legal evidence on the impact the detention had had on him.

39.   In short, there is no evidence of a process being abused – rather, people who have already been exploited and mistreated are experiencing further abuse and human rights violations by an immigration system that is not fit for purpose. This system prevents victims from being identified and from receiving the support they need and to which they are entitled.

How can legislation, including the Modern Slavery Act 2015, policy and criminal justice system practice be improved to prevent and address human trafficking?

40.   In addition to the recommendations listed above in this evidence, and building on the proposals for the UK in the United States Trafficking in Persons (TIP) Report 2022, the government should ensure that law and policy creates an environment where all survivors of trafficking feel safe to report to authorities and are empowered to recover and rebuild their lives.

41.   Survivors often remain in fear of the people who trafficked them and may continue to receive threats to their safety or that of their families. Many victims who want to seek justice against their traffickers feel unable to speak to police because of this fear and because of previous negative experiences with authorities and/or fears of being criminalised for offences they have committed in connection to their trafficking. The threat of being placed in immigration detention or removed from the country, or the trauma experienced by those who have already spent long periods of time in immigration detention or prison leaves survivors particularly afraid to come forward.[44] The number of survivors held in immigration detention, at great harm to their mental health, has tripled in recent years.[45] Survivors of trafficking have been threatened with removal to Rwanda.[46] 

42.   Recommendation

• Proposals in the Illegal Migration Bill that would introduce a de facto ban on the asylum system, significantly increase the government’s detention powers and block access to the protections offered by the NRM should be immediately abandoned.
• In order for further crimes to be prevented, victims need to be supported and criminals to be prosecuted, individuals affected by trafficking must feel safe to report their experiences to law enforcement and local government. In order to achieve this, the Government must legislate to create ‘secure reporting’ pathways (where data is not shared with immigration enforcement) to enable individuals with insecure immigration status to report crimes without fear of removal.

43.   The government has emphasised that “our domestic legislation should align with our international obligations, [which] includes [the Council of Europe Convention on Action against Trafficking in Human Beings]—ECAT”,[47] yet recent changes to law and policy have seen the UK move further away from its obligations under that treaty. For example, new law and guidance on grants of leave for confirmed victims have trafficking has narrowed the criteria for granting such leave. Guidance previously stated that leave could be granted where “necessary owing to personal circumstances”[48] but now ‘Temporary Permission to Stay’ will be only granted to confirmed victims of trafficking in order to assist the person in their recovery from any physical or psychological harm arising from their exploitation. If the person can access assistance in their home country, then permission to stay may not be granted. [49] This approach is not in line with the Convention. In the explanatory report to ECAT it is clear that an assessment of a survivors ‘personal situation’ for the purposes of granting leave should take in “a range of situations, depending on whether it is the victim’s safety, state of health, family situation or some other factor which has to be taken into account”.[50] This government’s approach fails to address the full needs of survivors when assessing whether to grant leave, including looking at risks of re-trafficking, safety and protection and all the needs of the survivor. [51]

44.   The Illegal Migration Bill goes even further, denying leave to those who have travelled to the UK by irregular means and only making exemptions for those “cooperating with a public authority” on criminal proceedings, providing the government considers it is necessary for the person to be in the UK to do so.[52]

45.   Recommendation

• The government should prioritise incorporating ECAT into domestic law and ensure that any changes to law and policy strengthen the UK’s anti-trafficking response and addresses the issues identified by victims, practitioners and international bodies.[53]
• The government should recognise and follow guidance set out in the OSCE/ODIHR international National Referral Mechanism Handbook on the provision of functional, effective NRMs.
• The Modern Slavery Act and it the Modern Slavery Statutory Guidance, published in 2020 after a great deal of work by the wide-ranging human trafficking/modern slavery sector in conjunction with the Home Office, must be maintained and not undermined.

March 2023