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Supplementary written evidence submitted by Sarah Dines, Minister for Safeguarding

Thank you for your letter of 21 July regarding follow-up questions from my evidence session in July.

1.     Tim Loughton asked the dates of when the previous Modern Slavery Strategy and Implementation stakeholder meetings took place, and also dates of meetings for the new model of stakeholder engagement.

We undertook a review of the Modern Slavery Strategy and Implementation Groups, and have recently relaunched these, as Modern Slavery Engagement Forums (MSEF). These forums formally bring together senior officials at Deputy Director level from across government and the devolved administrations, with third sector stakeholders, to discuss adult and child support policy, prevention, enforcement, international and transparency in supply chains.

The first of these forums met on 5 July 2023 and they will meet quarterly.

2.     When will the Home Office share the outcomes of the devolved child decision making pilot, which ended in April 2023? And if you are able to share more information on the future of this programme?

The devolved decision-making pilot is an on-going programme of work that was launched in June 2021. It is currently due to run until at least March 2024. Given local safeguarding partners are the primary support providers to children, we are seeking to understand through this Pilot Programme the benefits of a local, multi-agency approach to identification of child victims of modern slavery. The pilot programme requires that both the Reasonable Grounds and Conclusive Grounds decisions are taken through a multi-agency structure at

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one or more meetings, with representation from the three safeguarding partners – the local authority, health, and police – as a minimum.

Since the pilot launched, the guidance has set out clear decision-making timelines that need to be met by pilot sites. A Reasonable Grounds decision should be made no later than 45 days from the date the pilot site receives the referral. A positive Conclusive Grounds decision can also be made at the same meeting if there is sufficient evidence to do so. If a pilot site deems the evidence gathered for the first multi-agency meeting is insufficient for a positive decision to be taken at the same meeting, then a second meeting to make the Conclusive Grounds decision should take place no later than 45 days after the first meeting (90 days in total).

In June 2021, we launched the Pilot across ten sites, covering a total of eighteen local authorities. To enable further testing, the pilot was expanded to cover ten additional pilot sites in early 2023. Grant agreements with all twenty pilot sites currently run to 31 March 2024.

To date, the benefits seen by pilot sites include:

• remarkably quicker Conclusive Grounds decision-making – this was seen as particularly beneficial for child victims who were awaiting clarity on their immigration status or who were involved with the criminal justice system.
• increased awareness and understanding of the National Referral Mechanism process and modern slavery within local authorities.
• improved multi-agency partnership working ensuring a range of professional voices were used to inform decisions.

Following expansion of the pilot earlier this year, we are working closely with local authorities and stakeholders to monitor the impact and effectiveness of the Pilot and will continue to assess our next steps.

3.     Should there be a statutory definition of child criminal exploitation?

Presently the Government does not feel there is compelling evidence to introduce such a statutory definition. The Home Office is working across Government to identify areas of learning and improvement with regard to child criminal exploitation (CCE) and county lines. CCE is defined in statutory guidance for frontline practitioners working with children. This includes the Keeping Children Safe in Education (updated 2023) and Working Together to Safeguard Children statutory guidance (updated 2022).

CCE is also defined across a range of guidance, including the Serious Violence Strategy (published 2018), the Child Exploitation Disruption Toolkit for frontline practitioners (updated 2022) and the county lines guidance for prosecutors and youth offending teams (published 2019).

We consult partners, including the police, regularly on the legislative framework in connection with CCE and will act upon evidence if additional legislation is required.

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4.     What policies are in development that will speed up NRM decision-making and provide the necessary support to victims of trafficking?

Wait times are too long and we continue to make efforts to bring those timescales down. Staffing uplifts are currently being delivered under the umbrella of HMG’s 10 Point Plan, with an additional £10 million secured by the Home Office to onboard a further 200 decision-making staff across the competent authorities – recruitment is well underway.

• We are already seeing significantly increased systemic output as a result of these new staff becoming operational.
• Decision-making times have come down significantly in the most recent quarter. In Q1 2023 the average (median) time taken from referral to conclusive grounds decisions across the competent authorities was 566 days, compared to 641 days in the previous quarter.
• As of January 2023, there were over 29,000 people awaiting a conclusive grounds decision for referrals up until the end 2022. Almost 70% of these were referred in 2021 and 2022.

We have more than doubled decision-maker resource in recent years, from around 100 people in 2020 to over 300 today. We have seen an increase in Conclusive Grounds decision output of over 100% in the last year alone and expect this to increase further. The extra 200 decision-makers will be in place by the end of the year, which will continue to help drive down the Work in Progress caseload.

We are also:

• Improving the quality of referrals coming into the National Referral Mechanism system (for example, developing a first responder toolkit to help ensure sufficient information is provided upon referral and changing the NRM referral form so that it is clearer when that information should be entered) for decisions to be taken at the earliest possible opportunity;
• We have piloted devolved decision-making for child victims of modern slavery at 20 Local Authority pilot sites to test alternative approaches; and
• We have updated our guidance on Reasonable Grounds Threshold guidance to strengthen identification and provide clarity to potential victims.

Comprehensive, needs-based support via the government funded Modern Slavery Victim Care Contract (MSVCC) is available to all consenting potential and confirmed victims of modern slavery in England and Wales throughout their NRM journey. This includes secure accommodation where necessary, financial support, and access to a support worker to help victims access wider support services, including, healthcare and counselling through the NHS, translation services and legal aid.

Regarding support for children, the Government has rolled out Independent Child Trafficking Guardians (ICTGs) to two thirds of local authorities in England and Wales and are committed to delivering national rollout of the service from 2025/2026. ICTGs provide an additional source of advice and support for potentially trafficked children, irrespective of nationality, and

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somebody to advocate on their behalf to ensure their best interests are reflected in the decision-making of the public authorities involved in their care. The support they provide is in addition to the statutory support provided to children by local authorities: local authorities are responsible for safeguarding and promoting the welfare of all children in their area, including child victims of modern slavery regardless of their nationality or immigration status.

5.     Should the NRM be overseen by an independent body?

The Government recognises the value and importance of independent oversight on work to tackle heinous crimes such as modern slavery. That is why in the Modern Slavery Act 2015, the Government committed to appointing an Independent Anti-Slavery Commissioner. I appreciate the concern regarding the recent delay in appointment, but I can assure the Committee that the appointment is nearing completion.

6.     At Q597, you said you had discussed training of police officers with the NPCC modern slavery lead. Please provide the Committee with further details about plans for police training on modern slavery.

A key part of the Modern Slavery and Organised Immigration Crime (MSOIC) Unit’s mission is to improve the national response to modern slavery. Upskilling police officers to understand the complexities of modern slavery in order to identify victims and lead investigations has been at the centre of the Unit’s work since it was established in 2017. This has resulted in the development and rollout of bespoke training for police officers, which includes:

• Modern Slavery General Awareness course, which is part of the College of Policing curriculum for initial police training for all new staff.
• Modern Slavery e-learning, which has been completed on 55,856 occasions (between 2018-2021).
• Modern Slavery Investigator course – 2,030 police staff and other law enforcement officers, including from the National Crime Agency, the Gangmasters and Labour Abuse Authority, and Immigration Enforcement, have been trained (between 2018- 2023).
• Victim Liaison Officer training – 546 police staff have been trained (between 2020- 2023).
• A ‘Train the Trainer’ event delivered by the MSOIC Unit in February 2022, which was attended by 94 trainers from all UK police forces. The training provided enhanced knowledge on modern slavery to enable the trainers to deliver the training within their forces.
• Two sketch videos – one on the National Referral Mechanism (NRM) and one the statutory defence under section 45 of the Modern Slavery Act 2015 – are available to all staff on force intranet sites. The NRM awareness video is also available on YouTube.

In addition, the MSOIC Unit conducted a benchmarking exercise for all forces in England and Wales in January this year, to measure performance against the modern slavery national policing standards. Forces are encouraged to use the results of this exercise as their force action plan for improvement during the year. The MSOIC Unit will continue to work with and support forces that have identified gaps and the benchmarking exercise will be repeated in January 2024.

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All forces across England and Wales are supported by a team of regional coordinators (based in Regional Organised Crime Units) who provide advice and guidance, as well as partnership support and engagement sessions on a range of areas.

7.     At Q621, the former Migration and Modern Slavery Envoy agreed to write with information on whether Vietnam is safe for trafficked individuals to be returned to, and what projects they might be running?

The safety of returning people from the UK to their home country depends on individual circumstances, and is considered on a case-by-case basis.

Since 2018 the Home Office has invested £4.8 million of Official Development Assistance in Vietnam through our Modern Slavery Fund, working in partnership with the International Organisation for Migration and the Vietnamese Ministry of Public Security. The programme seeks to strengthen Vietnam’s response to human trafficking by preventing vulnerable people from becoming victims; strengthening the national and operational response to human trafficking; and supporting rehabilitation and reintegration of trafficked people, including those exploited in Europe.

To date we have provided over 1,050 people with economic and educational support to reduce their vulnerability to trafficking; trained over 500 officials to respond effectively to trafficking cases; and reached over 1.6 million people through awareness-raising outreach work. Our support has also contributed to developing Vietnam’s five-year plan to tackle human trafficking and a victim support policy. Our capacity building programme for police officers has also been incorporated into the national police training curriculum, meaning change will be long-lasting and sustainable.

8.     I wrote to you on 7 July with a range of questions about the SCA, IECA and the Multi-Agency Assurance Panels. Can you please provide a response to this correspondence?

These letters have been provided.

9.     Please can you provide an organogram of the Home Office Modern Slavery Unit.

We have previously provided details of the make-up of the Modern Slavery Unit (MSU). On 1 July 2023, there were 56 individuals working in posts within the Modern Slavery Unit.

The MSU is organised into two parts, the first of which is responsible for Prevention, Enforcement, Strategy, Governance, International, and Supply Chains, and the second for Victims Policy, which includes identification and support.

The MSU works on a wide range of issues including but not limited to: engagement with businesses and public authorities on supply chains; oversight of the Gangmasters and Labour Abuse Authority and Director of Labour Market Enforcement; grant management of the  Modern  Slavery  and  Organised  Immigration  Crime  Programme;  international

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engagement and oversight of the Modern Slavery Fund; devolved decision-making pilots for children; Independent Child Trafficking Guardians programme; the victim support model; the operation of the National Referral Mechanism; and the modern slavery measures in the Illegal Migration Act.

In recent years our achievements have included:

• Modern Slavery and Organised Immigration Crime Unit (MSOIC): since 2016 we have provided funding of £17.8 million to the MSOIC, to support the NPCC lead for modern slavery and organised immigration crime. There has been a continued uplift in operational activity over recent years, with the number of live police operations increasing from 188 police operations in December 2016 to 4,500 in June 2023.
• Independent Child Trafficking Guardians (ICTGs): ICTGs provide an additional source of advice and support for potentially trafficked children. To date, we have rolled out ICTGs to two thirds of local authorities in England and Wales (112 out of 175 local authorities), and in June I agreed that we will work to extend the current grant agreement to 31 March 2025, alongside continuing work to deliver National Rollout of the service to cover all of England and Wales from April 2025.
• Child decision-making pilot programme: we launched the pilots in 2021, and following expansion in March 2023, there are now twenty pilot sites, covering 30 local authorities across England, Wales and Scotland. In these sites, we have devolved the responsibility to make NRM decisions for potential child victims of modern slavery, so that local authorities – with their existing safeguarding structures – can provide the most appropriate care required for a child.
• Modern Slavery Victim Care Contract (MSVCC): we continue to oversee and fund the MSVCC (contracted to spend £379 million over 5 years), to provide specialist support to thousands of adult victims. It delivers a service that is needs-based and aligned to the requirements of individual victims, to assist them in their recovery from exploitation. We have started work on procuring the next adult victim support contract, once the current contract has come to an end.
• Modern Slavery Fund: between 2016 and March 2023, the Home Office has spent over £37 million through the Modern Slavery Fund to combat modern slavery overseas and reduce the threat of human trafficking to the UK. Between 2019 and 2021, this funding has:
• provided direct support to over 2,500 victims of trafficking, helping them to rebuild their lives and break cycles of exploitation;
• enabled over 4,000 first responders, law enforcement and policy officials

to better identify and respond effectively to modern slavery;

• helped to prevent modern slavery by conducting targeted outreach work with over 180,000 vulnerable people; and
• may have reached at least 1.5 million people through strategic communications.
• Part of the Modern Slavery Fund also includes the Modern Slavery Innovation Fund, which continues to test innovative approaches to build the global evidence base on what works to combat modern slavery. In this new phase we are funding civil society organisations in over 13 countries, including and includes projects that also reduce vulnerability to trafficking and addresses forced labour in UK supply chains.

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• International engagement: in December 2022, the UK and Albanian Prime Ministers signed the Joint Communique to enhance bilateral cooperation between our two countries. This ensures there would be appropriate support for victims of trafficking in Albania. In May 2023, the Minister for Safeguarding’s visit to Romania culminated in the signing of the UK and Romania Joint Action Plan on modern slavery and human trafficking, to increase cooperation on understanding the threat, prevention activity, law enforcement cooperation and support to returning victims. In July 2023 Senior Home Office officials also visited Vietnam to further enhance co-operation with the Vietnamese Government on human trafficking.
• Transparency in Supply Chains: launching the Modern Slavery Statement Registry in 20212, which to date has seen more than 38,000 organisations upload statements. We also designed and launched the Modern Slavery Assessment Tool to strengthen supplier’s modern slavery due diligence. As of January 2023, 3,462 assessments have been completed.

Chair’s letter to Minister Philp of 5 July: Papers from meetings with Adult Service Websites

You wrote to Minister Philp on 5 July requesting agendas, minutes and accompanying meeting papers from meetings officials at the Home Office have had with AdultWork and VivaStreet since 2017. As outlined in Minister Philp’s response to your PQ of 18 November 2022, the Home Office does not intend to publish papers from meetings with Adult Service Websites as we consider this could undermine future policy development in this area. For the same reason, we are unable to share such papers with the Committee. However, and as outlined during the evidence session you held with the National Crime Agency and the National Police Chiefs' Council (NPCC) lead for modern slavery and organised immigration crime, these discussions have focused on two areas: firstly, around the development of a set of Voluntary Principles, as committed to in the Government’s Tackling Violence Against Woman and Girls Strategy; and secondly, around the requirements the Online Safety Bill will place on these sites.

The draft Voluntary Principles have been developed to provide a framework for Adult Service Websites to take all reasonable and practical steps to prevent slavery and exploitation on their platforms, in advance of the Online Safety Bill coming into force. It includes principles which encourage Adult Service Websites to take proactive steps to identify material which may be linked to exploitation and illegal activity, and to refer such material to law enforcement agencies. This includes ensuring adequate moderation processes are in place to screen adverts for risk factors linked to exploitation and to notify law enforcement when suspicious content is found. The principles also encourage Adult Service Websites to respond positively, collaboratively and consistently to law enforcement requests for information and to have appropriate measures in place so users of their sites can report concerns about potentially harmful content.

The Voluntary Principles are still being finalised and will be published in full in due course. They are voluntary and therefore aim to pave the way for the Online Safety Bill which will place duties on these sites to proactively identify and remove content linked to sexual exploitation and human trafficking. The Online Safety Bill includes a tough suite of enforcement powers for Ofcom, the regulator, to take action against companies breaching

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their duties, including fines for companies of up to £18m or 10% of qualifying annual global turnover (whichever is higher).

Corrections

The Minister mentioned a recent memorandum of understanding (MoU) with Albania during the session, however she meant Vietnam. The original MoU on human trafficking with Vietnam was signed in 2018 and, as referenced above, a review meeting with senior Home Office officials was held with the Vietnamese Government on 3 July, which tracked progress to date on the implementation of the MoU and set out new priorities.

As set out above, in December 2022, the UK and Albanian Prime Ministers signed the Joint Communique to enhance bilateral cooperation between our two countries. This ensures there would be appropriate support for victims of trafficking in Albania.

September 2023