(COR009)

Written evidence submitted by Human Trafficking Foundation (COR009)

About the Human Trafficking Foundation

1. The Human Trafficking Foundation (HTF) was established by the All-Party Parliamentary Group on Human Trafficking and Modern Slavery. HTF co-chairs the Home Office Modern Slavery Unit’s Victim Care policy implementation group made up of expert stakeholders and chairs various anti-trafficking networks nationwide, which involve cross-sector statutory and non-statutory organisations delivering frontline support to people who have experienced modern slavery.

How the Home Office and its major contractors are working together to ensure the safe and effective operation of contracted services is maintained, particularly where these services affect vulnerable people;

Broader Context

2. Known Existing Challenges to Victims of Trafficking seeking support through contracted services include:

• Too few specialist safe house spaces for the number of identified victims referred for support
• Mainstream provision via local authorities or asylum support is often unsuitable
• Local authorities are given no additional funding to house and support victims of trafficking and there are housing shortages in local authorities nationally and in London in particular
• Quality of support under the victim care contract is inconsistent nationally due to lack of standardised training and high turnover of staff
• 80% of specialist support for adult victims is via outreach workers, who provide keywork sessions in public places e.g. libraries, cafes, etc.
• The majority of support for victims of modern slavery receiving government-contracted support is delivered via mainstream or voluntary organisations, e.g. foodbanks, churches, ESOL and other language classes, mental health charities, voluntary therapy and activity groups, etc.

Evidence from Stakeholders

3. The Human Trafficking Foundation has learned of the following challenges based on correspondence with stakeholders since restrictions were enacted to reduce the spread of Covid-19:

• Increased pressure on services to continue to support victims, for example ensuring the cash subsistence relied upon for food gets to service users.
• Voluntary services relied upon for support while in the victim care contract and while transitioning to longer-term support have needed to close to prevent the spread of the virus
• Charities providing housing outside the victim care contract for those not consenting to receive Home Office-governed support have needed to develop their own emergency strategies for responding to the outbreak, with no extra support and while awaiting official guidance
• People identified as potential victims of trafficking continue to be refused specialist safe house accommodation while living in temporary local authority accommodation without recourse to public funds and relying on foodbanks
• The Assisted Voluntary Returns Service has temporarily been closed. This is the mechanism via which victims of modern slavery were returned to their country of origin. The outcome of this will be any of the following: a) increased pressure on provision via the victim care contract and already-stretched local authorities; b) victims being returned via alternative non-assisted routes, potentially placing them at risk; c) anti-trafficking charities paying the bill for returns, amounting to an increased burden at an already uncertain time
• Frontline staff have needed to self-isolate after displaying symptoms and therefore victims are losing in some cases their only specialist key worker and being left without vital support. Even where services are able to prioritise urgent needs e.g. payments to service users, this does not meet the needs for broader support, e.g. emotional support and crisis intervention, that are met by key workers
• Caseworkers supporting survivors are reporting that due to language and other barriers, a significant amount of time is being taken up explaining to survivors individually what is happening and what they need to do, and then having to stay in touch and check they’re okay and following this guidance. There is a concern that this information was being shared adequately elsewhere, and that this is a lot of responsibility for caseworkers to take on, on top of their other work.
• We have learned that the Home Office are putting in place measures to support people being supported via the victim care contract, but that this is not being implemented quickly enough.

Speculative concerns

4. Based on knowledge of the general operation of support provision for victims of modern slavery, the Foundation has the following concerns around the risks posed to victims and survivors:

• Concerns that victims of modern slavery in specialist safe houses and those in NASS accommodation may continue to be moved on when their support under the victim care contract ceases, without safe and permanent accommodation options organised. There has been no clear policy or guidance for subcontractors in this regards that the Foundation has seen.
• Potential victims of modern slavery being refused accommodation via the NRM because of covid-19 fears and remaining in unsuitable accommodation, e.g. unsupported local authority temporary shelters
• Challenge to safely housing victims within NASS and safe house support in light of health concerns and lack of self-isolation options
• The health risks of survivors currently in unhygienic conditions in detention or shared asylum or local authority accommodation.
• Survivors of modern slavery are often particularly isolated and vulnerable with many being without family or friends in the UK or abroad and may not know how or be able to access the right health services should they contract the virus due to language, and lack of access to media without smartphones or computers
• Closure of public spaces prevents keywork sessions for survivors receiving outreach support taking place, leaving them without any support
• With their only support networks closing down or reducing provision, victims are at increased risk of deterioration in mental health in particular, increasing risk of suicide, which is an existing risk for many
• Migrants whose visas are due to expire in the coming days who cannot leave the country due to travel restrictions who are at risk of becoming irregular unless the government can temporarily extend their visas.
• People becoming destitute due to the job losses that push them into exploitative working. Or being exploited more in roles due to reductions in services/resources (i.e. people in sex industry being made to provide more risky services due to low client numbers; agricultural workers made to work longer hours, etc.)
• Mental health of survivors in outreach or post-NRM who relied on community groups etc to prevent social isolation having no one now to interact with or support them during this time.
• Lack of safe processes in place i.e. the lack of cards to provide subsistence payments to survivors, currently relying on cash, even though everyone is encouraged to avoid handling money at this time.
• Limited assessment of NASS and some local authority housing options whereby many will be in shared or cramped accommodation making self isolation impossible or decision making about moving victims difficult at this point in time.
• Victims who have no leave to remain and are on immigration bail will have a condition requiring them to reside at a specified address that may become inappropriate if shared with someone who is ill.

Recommendations include:

5. Specific covid-19 related guidance and plans around victim support covering all parts of the victim journey through the NRM and post NRM. Also we need a plan for when support workers are ill – something that is currently not in place, but may become an acute problem over the next few weeks.

6. To protect vulnerable victims of trafficking being supported via the victim care contract (in outreach or safe house provision) it has been suggested that interim guidance for the SSHD to remain responsible for accommodating the victim instead of that responsibility transferring to the local authority.  Those in NASS should remain in NASS and those in safe housing should remain in safe housing. In practice, this would prevent victims who receive a conclusive grounds decision from needing to leave their current accommodation and reduce exposure to any new carriers of Covid-19 or as potential carriers prevent exposing others to risk.

7. Emergency recruitment of temporary qualified social workers to provide crisis support to victims as has been seen in the NHS and police

8. Hotels are likely to be empty across the country. The Home Office should work with hotels to provide emergency accommodation to victims who are not able to be safely housed in safe houses or are in unsafe NASS/council organised accommodation.
9. Residence and reporting requirements for those on immigration bail should not be enforced during the pandemic - and any reporting dates be deferred until the pandemic has ceased.

10. Those not seen as high risk should be freed from detention until safe to return.

11. The Single Competent Authority should suspend decisions in cases where a positive outcome cannot be made until the pandemic has lifted.

March 2020