UNITED KINGDOM (Tier 1)
The Government of the United Kingdom (UK) fully meets the minimum standards for the elimination of trafficking. The government continued to demonstrate serious and sustained efforts during the reporting period, even considering the impact of the COVID-19 pandemic on its anti-trafficking capacity; therefore the UK remained on Tier 1. These efforts included identifying significantly more trafficking victims. Additionally, the government devolved the NRM decision process for children to local authorities to ensure better decision-making and more timely service delivery to child victims; maintained funding; and passed the Health and Care Act with provisions related to public procurement to prevent goods tainted by forced labor from being purchased. Furthermore, the government continued to fund targeted prevention activities globally. Although the government meets the minimum standards, it prosecuted and convicted less traffickers in the past year compared with the previous year, although the multiyear upward trend in convictions continued. The government passed laws and introduced measures that NGOs, international organizations, media, and GRETA warned would have a negative impact on victim identification and protection efforts, particularly among undocumented migrants and British national victims. Government funding for victims continued to increase, but observers continued to report long-term care and reintegration support for victims were inadequate, and many potential victims continued to face years-long wait times for a conclusive grounds decision within the NRM. Observers noted this was problematic for foreign national victims who lacked the ability to work while awaiting their conclusive grounds decisions. Observers reported the government inappropriately penalized some victims solely for unlawful acts that may have been committed as a direct result of being trafficked, including immigration violations. Children in the protection system remained vulnerable to trafficking, and foreign victims faced hurdles in obtaining residence permits. The government did not report sentencing data of convicted traffickers; thus, it was unclear if judges consistently treated trafficking as a serious crime.
PRIORITIZED RECOMMENDATIONS:
* Implement reforms to the NRM, including timely determination of victim status, to encourage more victims to come forward, particularly undocumented migrants.
* Expand long-term care and reintegration support and monitor and assess outcomes of post-NRM support.
* Ensure all potential victims, including individuals subject to immigration control, are consistently screened for trafficking indicators, and referred to services.
* Expand nationwide the Independent Child Trafficking Guardians (ICTG) program and train more social workers and care providers to better safeguard child victims.
* Ensure victims are not inappropriately penalized solely for unlawful acts, including immigration violations, committed as a direct result of being trafficked.
* Seek adequate penalties for convicted traffickers, which should involve significant prison terms.
* Vigorously investigate and prosecute suspected trafficking crimes, particularly in Scotland and Northern Ireland.
* Increase victim identification training for and the number of first responder organizations to make referrals to the NRM.
* Appoint a new Independent Anti-Slavery Commissioner, to provide independent oversight.
* Establish a database on investigations, prosecutions, convictions, and prison sentence data across the UK, categorized by type of trafficking.
* Provide a clear route to residency for foreign victims and ensure potential foreign victims who are referred into the NRM can work.
* Improve victims’ ability to access court-ordered restitution in criminal cases and compensation through civil proceedings.
* Ensure the statutory definition of trafficking under the Modern Slavery Act (MSA) and similar provisions in Northern Ireland do not require movement of the victim as an element of the crime.
* Provide a trafficking-specific long-term alternative for foreign victims at risk if returned to their home country.
* Ensure all victims have access to timely legal aid.
* Strengthen measures on transparency in supply chains, including holding companies to account for noncompliance.
* Strengthen and monitor anti-trafficking efforts in the British Overseas Territories.
PROSECUTION
The government demonstrated mixed prosecution efforts. The 2015 MSA, applicable to England and Wales, and similar statutes in Scotland and Northern Ireland, criminalized sex trafficking and labor trafficking and prescribed penalties of up to life imprisonment, which were sufficiently stringent and, with regard to sex trafficking, commensurate with those prescribed for other serious crimes, such as rape. Inconsistent with international law, the laws in England, Wales, and Northern Ireland required the element of movement of a victim in the definition of “trafficking." However, these jurisdictions criminalized “slavery and servitude, and forced or compulsory labour" in other provisions of their law, which could be utilized to prosecute trafficking crimes that did not involve victim movement. Scotland, by contrast, did not require victim movement in the definition of trafficking.
In December 2022, there were at least 3,555 active law enforcement investigations of new and ongoing suspected trafficking crimes, an increase compared with 3,335 in August 2021, although these numbers are not directly comparable with last year due to the lack of full year data. The Crown Prosecution Service (CPS) prosecuted 405 defendants on trafficking charges, a decrease from 466 defendants prosecuted in 2021. Courts convicted 282 traffickers in 2022, a decrease from 332 convictions in 2021 but an increase on previous years with the exception of 2021 (compared with 191 in 2018; 251 in 2019; and 197 in 2020). CPS data did not differentiate between sex and labor trafficking, nor did the government provide data on the range of sentences of convicted traffickers or percentage of convicted traffickers serving prison time. Due to pandemic restrictions in 2020, the Crown Courts continued to experience a backlog of more than 61,000 cases - including trafficking cases - in England and Wales as of February 2023. Experts assessed the backlog of cases built up in the previous year, when courts were closed due to COVID-19, may have affected prosecution and conviction numbers. As pandemic restrictions eased, police reported a continued steady increase of trafficking cases compared with previous years. Authorities investigated alleged traffickers in a notable forced labor case in Welsh care homes, sex trafficking case of Polish victims in London, and one of the largest “county lines" investigations to date in which children were coerced to transport illegal drugs from one county to another.
Scottish authorities prosecuted 13 suspected traffickers under the Scotland Human Trafficking and Exploitation Act (2015) between April and September 2022; while between April 2021 and March 2022, Scottish authorities prosecuted 23 suspected traffickers. From April through September 2022, Scottish authorities convicted four traffickers, compared with zero traffickers during the previous reporting period. Police Scotland continued to have a specialized anti-trafficking unit to coordinate information and intelligence and work with law enforcement agencies across Europe to investigate trafficking cases. Due to the pandemic, courts in Scotland continued to face a backlog of cases from 2020, although the number of backlogged cases was less in 2022 than in prior years. In 2022, authorities in Northern Ireland did not report the total number of trafficking-related investigations, compared with 370 in 2021. Northern Irish authorities prosecuted four suspected traffickers (six in 2021) and convicted three traffickers (one in 2021). Observers continued to note the greatest impediment to the timely prosecution of alleged traffickers in Northern Ireland remained the inherent delays in the legal system, often taking two or more years from the time of initial arrest to conviction.
The Home Office continued funding the Modern Slavery and Organized Immigration Crime (MSOIC) Unit with £1.4 million ($1.69 million) to support the police in combating trafficking and organized immigration crime. The government provided a wide variety of anti-trafficking training to law enforcement officers, prosecutors, and first responders. The government trained hundreds of investigators, officers, and front-line practitioners on various human trafficking topics including victim identification and investigative techniques. The Police Service of Northern Ireland continued to collaborate with an NGO to utilize a smartphone application on all officers’ mobile devices to support them in recognizing trafficking indicators. The Department of Justice (DOJ) trained front-line workers on trafficking indicators, including police, health care workers, and immigration and other government officials. In coordination with the interagency and civil society, Police Scotland, including its national human trafficking unit, trained thousands of law enforcement officers and investigators on various anti-trafficking issues and facilitated trainings to partners and stakeholders. Scottish authorities developed a pilot following the launch of the First Responder NRM Toolkit to support first responders and enable improved victim engagement and trauma-informed information gathering from victims. Observers reported training for criminal justice officials had improved but was still insufficient, particularly training on the non-punishment of victims and a trauma-informed approach.
The UK participated in 18 Joint Investigation Teams (JIT) with EU Member States and EUROPOL. The UK cooperated with a range of partners bilateral and multilaterally on law enforcement activities. In June and October 2022, UK law enforcement partnered with their counterparts in 34 European countries to conduct joint action days which identified 910 potential trafficking victims and 115 alleged traffickers across Europe. Northern Irish authorities cooperated closely with other UK jurisdictions and Irish counterparts on law enforcement efforts across the island of Ireland. Police Scotland participated in JITs with Romanian and Hungarian law enforcement. Scottish authorities worked with Romanian, French, and Belgian authorities on extraditions for human trafficking crimes. In July 2022, the Supreme Court granted the appeal in a 2019 ruling by the Employment Tribunal that diplomatic immunity did not protect against trafficking charges; the Court concluded that if the facts alleged by the complainant are proven, the foreign diplomat will not have immunity from civil jurisdiction in UK courts. The government did not report any investigations, prosecutions, or convictions of government employees complicit in trafficking crimes.
PROTECTION
The government decreased protection efforts; while more victims were referred to the NRM, the government passed laws and introduced measures that experts and NGOs widely and consistently assess could negatively impact victim identification and protection and average wait times for decisions on official victim status exceeded 600 days. During that time, victims continued to receive support; however, gaps remained in protections for foreign national and British victims, and victims accessing long-term support. The government’s NRM was the framework for identifying and providing care and support for victims. Designated first responders, such as police, border force, local authorities, and NGOs, continued to refer potential victims into the NRM. In 2022, first responders referred 16,938 potential trafficking victims for care nationwide, a 33 percent increase from 12,727 in 2021. This was the highest recorded number of referrals since the NRM began. The Home Office maintained a detailed online database with disaggregated information, including source of referral, nationality, jurisdiction handling the referral, and type of trafficking. Of the referred victims, 79 percent were male and 21 percent were female. Authorities identified 7,019 child victims, an increase from 5,468 in 2021. Authorities categorized 2,281 referrals as “county lines" cases (an increase from 2,053 in 2021), the majority (1,710) of these referrals were boys. Albanian nationals (4,613) made up the majority of identified victims, followed by UK citizens (4,185), and Eritrean nationals (1,171). Labor trafficking, including forced criminality, was the most common form of exploitation. In Scotland, first responders referred 621 potential victims to the NRM, an increase from 419 in 2021. Following the pandemic, in 2022, Police Scotland reported the highest number of potential victims ever recorded, with labor trafficking, including forced criminality, as the main form of exploitation. In Northern Ireland, officials reported a significant increase in the number of potential victims referred to the NRM from 363 in 2021 to 547 in 2022. In Wales, first responders referred 547 potential victims to the NRM, an increase from 479 in 2021.
Even though the number of victims identified increased significantly, NGOs observed the quality and timeliness of protection services for victims decreased. The Home Office’s Single Competent Authority (SCA) handled most NRM referrals and ensured victims continued to receive support. The “reasonable grounds" threshold, established by the MSA, and amended by the 2022 Nationality and Borders Act (NABA), functioned as a gateway to support for potential victims of trafficking. Once a potential victim was referred to the NRM, the SCA made a “reasonable grounds" decision whether the individual may be a trafficking victim. The government reported the SCA aimed to make a “reasonable grounds" decision within five working days. If the SCA made a positive “reasonable grounds" decision, adult victims in England and Wales received support for at least 30 days or up to the point when a “conclusive grounds" decision was made, whichever was longer. In Northern Ireland, potential victims received support for a minimum of 45 days while authorities reviewed their cases. In Scotland, the policy remained for potential victims to receive support for 90 days or until authorities made a conclusive grounds decision, whichever came first. If authorities recognized an individual as a victim per the “conclusive grounds" determination, the victim was not guaranteed additional recovery periods or services, under NABA, whereas previously victims received a minimum of 45 additional days of support. In the fourth quarter of 2022, the average “conclusive grounds" decision took 642 days; of the 16,938 NRM referrals during 2022, 76 percent (12,907) were still awaiting conclusive grounds determinations at the end of the year. In the meantime, while potential victims continued to receive services under the Modern Slavery Victim Care Contract (MSVCC), the high volume of cases and length of a victim’s care affected the quality of care; a government-requested 2022 report on the MSVCC called for increased oversight, improvements to facilities, and staff training.
In addition, foreign national victims without legal status were unable to work until they received a positive conclusive grounds decision, which could entitle them to remain in the UK outside the immigration rules, known as “discretionary leave." While the government provided subsistence payments to victims who had entered the NRM, observers noted victims were unable to meet their essential needs with the payments. For potential victims in the asylum system, the prolonged inability to work may increase the risk of trafficking. In response, in December 2022, the government raised the amount of payments in response to the High Court ruling that subsistence entitlements of asylum-seekers were insufficient, although NGOs note the increase was not enough. Since November 2021, the Immigration Enforcement Competent Authority (IECA) made reasonable and conclusive grounds decisions in cases involving adults subject to immigration control, including adults in deportation proceedings and individuals served a notice of intent of potential inadmissibility of an asylum claim. The government created the IECA, with the intent of speeding up the decision-making process for the backlog of “conclusive grounds" decisions. The former Independent Anti-Slavery Commissioner (IASC) and NGOs strongly criticized the creation of the IECA and the return to a “dual system" approach for identifying victims - one for UK citizens and the other for foreign nationals - noting that many victims who lacked secure immigration status may not be identified or protected and would subsequently fear coming forward to seek support; observers noted the government did not consult with civil society or the survivor community prior to making this change. Government officials in England and Wales were required to notify the Home Office when they came across potential victims of trafficking; such “duty to notify" referrals increased 43 percent from 3,193 in 2021 to 4,580 in 2022. Observers believed this increase through the mandatory “duty to notify" could be attributed to a growing number of victims who do not wish to enter the official NRM systems due to not understanding it, fear of deportation, or concern that it would delay their asylum claims. The government did not automatically grant foreign victims legal status in the UK; authorities reviewed requests for discretionary leave on a case-by-case basis. Discretionary leave decisions were not linked to an individual’s status as a confirmed trafficking victim but were judged on individual circumstances. As of June 2021, European Economic Area (EEA) citizens were subject to immigration control and most trafficking victims from EEA countries were required to apply for discretionary leave to remain in the UK, which was granted only in a few cases. Foreign victims who were granted a reflection period could not be removed from the UK during that period. Observers noted that a positive conclusive grounds decision does not lead to ongoing support, or regularization of immigration status for foreign national victims, something which increased vulnerability to re-trafficking. Observers suggested there were gaps in British national victims’ access to services in the NRM; for example, British victims faced barriers to accessing shelter, in part due to confusion among professionals over what support they were entitled to, leading to their referral to local authorities instead of specialized support services.
On April 28, 2022, the British Parliament passed the Nationality and Borders Act (NABA) with anti-trafficking measures with the stated intent of clarifying in law the UK’s international obligations and entitlements for trafficking victims. NGOs, the UN, and media warned that many of the changes will have significant negative impacts. These measures required individuals claiming asylum to provide information to authorities related to being a trafficking victim (if applicable) within a specified time period, although the government made available a “good reasons" ground for providing information outside the specified period; increased the reasonable grounds threshold of the MSA to require proof of additional “objective factors" beyond a potential victim’s testimony before authorities could issue a reasonable grounds decision; reduced the minimum recovery period from 45 days to 30 days and limited additional recovery periods for trafficking victims; added two disqualification statuses for potential victims on the basis of bad faith or public order; and specified the criteria and circumstances by which authorities could grant confirmed victims temporary permission to remain in the UK, including where necessary for assisting victims to recover from exploitation, receive compensation, or to cooperate with a criminal investigation. Experts widely criticized NABA for what they assessed would increase the burden of proof for victim identification and create impediments regarding the disclosure of victim status; conflate human trafficking with migrant smuggling; and disqualify certain victims, including victims who committed unlawful acts as a direct result of being trafficked.
Government officials claimed undocumented migrants were misusing the NRM system to avoid deportation; however, observers noted the government’s own published data demonstrated nine out of every 10 referrals to the NRM resulted in a positive reasonable grounds decision. Similarly, UN experts criticized government statements alleging fraud or abuse in the system. Observers suggested the rhetoric exaggerating the level of fraud and abuse in the system could have a chilling effect on trafficking victims coming forward. Civil society expressed concern that the government demonstrated a narrowing of victim protections related to international obligations, lack of independent oversight, and lack of consultation with the NGO community.
In March 2023, the government introduced the draft Illegal Migration Bill and stated that the bill is intended to tackle alleged abuse of the UK’s modern slavery system by people seeking to block their removal once their asylum claim has been denied. Civil society widely criticized the draft bill, noting that it could negatively affect victims of trafficking by denying their support; lead to wrongful detention and deportation of potential victims; or hinder victim identification. GRETA also assessed the draft bill, as written as of March 2023, did not comply with the anti-trafficking convention.
NGOs expressed concern the government did not have a Victims Commissioner to provide independent oversight and called on the government to improve victim screening measures. The Home Office launched an e-learning package in 2020 for all first responders, on indicators of human trafficking to help proactively identify victims, and with instructions of how to make a referral. While referrals from NGOs designated as first responder organizations (FROs) increased during the year, civil society expressed concern over inconsistent training for FROs. Only 15 NGOs held first responder status and could refer potential victims into the NRM; observers noted that not having an adequate number and geographical reach of FROs may have left victims unidentified. FROs were responsible for training first responders in their organization. Observers noted the quality of information provided to victims on their rights varied widely among first responders and interpretation and translation services were not fully available, in practice, at all stages of the victim support process.
The government continued implementing a five-year MSVCC, valued at over £300 million ($361.45 million), with the anti-trafficking NGO sector to coordinate the provision of care for adult victims in England and Wales under the NRM. NGOs stated this contract supported 17,000 victims during the reporting period who were awaiting decisions and subsequently ran over budget, although the figure for that remains unpublished. The MSVCC provides a range of support services including safehouse accommodation, financial support to meet essential living needs and assist with social, psychological, and physical recovery, access to essential services, and a dedicated support worker to assist victims in accessing support services such as free health care and legal aid. One of the largest FROs temporarily stopped taking referrals in December 2022, demonstrating the strain on first responders. Observers noted access to legal aid remained limited for many trafficking victims. An October 2022 NGO report stated victims were not able to access timely legal aid, which created barriers in access to services or claiming asylum, with foreign national victims detained or at risk of removal. Moreover, GRETA expressed concern that potential victims were not provided legal aid prior to entering the NRM, preventing potential victims from receiving advice that would allow them to make informed choices, including whether to enter the NRM. The 2022 NABA contained legal aid provisions to ensure individuals were informed on the NRM before entering it. Observers claimed accommodation was provided according to availability rather than need and there was limited support available for victims with complex needs. Northern Ireland significantly increased its budget from £600,000 ($722,890) for the 2021-2022 fiscal year to approximately £1.5 million to £2 million ($1.81 million-$2.41 million) for the 2022-2023 fiscal year for contracted support services by two local NGOs. The Northern Ireland Assembly passed the Sexual Offences and Trafficking Victims Act, which enshrined existing support and assistance for trafficking victims into law. In April 2022, Northern Ireland amended the Human Trafficking and Exploitation Act 2015 to include legislative changes to the defense, protection, and support of trafficking victims. The Scottish government continued to fund the Scottish Guardianship Service to provide additional legal and practical support to unaccompanied children and victims of trafficking. The Scottish government allocated over £8 million ($9.64 million) for victim protection and assistance over the next three years. In April 2022, the Scottish government began its new Victim Centered Approach Fund to enable organizations to provide support to victims of crime, including trafficking victims.
The government continued to utilize a recovery needs assessment to tailor ongoing support to victims’ specific needs and determine the point at which a victim would exit the support services under the MSVCC. Observers asserted the recovery needs assessment was too restrictive because it placed the burden on survivors to document their ongoing need, in order to continue receiving support. Although the government funded some organizations providing some long-term care to victims, observers also noted the government did not fund many organizations providing long-term care to victims. After a confirmed victim transitioned out of MSVCC support, they could access assistance through the “reach-in service," a post-NRM service that offered transitional support, including provision of information and assistance to housing, health care, translation, employment, and support with submitting paperwork.
Children received care through children’s services offices in local jurisdictions; social workers worked with potential child victims to assess needs and create a care plan that included health, legal, education, and accommodation support. The government reported children’s care services were under increasing pressure due to the high number of unaccompanied children arriving in small boats crossing the English Channel. The government continued the Independent Child Trafficking Guardians (ICTG) program rollout; the program covered two thirds of local authorities across England and Wales. NGOs called on the government to extend the ICTG scheme across the country and continue support to individuals beyond 18 years. NGOs highlighted concerns about the difficulty of safeguarding children whom the government relocated away from their home to parts of the country where services were available; criminal gangs actively targeted vulnerable children who were taken out of their communities and ran away or went missing. Observers also noted unaccompanied migrant children were particularly vulnerable to trafficking and many of these children went missing after their arrival in the UK. Media reported 4,600 unaccompanied migrant children were housed in hotels and provided limited assistance and supervision since July 2021, putting children at risk. Between 2020 and 2022, media reported more than 500 potential or confirmed trafficking victims went missing; the majority were Albanian boys. The Home Office continued its pilot program to devolve NRM decision-making for children to local authorities. Civil society commended this as a way to produce more reliable decision making and allow children access to services faster. In 2022, the Scottish government continued to evaluate the Scottish Guardianship Scheme, which applies to all unaccompanied children. Since April 2022, the Scottish government funded two victim navigators to support victims in the criminal justice system process. Scotland and Northern Ireland required the appointment of independent legal guardians for child trafficking victims and trained the guardians on the support services available.
To avoid re-traumatization, authorities encouraged police to use intelligence-led investigations, pre-recorded cross-examination, and allowed victims to apply for reporting restrictions and other measures to maintain anonymity. In 2022, the Home Office funded four police forces and the Gangmasters and Labour Abuse Authority (GLAA) to improve support measures for victims in the criminal justice system. Additionally, the Home Office commissioned independent research on models of support for victims navigating the criminal justice process; the results have not yet been published. The courts allowed victims to testify by video, behind a screen, or with the public removed from the courtroom during hearings. In September 2022, courts in England and Wales began use of pre-recorded cross examination. Courts could grant restitution in a criminal case; however, NGOs noted courts infrequently granted restitution. Although victims could apply for compensation through civil suits, this remedy was difficult to access given the small number of legal aid providers available to file such claims and some victims were unaware of their entitlement to compensation. During the 2021-2022 fiscal year, courts granted a total of £1.2 million ($1.45 million), a small part of this was compensation to trafficking victims in England, Wales, and Northern Ireland. Moreover, traffickers could appeal or contest a compensation order and observers noted traffickers often moved assets, meaning that awards were often not paid in practice. A 2022 policy paper by the IASC found courts granted only 41 compensation orders and eight reparation orders to trafficking victims since 2018. GRETA further noted free legal assistance was not provided in practice to victims seeking compensation under this scheme in England and Wales in spite of a complex compensation procedure and the requirement that victims prove they have suffered a physical or psychiatric injury as a direct result of a violent crime in order to receive an award; the Northern Ireland Criminal Injuries Compensation Authority could withhold or reduce compensation if the victim did not report the circumstances of the injury to the police and could not offer a reasonable explanation for not doing so, did not cooperate with law enforcement, or had a criminal conviction.
Victims had a statutory defense in England and Wales for unlawful acts committed as a direct result of being trafficked; the defense did not apply to the most serious crimes, such as sexual offenses or crimes involving serious violence. In these cases, CPS had to consider whether it was in the public interest to prosecute the trafficking victim. In a recent case, courts convicted and sentenced two Albanian men on drug charges; however, they were later released from prison when the courts established they were trafficking victims. NABA also specified two “victim" disqualification statuses on the basis of public order and “bad faith," where the victim is no longer protected from removal from the UK and no longer entitled to assistance. The stated purpose of the “bad faith" measure is to prevent the NRM from being misused by those that may fraudulently claim to be a trafficking victim. While NABA excludes victims from being disqualified for certain offenses, observers are concerned trafficking victims may be inappropriately penalized victims for crimes they committed as a result of being trafficked. Additionally, NGOs reported authorities failed to identify British national victims, due to perceiving them as victims involved in criminal activity instead of as trafficking victims. A recent NGO report found the number of potential trafficking victims in immigration detention centers tripled in four years. In February 2022, a parliamentary group published a report stating there was “compelling evidence" that some British women and children currently detained in Syria were trafficking victims and claimed the government did not screen these individuals for trafficking indicators.
PREVENTION
The government maintained its prevention efforts. The Home Office was responsible for coordinating the government’s anti-trafficking prevention and protection efforts. In contrast to previous years, the Home Office did not publish its annual report on modern slavery for 2022. The government previously conducted a review of the 2014 Modern Slavery Strategy and engaged with a range of stakeholders, including the interagency, business, academia, civil society, and survivors to develop a new strategy; however, the new strategy remained pending at the close of the reporting period. Civil society commented groups initially consulted in the development of the strategy were no longer being consulted. NGOs expressed concern the UK was without an Independent Anti-Slavery Commissioner to provide oversight. The IASC encouraged good practice in the prevention, detection, investigation, and prosecution of trafficking crimes as well as the identification of victims. In November 2022, the UK received and supported Universal Period Review recommendations, 14 of which pertain to modern slavery and protection for victims, including a recommendation to reinforce the NRM to identify and assist trafficking victims. In October 2022, Northern Ireland developed and received public consultation on a new three-year strategy for trafficking for 2023-2025. Scotland drafted its fifth annual Trafficking and Exploitation Strategy progress report with survivor input; the report was pending publication at the close of the reporting period. The Scottish government also launched its second statutory review of the 2017 Trafficking and Exploitation Strategy, but the report was not published by the end of 2022.
The UK government collaborated with NGOs to raise awareness on trafficking risks among Ukrainian refugees fleeing Russia’s full-scale invasion of Ukraine. It also launched the Homes for Ukraine program to allow Ukrainian nationals to come to the UK. Civil society expressed concern over the program’s private citizen sponsorship component, inadequate safeguards and vetting of hosts, lack of central government guidance, and the vulnerability of unaccompanied children to trafficking. Media reported some Ukrainian refugees experienced homelessness and alleged cases where refugees were subjected to exploitation, including trafficking. The government made efforts to ensure protection of Ukrainian refugees; other NGOs stated the government conducted a risk assessment and worked with partners to mitigate trafficking risks. In April 2022, the UK embassy in Poland reconvened a human trafficking working group with Polish law enforcement and judicial sector representatives after a two-year hiatus; initially created to address the exploitation of Polish nationals in the UK, the working group was reconstituted to address the refugee crisis resulting from Russia’s full-scale invasion of Ukraine and associated trafficking risks.
Although the government did not fund a general trafficking helpline, NGOs operated multiple hotlines that provided support to potential victims. The government did not report how many calls led to referrals. The government funded a specialist helpline that provided advice and support to children and adults on “county lines," criminal exploitation, and gangs. The government conducted awareness campaigns across the UK with a wide range of partners. The government continued to support the Modern Slavery and Human Rights Policy and Evidence Centre (PEC) through a five-year £10 million ($12.05 million) investment through the 2023-2024 fiscal year to better understand how to combat trafficking and to develop research to inform policy choices. PEC published reports on the need for a new Global Commission on Modern Slavery, prevention of trafficking in the UK, and funded five research projects focused on survivors. The Home Office continued the Modern Slavery Prevention Fund (MSPF), launching a new MSPF in 2022 worth over £600,000 ($722,890), to support organizations and key practitioners in delivering targeted prevention activities and to build evidence of effective interventions; the government funded seven projects, including projects focused on awareness raising, educational initiatives, promotion of industry standards, survivor engagement, and data analysis. The Scottish government funds various awareness raising projects. Police Scotland participated in six academic research projects relating to trafficking and exploitation. Northern Ireland reported awareness campaigns for health and law enforcement, business, and financial sectors.
GLAA implemented a new compliance strategy for labor recruitment regulations and increased investigations into allegations of overseas workers being charged finding fees, an illegal practice under section 6 of the Employment Agencies Act. Foreign overseas domestic workers (ODW) could legally change employers during the remaining six-month period of their visa. Observers criticized the short-term nature of the visa, noting workers struggled to change employment in the visa’s short time frame, leading to the workers’ heightened vulnerability to trafficking. Workers on the ODW visa identified as trafficking victims could apply for a two-year visa as a domestic worker, although NGOs contended workers who had suffered abuse would be unlikely to want to return to the same sector. NGOs continued to urge the government to adopt reforms to the ODW visa, particularly in light of the heightened exploitation ODWs faced as a result of the pandemic. Observers also expressed concern about the government’s transit visa scheme for workers in the fishing industry, noting the inability to change vessels or leave the vessel without violating the terms of the visa left workers at risk of labor rights abuses and labor trafficking. The government continued the seasonal workers program for non-EU migrants, announcing there will be 45,000 more seasonal worker visas next year. Operators licensed by GLAA oversee recruitment and placement of workers on farms, although observers note GLAA was under-resourced. NGOs urged reform of the program, noting it left migrant workers vulnerable to exploitation; according to an NGO study, many of the workers accrued large debts and were limited in their ability to change employers. In February 2023, the government announced it will guarantee seasonal workers in the program a minimum of 32 paid working hours. NGOs assessed that, with proper monitoring and enforcement, this is a positive step toward preventing exploitation. NGOs continued to express concern the government’s strict immigration policies, which criminalized the act of working while undocumented, prevented trafficking victims from seeking help. Observers noted the absence of secure reporting options for undocumented individuals to come forward as victims of crime undermined the government’s identification and protection efforts.
The MSA required organizations with annual turnover exceeding £36 million ($43.37 million) to publish an annual statement on the government’s modern slavery statement registry detailing efforts to ensure its operations and supply chains were free of human trafficking, although observers noted the MSA did not include a mechanism to ensure compliance. The government considered measures to strengthen the reporting requirement and introduce financial penalties for organizations which fail to meet their reporting obligations. By 2022, 31,400 organizations submitted more than 9,300 modern slavery statements. However, observers noted many businesses have not yet submitted statements and the government had not penalized noncompliant businesses. The government worked to finalize but had not published the 2021-2022 UK Government Modern Slavery Statement. In February 2023, the government issued a procurement policy note on modern slavery risks in government supply chains. In 2022, the government made efforts to improve transparency in its supply chains, including through the Health and Care Act to prevent goods tainted by forced labor from being purchased by the Department of Health. In Northern Ireland, the Modern Slavery and Human Trafficking Branch disseminated materials with local governments on transparency in supply chains. Two local authorities in Scotland amended licensing requirements for nail salons, an industry with known cases of human trafficking, to provide additional regulation. The government continued efforts under its national action plan on combating international child sex tourism. The government criminalized soliciting a sex trafficking victim. The Scottish government continued its working group to combat demand for commercial sex. The government reported training diplomats on safeguarding against sexual exploitation and harassment, and all UK diplomats must report concerns or suspicions of human trafficking while abroad. The government did not report providing anti-trafficking training to its troops prior to their deployment as peacekeepers.
The government funded a wide range of anti-trafficking programs globally, including continued implementation of programs under the £33.5 million ($40.4 million) Modern Slavery Fund (MSF), to a range of anti-trafficking efforts in fiscal year 2022-2023, particularly in Albania, Nigeria, Romania, and Vietnam. In Albania, Vietnam, and Romania, the MSF funded awareness campaigns. In Nigeria, the MSF continued to provide capacity-building support to Nigerian law enforcement. The MSF funded various law-enforcement training projects in Vietnam, Albania, and Romania. In May 2022, the government announced the Foreign and Commonwealth Development Strategy, which included sections on trafficking prevention.
TRAFFICKING PROFILE:
As reported over the past five years, human traffickers exploit domestic and foreign victims in the UK, and traffickers exploit victims from the UK abroad. Although the government reported 16,938 potential victims came through the NRM in 2022, the number of actual victims is likely higher. The majority of potential victims came from Albania, the UK, and Eritrea. Forty-one percent of potential victims assert their exploitation occurred entirely outside of the UK. Labor trafficking, including forced criminality, is the most common form of exploitation among adults and children. Climate change increases the risk of internal and cross border trafficking. Migrants crossing the English Channel in small boats are vulnerable to exploitation; more than 45,700 migrants crossed the Channel in 2022, many of whom were unaccompanied children. Nearly half of all trafficking victims identified are children. Children in the care system and unaccompanied migrant children are particularly at risk of trafficking. Gangs force children to act as drug couriers from larger cities into rural areas across the UK. Traffickers force adults and children to work in agriculture, cannabis cultivation, construction, food processing, factories, domestic service, nail salons, food services, the hospitality industry, car washes, food supply industry, and warehousing, as well as on fishing boats. Labor traffickers target adults with disabilities and adults from low socio-economic backgrounds. Traffickers increasingly recruit and exploit sex trafficking victims, predominantly from Eastern Europe, through social media and online platforms. Although information was limited, an international NGO reports some individuals from the UK may have been subjected to forced labor in cyber scam operations. Following Brexit, EEA citizens who had not gained legal status in the UK were at increased risk of trafficking. Thousands of Ukrainian refugees, predominantly women and children who are fleeing Russia’s full-scale invasion of Ukraine, have crossed the UK border seeking sanctuary and are vulnerable to trafficking. In Scotland, most victims are from Vietnam with many forced to work in agriculture, cannabis farms, and nail salons. Increasingly, victims are from Albania, Eritrea, Somali, and Iran. In Northern Ireland, there are cases of perpetrators forcing victims into shoplifting and the cultivation and distribution of illicit drugs; paramilitary groups exploit children for criminal purposes. Young women and girls from Albania, Bulgaria, and Romania, including ethnic Roma, remain vulnerable to sex trafficking in Northern Ireland and increasingly victims are undocumented Somali and Eritrean nationals.
The British Overseas Territories are 14 territories with a constitutional link to the UK. UK officials continued to monitor serious and organized crime risks, including human trafficking, in the British Overseas Territories. The UK is responsible for foreign relations, security, defense, and good governance in the territories. The Overseas Territories Border Security Program provided two trainings on trafficking to law enforcement in Gibraltar and Turks and Caicos Islands. The government trained border officials and police in Cayman Islands and Turks and Caicos Islands. In 2022, the UK government reported no evidence of child victims of sex trafficking nor forced labor in five overseas territories. The government did not report additional information on its efforts to combat trafficking in the British Overseas Territories. The Cuban government reported there are Cuban medical workers in Turks and Caicos Islands, British Virgin Islands, Anguilla, and Montserrat. Cuban medical workers may have been forced to work by the Cuban government. Observers note that the Falkland Islands, Montserrat, and St. Helena-Ascension-Tristan da Cunha do not have functioning labor inspectorates to enforce labor laws; and in St. Helena-Ascension Tristan da Cunha, observers noted significant legislative gaps with respect to trafficking of children for forced labor.
Source: U.S Department of State, Office to Monitor and Combat Trafficking in Persons