Response to Super-Complaint on Underground lives, Police response to victims of modern slavery

1. In consultation with chief constables, the Independent Anti-Slavery Commissioner, Victims Commissioners, the Crown Prosecution Service, voluntary agencies that provide support to victims, and others as appropriate, commission work to: 

• Better understand the victim experience of the police response to modern slavery and the wider response from immigration and other law enforcement agencies; and 
• Assess the extent and nature of poor victim experiences (from first contact with the police, through to investigation and prosecution stages where these occur) to understand and identify how they can be improved. 

1. The work commissioned should seek to result in recommendations for specific actions that will further improve victims’ experiences. The Home Office should publish the findings of this work. 

Assure themselves that police officers and staff (including non-specialist staff, as appropriate) are supported through access to learning, specialist policing resources and victim support arrangements, so that officers and staff are able to: 

• easily access information and advice on modern slavery and human trafficking through their force systems; 

Updates to information are regularly communicated through force orders or via direct email to trained MSHT Victim Liaison Officers (VLO), MSHT Specialist Investigators, MSHT Tactical Advisors and Senior Investigating Officers (SIO’s). 

Bitesize training programmes on MSHT, victim referral pathway and the National referral Mechanism (NRM) have been available to all officers from July 2021 from the online Managed Learning Environment.  

The MSHT victim referral pathway, available on force systems, provides a duty investigator/tactical advisor function to provide support to officers or supervisors/managers. 

• identify possible victims of modern slavery; 

The bitesize training programme on MSHT (as above) includes victim identification 

First Response investigator guides are available to all officers and staff electronically through force systems and physical copies have been distributed to Patrol teams. 

MSHT Specialist Investigators (x32) & MSHT Victim Liaison Officers (x14) have received additional training and are available to provide specialist support to colleagues as appropriate. 

MSHT VLO’s have been trained within Patrol, Safer Neighbourhood Teams (SNT) and the Domestic Abuse Unit (DAU) to provide a more effective resource to identify and provide immediate support to MSHT victims.  

A force MSHT CPD event was held in February 2019, attended by over 100 officers, staff & partners. Presentations included police, NGOs, partner agencies and specialist organisations.  

Force Crime Recording (FCR) & Designated Decision Makers (DDM) are aware of MSHT crime recording requirements; where information relating to MSHT is identified within a crime or incident and has not already been subject to accurate recording, officers are tasked to address this. 

• recognise that victims of modern slavery should not be treated as criminals in situations where they have been forced to commit an offence by their exploiters; 

National guidance on addressing potential section 45 defences or cases where victims may also be suspects (or vice versa) during initial custody procedures has been provided to all investigative teams and custody officers. 

Warwickshire Police now sit on the CPS regional working group for MSHT to provide a more effective response to cases where victims may have been forced to commit offences or the section 45 defence is likely to be utilised. 

Bitesize training programme on section 45 defences includes this concept and appropriate actions (available since August 2021) 

• know how to take immediate steps to make victims feel safe (including facilitating access to a place of safety, if necessary); 

MSHT Victim Liaison Officers & Specialist Investigators have received additional training enabling them to facilitate immediate steps to make victims feel safe. 

Warwickshire Police are working with Warwickshire Community Safety Partnership (CSP) to develop a consistent countywide response to MSHT from all partner agencies within the county including consistent accommodation and victim support provisions across all Districts & Boroughs. 

Warwickshire Police are a referring partner for the West Midlands Anti-Slavery Network (WMASN) ‘Safe Place’ facility which provides safe accommodation for adult male victims of MSHT pre-NRM. 

• understand how to advise victims what support is available them; 

All officers have access to multi-lingual booklets published by WMASN which detail the support available through the NRM in an easy read format. 

MSHT Victim Liaison Officers & Specialist Investigators have additional training to fully explain the range of support available to victims including support outside the NRM. 

Ongoing work with Warwickshire CSP is intended to provide a capability within partner agencies to undertake this duty as first responders. 

• understand the National Referral Mechanism and duty to notify requirement, and know how to make good-quality referrals; and ensure that the statutory defence (provided by section 45 of the Modern Slavery Act 2015) for victims of slavery and exploitation who are compelled or coerced into committing offences by their exploiters is considered in all cases to protect victims from prosecution. 

Force MSHT victim referral pathway and CATE (Child Abuse, Trafficking and Exploitation) processes include provision of multi-agency Sec 47 meetings for all child potential victims prior to NRM completion, to ensure referrals made are of good quality and by the most appropriate agency. 

• ensure that the statutory defence (provided by section 45 of the Modern Slavery Act 2015) for victims of slavery and exploitation who are compelled or coerced into committing offences by their exploiters is considered in all cases to protect victims from prosecution. 

Bitesize training programme on Sec 45 defences includes this concept and appropriate actions (available since August 2021) 

Additional training is planned for proactive investigation teams who most frequently encounter this within County-Lines cases. 

Assure themselves that their resources are being deployed to enable effective investigation of modern slavery offences (which may, for example, involve taking account of high levels of vulnerability and organised crime group involvement). They should assure themselves that their crime allocation processes direct investigations to the most appropriately skilled individuals and teams. 

The crime allocation procedure has an identified escalation procedure. 

Since 2020, Warwickshire Police have been delivering the national MSHT Specialist Investigators course and now have a total of 32 trained investigators across CID, proactive CID and CATE teams, who have the additional skills to investigate MSHT. 

Work together to understand the support needs of victims of modern slavery crimes. They should provide appropriate support within their respective remits to augment the national provision so that victims feel safe and empowered to remain involved in any investigations. This should focus on what support should be available before and after National Referral Mechanism (NRM) referral as well as alternative provision available for those declining NRM referral. 

Warwickshire Police are working with Warwickshire Community Safety Partnership (CSP) to develop a consistent countywide response to MSHT from all partner agencies within the county including consistent accommodation and victim support provisions across all districts & boroughs. 

Warwickshire are currently implementing a Multi-Agency Risk Assessment Meeting (MARAM) process to allow agencies to better work together to support individuals with vulnerabilities who do not meet the criteria under the Care Act for adult care & support needs or equivalent mental health act provisions.  It is anticipated this will include victims of MSHT. 

The Office of the Police and Crime Commissioner (OPCC) for Warwickshire is in the process of commissioning a new Victim Needs Assessment and have incorporated the following into the terms of reference:  

• Services to victims of Modern Slavery and Human Trafficking, including: 

• What does support for victims of modern slavery look like/need to look like locally from when they are initially identified, before they enter the NRM and what are the challenges? 
• What does support for victims of modern slavery look like/need to look like locally when they exit the NRM and what are the challenges? 
• What does support for victims of modern slavery look like/need to look like locally when they decline to enter the NRM and what are the challenges? 

• Services to victims who are Refugees  
• Services to victims who have a questionable immigration status (not Refugees) 

1. Home Office to provide a report to Her Majesty’s Chief Inspector of Constabulary on progress in implementing its recommendations within six months of the date of publication of this report. 

1. National Police Chiefs’ Council to collate Chief Constables’ progress in reviewing and where applicable implementing their recommendations and report these to Her Majesty’s Chief Inspector of Constabulary within six months of the date of publication of this report (i.e. 26/11/2021). 

1. Association of Police and Crime Commissioners to collate Police and Crime Commissioners’ progress in reviewing and where applicable implementing their recommendations and report these to Her Majesty’s Chief Inspector of Constabulary within six months of the date of publication of this report (i.e. 26/11/2021).