Overview
This briefing explores the findings of the latest annual report from the London Modern Slavery Leads (LMSL) Network and includes our commentary on the upcoming legislative changes and the development of new policies relating to modern slavery that should be monitored.
Sir Mo Farah’s brave disclosure about being trafficked as a child shocked many and shed light on the issues of modern slavery and human trafficking in London. This emphasises the need to focus on tackling modern slavery.
The scale of modern slavery is revealed in national data on modern slavery cases published by the MPS and Home Office:
- 12,727 individuals were identified as potential victims of modern slavery in the UK in 2021, a 20% increase on the previous year. Almost one third of these cases were in London.
- 50% of these cases were for adults and 43% were for children. Across the UK, cases of labour exploitation were the highest for adults. Children had mostly been criminally exploited.
The London Modern Slavery Leads Annual report 2021/22 report, published by the Human Trafficking Foundation, provides an overview of the great work that has been delivered across London to tackle modern slavery but highlights a number of challenges.
In addition to providing an overview of the collective achievements of the LMSL Network, the report includes detailed information provided by each London council on how it is responding to modern slavery and data insights from the Met Police for each borough. This is the first time a detailed breakdown has been presented for each borough
The LMSL Network, consists of representatives from each of the 32 London boroughs, the City of London corporation, as well as Clinical Commissioning Groups (CCGs) and select partners from across the capital. The Network provides an opportunity for all members to come together, share best practice, and raise trends or challenges they have identified in their borough; these are then addressed collectively.
Commentary
Modern slavery guidance remains broad and training is not standardised so how councils’ modern slavery duties are enacted differs between local authorities. The London Modern Slavery Leads Annual report 2021/22 report will help to facilitate the sharing of best practice, and the report highlights key issues for all boroughs to address.
The challenges which London boroughs have identified in the report include:
- Councils are looking to improve data collection, data sharing and data analysis around modern slavery
- LMSL Network aims to share anonymous data to increase understanding/awareness of modern slavery across London
- Councils are trying to improve modern slavery training for all appropriate staff across different teams
- There is a need to ensure one clear process for referring modern slavery cases, and to ensure that all adult cases of modern slavery are raised as a safeguarding concern.
- Boroughs want to raise awareness of modern slavery for all council staff, borough residents and local businesses
- The LMSL Network seeks to encourage meaningful engagement with survivors to improve practice
- A key goal for the LMSL Network is to address the gap in support for child modern slavery victims as they turn 18
- There is a need to improve housing support for victims of modern slavery. The LMSL aims to develop a cross-border sharing housing protocol to:
- Prevent victims from becoming homeless when fleeing exploitation or exiting the NRM (national referral mechanism), and ensure that emergency accommodation is provided quickly
- Ensure suitable accommodation for victims
- Ensure all housing officers have training so that they can pick up on the signs of modern slavery, and not ask victims probing traumatic questions when information has already been provided
- To stop local connection being questioned when victims present as homeless, despite it often not being safe to stay in a borough where there is local connection
Legislative changes and policy updates
The Nationality and Borders Act received royal ascent in April 2022 and different parts of the Act will come into force at different times.
Part 5 of the Act addresses Modern Slavery disqualifies some victims of modern slavery with criminal records from support and introduces a deadline for victims of modern slavery to disclose their experience of abuse, or else be penalised for late submission and run the risk that their 'credibility is damaged'. We are concerned that this could result in unintended consequences for vulnerable groups and individuals, and lead to increased pressures for local authorities left to support this cohort.
The Homelessness Code of Guidance was updated in October 2021. It will be important to engage with housing teams on the implementation of these changes. Chapter 25 of the Homeless Code of Guidance focussed on modern slavery, which now includes the following:
- Housing authorities must provide interim accommodation to individuals that have been referred into the NRM while they wait for an initial Reasonable Grounds decision and/or while the housing authority carries out enquiries, if they believe they are vulnerable due to being a victim of modern slavery
- A person who has been a victim of trafficking or modern slavery may have a priority need for accommodation if they are assessed as being vulnerable according to section 189 of the 1996 Act
The Queen’s speech announced a host of upcoming legislation, some of which will directly or indirectly impact modern slavery. This includes the Modern Slavery Bill, the Bill of Rights and the Victims Bill. We will monitor the developments of this upcoming legislation.
If you would be interested in attending a meeting with the Human Trafficking Foundation to discuss the LSML annual report in more detail please contact eva.barnsley@londoncouncils.gov.uk
