Response from Unseen to HMIC report on modern slavery

The recent HMICFRS report of policing’s response to modern slavery and human trafficking has highlighted the need to review practice towards investigating this crime and effectively recognising and safeguarding its victims. National Policing lead, Chief Constable Sawyer, has confirmed that the police recognise there are areas requiring improvement and that the police will continue to work towards implementing the eleven recommendations presented.

Modern slavery is dynamic and complex. Society and all its actors need to stay ahead of the curve if we are to understand this crime’s continuously changing manifestations and typologies. We cannot and should not expect all the answers to modern slavery to come from policing in isolation. We have to take responsibility as wider society to raise awareness of this crime – media, businesses, schools, health services, local authority services and the third sector all have a role to play in understanding this issue and highlighting it. We agree, that there is no excuse for police officers to still believe that slavery is not an issue in their force area and encourage them to actively engage with the general public to raise awareness of this crime type so that they can receive intelligence and information about what is happening in their local communities. The recent Lets Nail It! #letsnailit campaign run by Unseen did exactly this and encouraged officers to begin these conversations.

Unseen has worked alongside numerous forces over the last 10 years. All have recognised their shortcomings in this arena, the knowledge gaps of their officers but have committed to working, in a time of shrinking resources, a lack of information and intelligence, increasing austerity and in a climate less accepting of foreign nationals, to tackle this ever changing and complex crime type.

Many are requesting assistance to better understand the crime, train their officers and work in partnership to ensure they are in a position to effectively respond. Throughout the inspection report ‘pockets of good practice’ are referred to, however few examples of what ‘good practice’ looks like are given. To do so would not only affirm those forces who are doing good work, but it would also set examples for those who are struggling. It is not surprising to read that those forces with specialist teams are the forces that are further ahead. Whilst the fundamental aim should be that slavery is understood and responded to effectively by all officers we are not there yet. Dedicated multi-agency teams with the capacity to gather and generate intelligence, analyse it and then act on it are vital if we are to truly have the proactive response desired and outlined in the inspection report.

To echo the words of Chief Constable Sawyer the problem of modern slavery is not something that they can overcome alone.

In response to the report we feel it is pertinent to raise a few points that reflect the need for effective partnership working, across a range of statutory, governmental and third sector organisations that emphasise some of the complications we have observed for police officers dealing with potential modern slavery crimes.

It is worth noting that significant work is already underway within the policing arena to strengthen the response to modern slavery, which started during the inspection period and addresses some of the concerns raised in the report. We are encouraged to see that the NCA, Police and Crime Commissioners, Local Policing and The National Chiefs Council are responding positively to the issue. Our recommendation and plea is that we work collaboratively as we all have a part to play in tackling slavery.


Police are one of a range of first responders and agencies with a responsibility to identify potential victims of slavery and we must be cognisant of the fact that some victims will be frightened of law enforcement and not want to engage with them. As the report identifies victims are ‘Hidden and excluded from society for years’ and may be reluctant to seek help from the authorities, which this makes identification incredibly difficult.

With the system currently in place in the UK we can’t escape the reality that if a victim does not identify themselves the police (and other first responders) have limited options. We agree that the police need to better understand the connection between the reporting of certain crime types and the potential of modern slavery occurring as identified in the report. We need officers to flag and link crime types and divert resources accordingly to deal with this. This means that not only response officers and investigators need appropriate training but call centre staff and those receiving 999 calls need to be properly trained and briefed so they can correctly flag potential links to slavery on internal systems and prepare the frontline officers responding.


The support structures we have in place for victims and the law available to officers to use, in terms of ensuring appropriate support and protection for victims is far from satisfactory. It may be easier to place the blame at the feet of policing rather than look at the systemic issues that equate to victims staying trapped in slavery. Whilst we are encouraged to see the Governments Modern Slavery Task Force is committed to improving the support of victims under the support structures offered in the UK, support can only be offered to someone if they:

  • are willing to disclose their story, in enough detail to evidence indicators of trafficking and slavery, if they are encountered by law enforcement agencies
  • are willing to sign to say that they are a victim and that their details can be shared with other authorities, including the police and immigration
  • they understand that to receive support under the Adult Care contract means that they will likely be moved out of the area in which they have been found.

To those outside of the sector these may appear to be perfectly reasonable requests. However, the reality is that officers will be having that conversation via a translator on the forecourt of carwash, sitting on the floor of a brothel or in the kitchen of a hotel, with little or no partner agency assistance. Additionally, if an officer is faced with an adult whom they believe to be a victim but does not view themselves in this way or is not in a position to accept their offer of assistance at the current time, what is expected of them is unclear. Safeguarding is obviously a concern at this stage but under current legislation unless an adult reports the crime or consents to entering the NRM an officer’s options are very limited, as is the recording of a crime, as nothing may have been formally reported.

To further complicate the situation, and as highlighted by the report, if during this process an adult decides not to consent to support but an officer becomes aware that they an illegal immigrant – they have a duty to report this. Someone that they are professionally concerned for, who will not, for whatever reason admit what is happening to them, is then, instead of helped, referred into a struggling and inappropriate immigration system.

If a potential victim declines help, officers are obliged (under the Modern Slavery Act, section 52) to report their concerns via a Duty to Notify form to the Home Office. Whilst this evidences that an officer has identified a potential victim it certainly doesn’t afford any extra safeguards for the individual they are concerned about. The report fails to point out that the police are one of several agencies required to complete these forms and there has been a steady increase in the submission of them over the last six months according to the Government’s recent Annual Review.

It is worth noting that all of the above comes ahead of an officer being able to step back and consider if there is enough evidence to embark on an investigation pertaining to modern slavery.


Where investigations have been poorly conducted and lines of inquiry not followed or concluded, HMRIC are correct that forces need to review their practice and ensure appropriate training and skills are in place.

However, we need to be aware of the complexity of the crime and factors encountered that stifle potential investigations progressing and make investigating this crime challenging:

  • a lack of willingness of potential victims to speak,
  • the lack of actual knowledge and information a victim may hold about their exploitation,
  • the fact that they may have been moved out of area from where the crime was committed against them,
  • a fear of law enforcement,
  • the fact that witnesses may be victims themselves, and the fact that once an interest is shown in an individual of a site by law enforcement victims are moved.

Continued partnership working between the police and Crown Prosecution Service is needed to understand what constitutes best evidence for a slavery case and working towards achieving this is a sensible approach to ensure that future investigations have clear guidelines and parameters. A shift from victim testimony to using other forms of investigative practices that do not rely on the voice of the victim are to be encouraged.

For police forces to prioritise and resource anti-slavery work they need to have intelligence and evidence that the crime is occurring. The UK-wide Modern Slavery Helpline, operated by Unseen, is a now a key tool for the UK, providing information daily about all types of modern slavery crimes to the National Crime Agency, the Gangmasters and Labour Abuse Authority and police forces across the UK. In its first year, the Helpline has made over 1,000 referrals to law enforcement agencies. These referrals help the police to better understand what is happening in their local force area, without which information and intelligence may be limited.

A concerted overall response that supports the police to effectively investigate this crime type with other agencies playing their part is what is required. A consistent approach to multi-agency partnership working is required as we have seen pay dividends via the Anti-Slavery Partnership, involving all the necessary actors understanding slavery, spotting the signs and reporting it.

Slavery is a crime but if we leave it all up to the police and blame them solely for the structural inefficiencies we will be failing the victims, the police and ourselves.


Unseen is a national charity providing direct services to men, women and children who have been identified as trafficked and enslaved in the UK

Unseen runs the Modern Slavery Helpline 08000 121 700 The Modern Slavery Helpline can be a go to resource for every frontline police officer – either to use themselves to call for advice or to pass on to those they encounter and are concerned for

Unseen developed the Anti-Slavery Partnership model and framework that now is in place across the South West region