Victims of modern slavery Contents

2The status of recognised victims

9.Potential victims of modern slavery can be identified in a number of different ways. Some are recognised by asylum screening units or border force checks.19 Others manage to escape their exploiters and make contact with people who can help them. For example, “Client T”, a victim who spoke to us about his experience, explained that a pharmacist had taken him to the police after he sought help for food poisoning.20 Once identified, potential victims are referred to the National Referral Mechanism (NRM), which determines if they are indeed victims of modern slavery. This chapter focuses on people who have been recognised as victims of modern slavery through the NRM.

The National Referral Mechanism

10.The NRM framework involves a number of different agencies and stages (Box 1).

Box 1: National Referral Mechanism process

First responder: An organisation designated a ‘first responder’ must refer the potential victim to one of the UK’s Competent Authorities (CA). The list of first responders includes: the Police Force, UK Border Force, Medaille Trust, Barnardo’s and others. First responders complete a referral form, which goes to the Modern Slavery Human Trafficking Unit (MSHTU), part of the National Crime Agency. The MSHTU decides which CA will deal with the referral.

Competent Authority: The UK’s two Competent Authorities are: the MSHTU, which deals with referrals from the police, local authorities, and NGOs; and The Home Office Visas and Immigration (UKVI), which deals with referrals identified as part of the immigration process.

Reasonable Grounds: Within five working days a decision maker in the relevant CA will decide whether there are ‘reasonable grounds’ (RG) to believe the individual is a potential victim of modern slavery. If a victim is given a positive RG decision then they are, if they need it, allocated a place within a Government funded safe house and granted a reflection and recovery period of at least 45 calendar days.

Conclusive Grounds: During the reflection and recovery period the CA gathers further information. The threshold for a Conclusive Grounds decision (CG) is that on the balance of probability “it is more likely than not” that the individual is a victim of human trafficking or modern slavery. A positive CG decision means that the State has conclusively determined that they are a victim of modern slavery.

Source: National Crime Agency

11.Once a potential victim has been referred to the NRM, support and accommodation is available through a Government-funded safe house. The support is delivered through the Salvation Army and its subcontractors, who run a network of safe houses across England and Wales.21 The Government said that if a victim is traumatised or in a difficult situation then they can be in a safe house within six hours.22 During the 45-day recovery period, support providers work with victims to produce a move-on plan to help them to return home, reintegrate into society or access mainstream support.

12.The NRM was established in 2009 in order to meet the UK’s obligations under the Council of Europe Convention on Action against Trafficking in Human Beings. The Commissioner said that the NRM now deals with almost 4,000 referrals per year, compared with around 700 when it was introduced.23 This had placed more demands on services and victims.24

13.Stakeholders raised a number of concerns about the NRM process. Kate Roberts, Head of Office at the Human Trafficking Foundation, said that legal aid was not available to victims prior to a Reasonable Grounds decision. Victims therefore had to give consent for a referral to the NRM before receiving any legal advice.25 Organisations that support victims said that in order to give “meaningful consent”, potential victims needed advice on matters such as immigration and access to justice to ensure that they were not disadvantaged.26 Kate Roberts added that there was no appeal process for either Reasonable Grounds or Conclusive Grounds stage of the NRM:

At the moment, if you receive a negative Reasonable Grounds decision—the first threshold, the very low threshold—there is no way of appealing that. There is obviously also no legal aid for appealing that because you are not eligible for anything, because you have not got a Reasonable Grounds decision. There is no appeals process for the Conclusive Grounds stage decision either. I think both of those are flaws.27

14.The Commissioner also raised grave concerns about the treatment of victims during the NRM process. He told us that lessons learnt from dealing with victims of domestic abuse had not been applied to victims of slavery:

A victim of modern slavery comes forward, they are presented with a number of forms that they have to sign, then their immigration status is looked at, and then there is a process to decide whether they are a victim or not. If we did the same for a victim of domestic abuse or a victim of rape I am sure people, parliamentarians and others, would be standing there in shock and horror.28

15.In 2014 the Home Office launched a review of the NRM process acknowledging that improvements needed to be made.29 The Government has since conducted a pilot of a revised system, which concluded in March 2017 and will be evaluated. The Home Office Minister, told us that her department was committed to “quite substantial reforms” to the NRM.30

16.We welcome the Government’s decision to review and reform the National Referral Mechanism. It is a complex system that should offer support to potential victims when they are at their most vulnerable. We heard serious concerns about the lack of legal advice to victims prior to their consent to referral, the absence of an appeals process and the NRM’s inability properly to respond to the needs of victims. An evaluation of any proposed new system is beyond the scope of this inquiry. It would, however, benefit from scrutiny by a select committee. We will refer the evidence we received on the NRM to the Home Affairs Committee for consideration.

Lack of data

17.One aspect of the NRM process of direct relevance to our inquiry was the lack of data on victims once they leave the framework. Baroness Butler-Sloss told us that victims “go missing because, since they don’t have accommodation, they go into various places, nobody keeps in touch with them”.31 The Greater London Authority Conservative Group said that

There has been no extensive research conducted, nor data obtained, to analyse and assess what happens to victims of human trafficking following the support they receive during the statutory 45 day period.32

18.The Commissioner wrote to the Home Office Minister expressing concern about the “lack of monitoring and accountability” within the NRM.33 He said the collection and recording of data was “substandard” and that the system needed to be redesigned and digitised.34 The Human Trafficking Foundation told us

Little is known as to what happens to victims of slavery and trafficking once they leave the safe house, or support ends following a Conclusive Grounds decision, and even less is known of those who have no support or benefits. No data is collected on long term outcomes for victims.35

19.We were told that one of the most serious consequences of the neglect to track victims was that some were re-trafficked. Ann-Marie Douglas, Project Director for the Adult Victims of Modern Slavery Care Contract at the Salvation Army told us that once the limited safe house and benefit support was exhausted, victims were vulnerable to re-trafficking.36 Kate Roberts said she had spoken to one police officer who had “re-entered the same person three times through the NRM because they had come across them being re-exploited three times”.37

20.We asked the Home Office for data on victims who had been entered into the NRM more than once. We were told

Data on re-trafficking of victims is not held centrally by the NCA [National Crime Agency] as this is not routinely recorded as part of the NRM process. As part of the NRM pilot and wider NRM reform work we are reviewing data collection and analysis.38

In oral evidence to the Committee, the Home Office Minister said that the issue of multiple referrals to the NRM had not been raised with her.39 The Home Office subsequently asked for details on such cases to be shared with them.40

21.The decision not to record and collate data on victims who have been re-trafficked and processed multiple times through the National Referral Mechanism is a serious oversight. This framework was designed to identify victims and help them to recover. For those victims who have been subject to re-trafficking the system has clearly failed. While we are pleased to hear that the Home Office Minister wishes to investigate such cases, it is troubling that the Home Office needs to ask us for this information. We recommend that any reform to the National Referral Mechanism include the recording and collecting of instances where victims have been processed through the framework more than once. This should be implemented as a matter of urgency.

22.We recommend that local police forces should be required to pass any information on potential re-trafficking to the Home Office police lead on modern slavery. The Home Office should report on these figures annually, including any trends.

Immigration status following the NRM

23.Once victims have been through the NRM they must leave the Government funded safe house either within 48 hours (following a negative CG decision) or two weeks (following a positive CG decision). Following their confirmation as victims, the support individuals receive depends on their immigration status, nationality, ability to work and whether they are assisting the police with an investigation. We heard contradictory evidence about the interaction between the NRM and immigration status. The Home Office said that consideration of a person’s status as a victim of modern slavery is “entirely separate from any decision on whether someone is entitled to stay in the UK”.41 The Home Office Minister however said that the relationship between the NRM and immigration was “fiendishly complicated”.42 The Home Office Minister had to write to us to correct evidence she had given on the system of Discretionary Leave to remain.43

24.Confirmed victims can remain in the UK and access benefits through a number of different routes depending on their immigration status:44

25.If a confirmed victim is a non-EEA national then they can apply for asylum.45 In 2015, 379 victims (36% of all confirmed victims) claimed asylum and it was granted in 216 (21%) cases.46 If someone claims asylum and is granted refugee status then they are entitled to the same services and benefits as UK citizens. Non-EEA victims are also automatically considered for Discretionary Leave to remain (DL).47 DL can be granted to individuals by the Secretary of State in “exceptional compassionate circumstances” regardless of standard Immigration Rules.48 Those granted DL have access to public services and benefits and no prohibition on work.49 In 2015, 71 non-EEA nationals were granted DL.50

26.If a confirmed victim is an EEA national then they are not automatically considered for DL. The Home Office Minister said that these victims “may well be entitled to be here anyway”.51 This is because EEA nationals have a right of entry and residence under European Union law as long as they exercise a Treaty right. This includes the right to take or seek employment or to set up business.52

27.EEA victims, however, are often unable to exercise Treaty rights, leaving them destitute or at risk of being removed.53 If they are neither in work nor seeking work, their right to reside can be conditional upon them having sufficient resources so as not to become a burden on the welfare system. EEA nationals have very limited access to welfare on arrival and there are no concessions for victims of modern slavery.54 The Commissioner said:

People are sometimes removed because they may be in situations of rough sleeping, or begging, and they are removed before they have even been assessed as potential victims of modern slavery or victims of any crime. The desire to remove people is there even when it is EU nationals.55

28.EEA national victims can remain in the UK and apply for DL through either their own application or an application by the police. If their application is successful they will have access to public services and benefits. In 2015, 52 EEA nationals were granted DL.56 We asked the Home Office how many EEA confirmed victims were refused DL but were told that the Government was “unable to determine” the number.57

Discretionary leave to remain: self-application

29.EEA victims can apply for DL. We heard, however, that victims, and the professionals supporting them, are often not aware of this option.58 Christian Action Research and Education (CARE), a charity, said

Because leave to remain is more commonly given to people from non-EU/EEA countries it is essential that JobCentre Plus staff have a clear understanding that victims from the EU/EEA may have been granted DLR and if so should be treated on the basis of the rights afforded by the discretionary leave.59

30.Following new March 2016 Home Office guidance, applications for DL can only be made on receipt of a Conclusive Grounds decision. Previously applications could be made at the Reasonable Grounds stage. The Commissioner said this “significantly delays the process” and that victims were left on the street whilst waiting for the outcome of their application.60 He also said the situation “may not only put victims of modern slavery at risk of further exploitation and destitution, but may also negatively affect the course of [a criminal] investigation”.61

Discretionary leave to remain: police applications

31.Victims can also be considered for DL if they are assisting with a police investigation.62 Under this separate process, the police make a formal application to the Home Office.63 The Medaille Trust, a charity and provider of safe houses for victims, said that if the police force supported a victim then this could make it “easier for clients to access their entitlements”.64 They added, however, that “support and understanding also differs from force to force”.65

32.Hestia, a charity that works to combat modern slavery, said that investigating police forces were often unaware of their responsibility to apply for DL.66 They told us:

Investigating police forces are not well versed in immigration matters and often do not know what DL means let alone how to apply for it or that they are responsible for this application.67

This meant that recognised victims still faced an “uphill struggle” to obtain DL when assisting with an ongoing investigation. Kevin Hyland agreed that police forces were not always aware of their role:

When I did my check on law enforcement for my report to Parliament, some forces were losing the NRM reports. They just lost them, because they felt that once they had sent it off to the National Crime Agency that was their job done. It isn’t. They still have the investigation responsibility of the victim.68

Habitual Residence Test

33.In order to access limited welfare support EEA nationals, including victims of modern slavery, must show they have a legal right to reside in the UK and that they are habitually resident. If EEA victims pass the Habitual Residence Test then they are entitled to Jobseekers Allowance for three months. They are not, however, entitled to Housing Benefit. If victims are able to register at the Jobcentre and look for work then they have a right to reside in the UK. They will still need to prove habitual residence in order to have access to benefits. The term ‘habitually resident’ is not defined in legislation and decision-makers can look at a range of factors, including:

34.The Commissioner told us that passing the Habitual Residence Test was impossible for many victims:

If you have been locked up in a farm, or locked up in premises being forced into labour or being sexually exploited, you are not going to be able to produce pay slips, or a P45, or whatever. That is the basics of where we are getting this wrong, even to that level.

With the benefits, I think that so many victims are falling through the gaps because, for example, if you cannot produce payslips you are not entitled to show your habitual residency; if you have been kept in modern slavery that is impossible.70

In June 2015, the Home Office said that it was working with DWP to make it easier for victims to prove they meet the Habitual Residence Test requirements.71 No details on this work have yet been published.

35.We heard that the status of modern slavery victims contrasted with that of refugees. Baroness Butler-Sloss said

As soon as somebody is positively identified as a refugee then a whole lot of entitlements flow from it, but there is no entitlement of any sort for a person who has been positively identified as a victim [of slavery] and this is an appalling lack.72

Whilst recognition as a refugee grants an initial period of five years leave to remain, recognition of a victim of slavery through the NRM confers no equivalent right to remain for even a month.73

The impact of this system on victims

36.We heard that the complexity of the post-NRM system causes some victims fall through gaps in support.74 The Human Trafficking Foundation said

There is no standard structure in place for an ongoing care plan or established support pathway so it really is a matter for individuals themselves (or if they have them, dedicated caseworkers) to find the best options available to each individual. This leaves a high risk that some individuals will fall between the gaps.75

The Commissioner also told us that victims could be pushed “on to the streets while they await a decision on their Discretionary Leave”.76

37.Conversely, the Home Office Minister said the various options for EEA victims gave “sufficient flexibility” and were “victim-focused”.77 She also said that if the system worked as it should then nobody should be made homeless:

As far as I can see, this should not be happening, because once we have made that first decision that they probably are victims of slavery—they have Reasonable Grounds—then they start having the support package.

She added, “I would be very surprised indeed if [destitution] was as a result of coming out of the system”.78 CARE told us that they were concerned by this statement and said that “the evidence is that the system is not working properly”.79

38.We were provided with a number of cases where EEA victims had become destitute after leaving the NRM:80

a)Case A: An EEA national given a CG decision but awaiting a leave to remain decision was refused accommodation and subsistence level support. The claimant was left in a position where she could only provide for her basic needs by engaging in prostitution. She brought a claim against the local authority on the basis that this was inhuman and degrading and contrary to the UK’s duties under European Convention on Human Rights articles and, Article 12 of the Convention Against Trafficking or Article 11 of the EU Anti- Trafficking Directive.

b)Case B: an EEA National, who was trafficked for domestic servitude and forced labour purposes over an extended period of time, received a positive Conclusive Grounds decision, but was not considered for a grant of DL. The safe house contractors thought she was in danger of being re-trafficked but the Home Office refused further extensions to her stay. The subcontractor found her accommodation for five nights per week but for the other two nights she had to sleep rough. Deighton Pierce Glynn, a firm of solicitors specialising in civil liberties and human rights, applied for DL. The Home Office maintained its refusal to extend her stay in safe house accommodation pending consideration of the DL application.

c)Case C: A Polish national was supporting police in a prosecution and was granted DL under that basis but then could not get housing. Because they could not show that they were positively looking for work they were denied Jobseeker’s Allowance. A charity then became involved and helped that person.

39.The cases above are just three examples of EEA victims facing destitution following the NRM. We also heard evidence that the system is not victim-focused, as the Government suggested. The key worker for “Client S” told us that the system was not sensitive to slavery victims:

The Home Office believed that she could be returned to another part of Albania and be safe. She had a history [as a victim] of violence and abuse, hence the reason she was trafficked in the first place, because she was vulnerable. She would have been picked up by the traffickers again. As soon as we got the year’s discretionary leave, she was then told she had to move out of G4S accommodation, which is normally 28 days. It did take the Home Office from June to late October to actually send the paperwork through that she had been granted Humanitarian Protection.

In the interim, because she came under S. Council, the Council wanted to house her immediately in a high-rise in an area that was known for drugs and antisocial behaviour. When we went to view, Client S just froze. She just froze in absolute terror, because she was held in similar places. So that was a massive trigger for her and it just felt like I could not shield her from that.81

Simplifying the system

40.Baroness Butler-Sloss branded the lack of some form of automatic entitlement for EEA victims as a “ludicrous situation”.82 She told us that a Conclusive Grounds status should have meaning:

It is an extremely unattractive anomaly and an extremely expensive process putting a person through the NRM to get a positive outcome that everybody accepts that person is the victim of an appalling crime. At that stage, having spent all that money, having gone through all that process, there is no result except a piece of paper.83

A 2017 report on supporting adult victims of slavery noted that some victims received their CG decision letter “together with a letter telling them they have no leave to remain in the UK”.84 An example of the confirmation letter that victims receive is in Annex 1 of this report. Other stakeholders agreed that a positive CG status should carry more weight. Kate Roberts said:

In practice, to that individual [CG status] does not mean much more than a piece of paper. It does not mean anything to other agencies generally speaking, for example, the DWP, so when victims are trying to access things, like benefits, there is no understanding of what they have been through, why they don’t have documents, why their story does not make sense. It can often be re-traumatising for people.85

41.Baroness Butler-Sloss suggested simplifying the system by linking the status of a confirmed victim with the right to remain for at least 12 months.86 She said this would allow more time for victims to get their lives on track, “whether they go back voluntarily to their own country or whether they choose to ask to be allowed to remain”.87 She added that the DL grant should come with benefit entitlement, set out in statutory guidance, in order to give victims access to healthcare and housing during the DL period.88 Kevin Hyland told us that there was already a precedent for automatic DL grants for victims of domestic servitude:

Under an amendment under the immigration laws, if they get Conclusive Grounds as a victim of modern slavery they get two years’ leave to remain in the UK where they are entitled to work within domestic work. There is a precedent for one area of exploitation.89

42.The Home Office Minister expressed concerns that introducing automatic DL for one year would “create the most enormous pull factor” to the UK.90 In oral evidence she suggested this pull factor would be to the traffickers.91 In her follow-up letter she suggested instead it would be to “people seeking access to benefits to circumvent recent restrictions”.92

43.It is not clear, however, how such a pull factor would operate. It is difficult to see why traffickers would increase the number of victims they exploited in order to allow those victims to then enter the NRM and be given leave to remain. As the Human Trafficking Foundation explained, “Traffickers do not act in the interest of those they enslave”.93 It is also not possible for individuals to be deliberately enslaved in order to secure leave to remain:

A person cannot choose to be trafficked or subjected to modern slavery, [as], by its very nature, such abuse entails control and a loss of decision making or autonomy.94

In any case the NRM is designed to filter out any fraud and those individuals would not receive CG status. The Human Trafficking Foundation said they had seen no evidence to suggest that a recovery period of a year would act as a pull factor or encourage trafficking.95

44.Treating confirmed victims of modern slavery differently depending on their nationality has created a confusing landscape that is poorly understood by professionals or victims themselves. As a result some victims face destitution or even a return to their enslavers because they have no ongoing access to support. The Home Office Minister claimed that allowing victims a year’s leave to remain with some entitlements would create a ‘pull factor’. This claim makes little sense and is unsubstantiated by evidence. We recommend that all confirmed victims of modern slavery be given at least one year’s leave to remain with the same recourse to benefits and services as asylum seekers are granted. This would allow time for victims to receive advice and support, and give them time to plan their next steps. This would not prevent those who wish to return home from doing so. We set out details on what specific support should go with an automatic grant of 12 months discretionary leave to remain in chapter 2 of this report.

45.We recommend that confirmed victims of modern slavery be exempted from the conditions of the Habitual Residence Test. It is absurd to expect victims of modern slavery to be able to prove they have been living and working in the UK if they have been enslaved.

The impact on successful prosecutions

46.The matter of allowing victims to access support in the UK is not just a humanitarian one. Baroness Butler-Sloss told us that the lack of proper support for victims had a negative impact on the number of successful prosecutions against slave masters.96 In 2015, 289 modern slavery offences were prosecuted and there were 113 convictions.97 In contrast 3,266 individuals were entered into the NRM and 1,043 were confirmed to be victims of modern slavery. Commenting on the rate of prosecutions, the Home Office Minister said that there was “no reason to expect a one-to-one correspondence between the numbers” and that some perpetrators may have been convicted under non-slavery offences.98 She added that witnesses did not necessarily need to be at a trial in order for a conviction to be secured.99

47.Baroness Butler-Sloss expressed concern that in some cases, where witness testimony was needed to secure convictions, the victim had disappeared after their entitlement to stay in a safe house expired:

One of the reasons is that the police cannot keep track of these people because they have no idea where they are, because they all disappear because they have no entitlements […] If you do not have the witnesses—speaking again as a former judge—you have a great difficulty in being able to have prosecutions, so it is in the public interest to keep these people with some entitlement in this country at least until the time when there has been a trial.100

She told us that a senior Metropolitan Police officer had spoken to the Human Trafficking Foundation about the problem:

He was talking about this problem about getting convictions because they cannot get the witnesses. It is not even, are witnesses prepared to give evidence? The fact is they cannot be found.101

48.Some victims may not wish to give evidence in court as it would be too distressing but others may be empowered by participating in a successful prosecution.102 There is some benefit provision for victims once they get to the point of giving evidence in court. Victims are treated as available and seeking employment by DWP, and therefore eligible for JSA, for up to eight weeks from the first attendance in court. After this, if the court advises that the victim will be needed for longer than eight weeks, the victim can close their JSA claim and claim Income Support, or claim for loss of benefit from the court.103

49.We received evidence, however, that this system of support is either too limited or not being properly applied. The Commissioner informed us of a case where four EEA victims of modern slavery were left sleeping rough for five months, despite appearing as witnesses in the successful prosecution of their slave masters. He said this highlighted the urgent need for more wide-ranging methods of support.104 West Yorkshire Police said a victim assisting with a prosecution had been “intimidated by the people linked to the suspects”.105 Despite the victim being unable to return to his home address, the local authority would not re-house him, leaving him homeless and at a risk of being lost to the police.106

50.The Commissioner explained that victims would be deterred from even coming forward and making accusations against their abusers if they believed they would not be supported:

My position is that one of the best forms of intelligence and information is from the victims, and if we are continually letting them down, how are we ever going to get the prosecutions and the confidence of victims to come forward?107

Kate Roberts agreed that the support for victims needed to be improved if the authorities expected victims to give evidence against slave masters. She told us:

For some victims they say, “You want me to give a lot of information about my trafficker, yet you are only guaranteeing me support in a very short term. What is going to happen to me beyond that and is that going to put me and my family in danger?”108

The Home Office Minister conceded that the estimated prevalence of modern slavery crimes in the UK vastly exceeded the number of victims who were coming forward to give evidence.109

51.The Commissioner also told us that the way the police handled cases of modern slavery needed to be improved. He told us:

Of the 3,200 referrals into the NRM (last year) that only translated into 884 crime reports by policing. There is a one in four chance of an investigation […] and when I say “investigated”, I mean even being recorded as a potential investigation. I know the numbers are not equal, but if there were 4,000 rapes in the UK and only one in four was ever recorded by the police, again, it would be an outcry.110

The Home Office Minister told us that there was currently a HM Inspectorate of Constabulary inspection of police training on modern slavery, including how the police identified victims.111 She also said a centre had recently been set up in order to “properly analyse and collect data between the police force, the National Crime Agency and anyone who has good information”.112

52.The number of successful prosecutions against individuals guilty of modern slavery offences is on an upwards trend. This is encouraging and testament to both the importance of the Modern Slavery Act and the work of the police and courts, but the numbers are still hugely disappointing. The police are not as active as they should be on this front. There are thousands of victims that have not come forward, potentially because they know that they will face limited support. Those that do and are asked to give evidence against their enslavers can, owing to insufficient support, end up destitute as a result. This can result in the inexcusable scenario that abusers go free because their victims are not supported in giving evidence against them. This is indefensible on policy grounds. It is also indefensible on moral grounds. We will refer the poor conviction rate to the Home Affairs Select Committee. We recommend that the Department for Work and Pensions undertake an urgent review of the benefit support available to victims who are assisting the police with investigations. Financial support for those victims should be available as soon as they receive a positive Conclusive Grounds decision.

20 Q9–11, (Client T)

21 Department for Work and Pensions and the Home Office (VMS0023)

22 Q178 (Sarah Newton)

23 Q130 (Kevin Hyland)

24 Ibid

25 Q108 (Kate Roberts)

27 Q121 (Kate Roberts)

28 Q130 (Kevin Hyland)

30 Q144 (Minister Sarah Newton)

31 Q155 (Baroness Butler-Sloss)

32 Greater London Authority Conservatives (VMS0028)

34 Ibid

35 Human Trafficking Foundation (VMS0015)

36 Q44 (Ann-Marie Douglas)

37 Q128 (Kate Roberts)

39 Q184 (Sarah Newton)

42 Q143 (Sarah Newton)

43 See Q149 (Sarah Newton)

44 In 2015 the Home Office also granted humanitarian protection to 7 non-EEA nationals and other forms of immigration leave to 3 non EEA nationals and 2 EEA nationals.

45 Letter from Kevin Hyland OBE, appended to correspondence to Stephen Crabb MP, April 2016

47 Ibid

49 Ibid

50 Ibid

51 Q150 (Sarah Newton)

52 UK Visas and Immigration, Guidance: EEA nationals: EUN01, September 2013

53 For example see Deighton Pierce Glynn (VMS0033) and Hestia (VMS0032)

54 Letter from Stephen Crabb MP, 8 July 2016

55 Q138 (Kevin Hyland)

56 Follow-up letter from Sarah Newton, 17 February 2017. The Home Office did not specify whether these were self-applications or police applications

58 Letter from Kevin Hyland OBE, appended to correspondence to Stephen Crabb MP, April 2016

59 CARE Christian Action Research and Education (VMS0006)

60 Office of the Independent Anti-Slavery Commissioner (VMS0005)

61 Ibid

62 Q158 (Sarah Newton)

63 Supplementary written evidence from CARE (Christian Action Research and Education) (VMS0037)

64 Medaille Trust (VMS0012)

65 Ibid

66 Hestia (VMS0032)

67 Ibid

68 Q133 (Kevin Hyland)

70 Q130 (Kevin Hyland)

71 Written Answer to Parliamentary Question, HL541

72 Q106 (Baroness Butler-Sloss)

73 Human Trafficking Foundation (VMS0015)

74 Q133 (Kevin Hyland)

75 Human Trafficking Foundation (VMS0015)

76 Letter from Kevin Hyland OBE, appended to correspondence to Stephen Crabb MP, April 2016

77 Q150 (Sarah Newton)

78 Q154 (Sarah Newton)

79 Supplementary written evidence from CARE (Christian Action Research and Education) (VMS0037)

80 Human Trafficking Foundation (VMS0024), Deighton Pierce Glynn (VMS0033) and the Independent Anti-slavery Commissioner (Q138)

81 Q77 and 78 (Key Worker S)

82 Q111 (Baroness Butler-Sloss)

83 Ibid (Baroness Butler-Sloss)

85 Q110 (Kate Roberts)

86 Q106 (Baroness Butler-Sloss)

87 Ibid

88 Q116 (Baroness Butler-Sloss)

89 Q138 (Kevin Hyland)

90 Q162 (Sarah Newton)

91 Ibid

93 Supplementary written evidence from Human Trafficking Foundation (VMS0036)

94 Ibid

95 Ibid

96 Q106 (Baroness Butler-Sloss)

97 Follow-up letter from Sarah Newton, 17 February 2017. An increase of 5 cases compared to the previous year.

98 Ibid

99 Q158 (Sarah Newton)

100 Q106 (Baroness Butler-Sloss)

101 Q115 (Baroness Butler-Sloss)

102 ATLEU (VMS0017)

104 Letter from Kevin Hyland OBE, appended to correspondence to Stephen Crabb MP, April 2016

105 West Yorkshire Police (VMS0001)

106 Ibid

107 Q130 (Kevin Hyland)

108 Q108 (Kate Roberts)

109 Q157 (Sarah Newton)

110 Q133 (Kevin Hyland)

111 Q157 (Sarah Newton)

112 Q167 (Sarah Newton)

27 April 2017