Crime and Policing Bill

Written evidence submitted by POW Nottingham (CPB78)

Summary

1. This submission outlines POW Nottingham’s concerns and recommendations regarding proposed changes under the Crime and Policing Bill (2025), particularly clauses NC1–NC3, which relate to prostitution, commercial sexual exploitation, and victim identification. As an organisation that works directly with individuals in the sex industry-including those who have experienced exploitation-we urge Parliament to take a rights-based, evidence-informed approach to protect the safety and wellbeing of sex workers and survivors of trafficking alike.

About POW Nottingham

2. POW Nottingham is a non-profit, peer-led organisation supporting the rights, safety, and health of individuals in the sex industry. We provide non-judgemental support, outreach, advocacy, and harm reduction services to people with lived experience of sex work, including those at risk of, or subject to, exploitation and coercion. We work closely with statutory and voluntary agencies across Nottinghamshire and hold long-standing relationships with local law enforcement and public health teams.

Evidence

Sexual Exploitation

3. We recognise the very real harms of sexual exploitation and trafficking, and we support robust, victim-centred efforts to combat these crimes. However, it is vital to distinguish between consensual adult sex work and exploitative practices. Legislation that conflates the two risks pushing vulnerable individuals further from support and into more dangerous environments.

NC1: Profiting from the Prostitution of Others

4. We are concerned that the proposed offence in NC1 risks criminalising individuals who are not exploiters, including those who offer safety, security, or mutual support in shared working arrangements. This clause may:

· Undermine safety for sex workers.

· Criminalise third parties such as landlords, security staff, or even peers, regardless of whether exploitation is present. It may deny sex workers the ability to define exploitation how they experience it and there would be no legal difference between someone providing support to a sex worker and someone who causes genuine harm or violence to a sex worker.

· Disincentivise harm-reduction models and all support systems.

5. Research has shown that criminalising shared working arrangements forces sex workers into more isolated conditions, increasing their risk of violence and reducing access to support (Pitcher & Wijers, 2014; Sanders et al., 2018).

NC2: Commercial Sexual Exploitation

6. The definition of "commercial sexual exploitation" under NC2 is overly broad and risks conflating sex work and exploitation. This could lead to:

· Increased policing of sex workers rather than exploiters.

· Displacement of sex workers into more hidden, isolated settings.

· Greater barriers to accessing support, health services, and justice.

7. The criminalisation of adult services websites and the purchase of sex has been implemented in various countries, often with harmful and unintended consequences-both for individuals who sell sex and for those who are victims of sexual exploitation and trafficking (Platt et al., 2018; Amnesty International, 2016; Le Bail & Giametta, 2018). Evidence from Sweden, Canada, and France suggests that these laws have increased stigma and violence against sex workers, while failing to meaningfully reduce trafficking (Global Alliance Against Traffic in Women, 2011). We support the decriminalisation of sex work, in identifying a key distinction between sex work and exploitation, to grant sex workers rights that enable their safety within their work.

NC3: Removal of offences for loitering and soliciting for the purposes of prostitution

8. We welcome efforts to identify and support victims of exploitation. However, the measures outlined must be underpinned by:

· Trauma-informed practice.

· The involvement of specialist support organisations.

· A clear distinction between coercion and consensual activity.

9. Without careful implementation, there is a real risk that those most in need will be retraumatised by enforcement-led approaches. A review by the Home Office (2020) has acknowledged that police-led operations without sufficient support frameworks can deter victims from engaging with services.

Additional Concerns

· Lack of Consultation with Lived Experience: We are not aware of meaningful consultation with sex workers or survivor-led organisations in drafting these clauses. Policy that impacts marginalised communities must be developed with their direct input (SWARM, 2020).

· Risk of Increased Stigma and Surveillance: The Bill may lead to increased monitoring and punitive measures against individuals already marginalised by poverty, migration status, or gender-based violence.

· Impact on Outreach and Engagement: Raids and enforcement can fracture trust, making it harder for support organisations like ours to reach those most at risk (Armstrong, 2021).

Recommendations

1. Separate Sex Work from Exploitation in Law and Practice: Create clear legal distinctions between consensual adult sex work and exploitative practices to ensure protection without criminalisation.

2. Decriminalise Sex Work: Evidence shows that decriminalisation reduces harm and improves outcomes for safety, health, and trafficking prevention (WHO, 2012; UNAIDS, 2014).

3. Include Lived Experience in Policymaking: Engage sex worker-led and survivor-led organisations in all legislative processes impacting their communities.

4. Prioritise Safeguarding over Enforcement: Ensure operations to identify victims are led by safeguarding principles, with pre-planned support from specialist services.

5. Amend or Remove NC1 and NC2: Re-examine clauses that risk criminalising safety strategies and support networks.

6. Ensure Definitions Are Precise: Clarify what constitutes "commercial sexual exploitation" to avoid sweeping and harmful generalisations.

References

· Amnesty International. (2016). The Human Cost of ‘Crushing’ the Market: Criminalization of Sex Work in Norway. Retrieved from https://www.amnesty.org/en/documents/eur36/4034/2016/en/

· Armstrong, L. (2021). Decriminalisation and the policing of sex work: A research report on New Zealand's model. University of Wellington.

· Global Alliance Against Traffic in Women. (2011). Moving Beyond 'Supply and Demand' Catchphrases: Assessing the uses and limitations of demand-based approaches in anti-trafficking.

· Home Office. (2020). Review of Modern Slavery Strategy and Victim Engagement.

· Le Bail, H., & Giametta, C. (2018). What do sex workers think about the French Prostitution Act? Medecins du Monde.

· Pitcher, J., & Wijers, M. (2014). The impact of different regulatory models on the working conditions, safety and welfare of indoor-based sex workers. Criminology & Criminal Justice, 14(5), 549–564.

· Platt, L., Grenfell, P., Meiksin, R., Elmes, J., Sherman, S. G., Sanders, T., & Stoebenau, K. (2018). Associations between sex work laws and sex workers’ health: A systematic review and meta-analysis. PLOS Medicine, 15(12), e1002680. https://doi.org/10.1371/journal.pmed.1002680

· Sanders, T., Scoular, J., Campbell, R., Pitcher, J., & Cunningham, S. (2018). Internet sex work: Beyond the gaze. Palgrave Macmillan.

· SWARM. (2020). Statement on legislative approaches to sex work in the UK. Sex Worker Advocacy and Resistance Movement.

· UNAIDS. (2014). The Gap Report: Sex workers.

· World Health Organization. (2012). Prevention and treatment of HIV and other sexually transmitted infections for sex workers in low- and middle-income countries.

April 2025