It is imperative that the new UK Government takes steps to address modern slavery in its first 100 days.
Modern slavery impacts all of us. It is taking place in our communities: people forced to work in appalling conditions in factories, farms and car washes; or forced into sexual abuse; or young people controlled by gangs and forced to commit crimes. It is in the supply chains of what we eat and drink, the clothes we wear and the devices we use every day. In 2018, the Home Office estimated that modern slavery costs the UK up to £4.3 billion annually. Organised criminal networks, often involved in modern slavery, are making our streets less safe. Any future government will therefore have to implement a coordinated response at local, national and international level.
Taking action in the first 100 days would convey the appropriate urgency which this issue requires. It can also demonstrate a direction of travel for further action in the future.
In keeping with principles agreed by 60+ anti-slavery NGOs, we recommend the Government takes the following steps in its first 100 days:
Collaborate with those with lived and learned experience
1. Policy makers and those delivering services must prioritise engaging and consulting with communities at risk and survivors of modern slavery in a consistent and meaningful manner.
This is essential to effectively protect those in our communities most at risk of harm, including children and young people, as well as meeting survivors’ needs and reflecting their sense of justice.
Within the first 100 days, the Minister for Safeguarding must therefore meet with people with lived experience of modern slavery and NGOs with experience of working with survivors in their recovery.
Prevent modern slavery
2. Implement a cross-government response to modern slavery
To date the Home Office has led the UK’s response to modern slavery. A change in governance structure is necessary in order to avoid modern slavery being conflated with issues of immigration. Therefore a cross-government structure must be swiftly established, involving both central, devolved and local government, to deliver an effective and sustainable anti-slavery strategy.
3. Introduce legislation to protect workers’ and survivors’ rights
This legislation is much-needed in order to establish a Single Enforcement Body, enable secure reporting, end restrictive visas, and directly incorporate the European Convention on Action against Trafficking (ECAT). Such measures are critical to protecting workers suffering a range of exploitative and abusive working conditions, of which the most extreme cases amount to modern slavery.
Prioritise sustainable recovery
4. Amend statutory guidance to facilitate identification and access to support
As recently as May 2024, the statutory guidance produced under the Modern Slavery Act was amended, without consultation, to limit identification and support for survivors.
The government should work with experts with lived and learned experience to ensure that guidance reinforces survivors’ rights under ECAT and facilitates access to those rights in practice. In due course, Regulations under section 50 of the Modern Slavery Act should be introduced to ensure survivors’ rights are further protected and not reliant on guidance which can be easily and quickly amended.
5. Create guidance under the Victim and Prisoner Act 2024
The Justice Secretary is empowered to produce guidance for victim support roles. This should be utilised to create guidance for Independent Modern Slavery Advocates to help survivors navigate complex systems.
Uphold justice
6. Ensure survivors can access compensation
Amend the CICA scheme to recognise modern slavery as a crime of violence and allow survivors access to legal aid to apply for the scheme.
It is rare for survivors to succeed in claiming compensation from their traffickers due to the lack of an appropriate civil remedy. Workers’ Rights legislation should, therefore, be used to create a tort of modern slavery to facilitate compensation claims against traffickers and/or unscrupulous employers, targeting the financial gains they currently enjoy.
7. Strengthen the Transparency in Supply Chains provisions of the Modern Slavery Act
The Government has yet to implement commitments made to strengthen section 54 of the Modern Slavery Act. There is broad consensus in favour of amending the Act so that businesses are required to provide key information within their supply chain statement. In due course, introduce mandatory human rights and environmental due diligence legislation to ensure the UK keeps pace with requirements imposed on businesses around the world.
For further information, please contact euan.fraser@hopeforjustice.org.
