Hestia put forward this super-complaint through a report entitled Underground lives, Police response to victims of modern slavery, Hestia, March 2019. It raises various concerns about the police response to modern slavery, including how police identify, deal with and support victims of modern slavery, and how modern slavery crimes are investigated.
Hestia believes the current police response leads to victims not engaging with the police or supporting modern slavery investigations and prosecutions and that, as a consequence, offenders are not brought to justice. It is concerned that offenders are instead left free to continue their exploitation of vulnerable people, causing harm to both victims and the wider public interest. The public interest may be harmed, for example, if an individual victim or witness who is being exploited by an organised crime group (such as a group organising human trafficking) doesn’t feel able or confident to report the matter to the police or to support an investigation of the crimes committed. In this way, an opportunity is missed to prosecute the perpetrators and thereby protect the public from continuing criminal activities.
|Recommendation 1. To the Home Office
|Recommendation 2. To chief constables
Assure themselves that police officers and staff (including non-specialist staff, as appropriate) are supported through access to learning, specialist policing resources and victim support arrangements, so that officers and staff are able to:
|Material regarding Modern Slavery & Human Tracking (MSHT) is available via the Warwickshire Police force intranet to all officers and staff. This includes first response guides, investigator manuals and victim support information.
Updates to information are regularly communicated through force orders or via direct email to trained MSHT Victim Liaison Officers (VLO), MSHT Specialist Investigators, MSHT Tactical Advisors and Senior Investigating Officers (SIO’s).
Bitesize training programmes on MSHT, victim referral pathway and the National referral Mechanism (NRM) have been available to all officers from July 2021 from the online Managed Learning Environment.
The MSHT victim referral pathway, available on force systems, provides a duty investigator/tactical advisor function to provide support to officers or supervisors/managers.
|As part of their initial training, all student officers are provided with ½ day MSHT training including victim identification.
The bitesize training programme on MSHT (as above) includes victim identification
First Response investigator guides are available to all officers and staff electronically through force systems and physical copies have been distributed to Patrol teams.
MSHT Specialist Investigators (x32) & MSHT Victim Liaison Officers (x14) have received additional training and are available to provide specialist support to colleagues as appropriate.
MSHT VLO’s have been trained within Patrol, Safer Neighbourhood Teams (SNT) and the Domestic Abuse Unit (DAU) to provide a more effective resource to identify and provide immediate support to MSHT victims.
A force MSHT CPD event was held in February 2019, attended by over 100 officers, staff & partners. Presentations included police, NGOs, partner agencies and specialist organisations.
Force Crime Recording (FCR) & Designated Decision Makers (DDM) are aware of MSHT crime recording requirements; where information relating to MSHT is identified within a crime or incident and has not already been subject to accurate recording, officers are tasked to address this.
|MSHT Specialist Investigator and Victim Liaison Officer training includes this concept and the necessity for decision making (in line with the National Decision Model) in situations where victims may have been forced to commit offences.
National guidance on addressing potential section 45 defences or cases where victims may also be suspects (or vice versa) during initial custody procedures has been provided to all investigative teams and custody officers.
Warwickshire Police now sit on the CPS regional working group for MSHT to provide a more effective response to cases where victims may have been forced to commit offences or the section 45 defence is likely to be utilised.
Bitesize training programme on section 45 defences includes this concept and appropriate actions (available since August 2021)
|Bitesize training programme on MSHT provides this information, as do First Responder guides issued and provided via the force intranet.
MSHT Victim Liaison Officers & Specialist Investigators have received additional training enabling them to facilitate immediate steps to make victims feel safe.
Warwickshire Police are working with Warwickshire Community Safety Partnership (CSP) to develop a consistent countywide response to MSHT from all partner agencies within the county including consistent accommodation and victim support provisions across all Districts & Boroughs.
Warwickshire Police are a referring partner for the West Midlands Anti-Slavery Network (WMASN) ‘Safe Place’ facility which provides safe accommodation for adult male victims of MSHT pre-NRM.
|This is addressed within student initial training and MSHT specialist training programmes, which have also been provided to some OCC staff.
All officers have access to multi-lingual booklets published by WMASN which detail the support available through the NRM in an easy read format.
MSHT Victim Liaison Officers & Specialist Investigators have additional training to fully explain the range of support available to victims including support outside the NRM.
Ongoing work with Warwickshire CSP is intended to provide a capability within partner agencies to undertake this duty as first responders.
|Bitesize training programme on NRM explains this process and the necessity for good quality referrals as part of the MSHT response process in place of rushed referrals.
Force MSHT victim referral pathway and CATE (Child Abuse, Trafficking and Exploitation) processes include provision of multi-agency Sec 47 meetings for all child potential victims prior to NRM completion, to ensure referrals made are of good quality and by the most appropriate agency.
|Warwickshire Police now sit on a CPS regional working group for MSHT to provide a more effective response to cases where victims may have been forced to commit offences.
Bitesize training programme on Sec 45 defences includes this concept and appropriate actions (available since August 2021)
Additional training is planned for proactive investigation teams who most frequently encounter this within County-Lines cases.
|Recommendation 3. To chief constables
Assure themselves that their resources are being deployed to enable effective investigation of modern slavery offences (which may, for example, involve taking account of high levels of vulnerability and organised crime group involvement). They should assure themselves that their crime allocation processes direct investigations to the most appropriately skilled individuals and teams.
|Warwickshire crime allocation procedure identifies that MSHT investigations should ordinarily be investigated within local CID teams, with Proactive CID teams investigating ‘County Lines’ and the CATE team reviewing all MSHT investigations relating to children.
The crime allocation procedure has an identified escalation procedure.
Since 2020, Warwickshire Police have been delivering the national MSHT Specialist Investigators course and now have a total of 32 trained investigators across CID, proactive CID and CATE teams, who have the additional skills to investigate MSHT.
|Recommendation 4. To chief constables, and police and crime commissioners
Work together to understand the support needs of victims of modern slavery crimes. They should provide appropriate support within their respective remits to augment the national provision so that victims feel safe and empowered to remain involved in any investigations. This should focus on what support should be available before and after National Referral Mechanism (NRM) referral as well as alternative provision available for those declining NRM referral.
|Warwickshire Police are a referring partner for the West Midlands Anti-Slavery Network (WMASN) ‘Safe Place’ facility which provides safe accommodation for adult male victims of MSHT pre-NRM
Warwickshire Police are working with Warwickshire Community Safety Partnership (CSP) to develop a consistent countywide response to MSHT from all partner agencies within the county including consistent accommodation and victim support provisions across all districts & boroughs.
Warwickshire are currently implementing a Multi-Agency Risk Assessment Meeting (MARAM) process to allow agencies to better work together to support individuals with vulnerabilities who do not meet the criteria under the Care Act for adult care & support needs or equivalent mental health act provisions. It is anticipated this will include victims of MSHT.
The Office of the Police and Crime Commissioner (OPCC) for Warwickshire is in the process of commissioning a new Victim Needs Assessment and have incorporated the following into the terms of reference:
|Recommendation 6. Monitoring of recommendations
|Report provided by Warwickshire Police to HMICFRS via their online monitoring portal.
|Awaiting correspondence from the APCC to arrange.