How can the government work alongside organisations in other sectors, including all groups and individuals in British society, to shape the national approach to modern slavery? This post provides a discussion of why this multifaceted strategy is the most effective way forward.
Portugal Street, Holborn, London.
Holborn and Russell Square are home to two of the largest and most popular soup kitchens in London; they are also well-known trafficking hubs. Many of these areas exist in the UK, where, as the photographer Amy Romer investigates, traffickers select the most vulnerable out from areas where the homeless and unemployed congregate. Although unremarkable scenes at first glance, these pictures undoubtedly represent the hidden nature of slavery. Source: The Dark Figure by Amy Romer
Modern Slavery is not a new threat facing the UK, but indeed an ancient, entangled and evolving issue that we have come to accept as a ‘given’ in today’s society. And yet in the same breath we are shocked by the number and forms of slavery revealed to be entrapped in British culture and supply chains. We are both regularly apathetic and yet indignant at the prevalence and impact of the issue. For an interesting contrast, according to the estimate from the Global Slavery Index (GSI) (1), there are more modern slavery victims in the UK than there are NHS doctors in England (2). So, in theory, if every modern slavery survivor received the treatment they deserve from state healthcare, there may possibly be more patients than doctors. Moreover, 136,000 is still a modest figure given the complex and numerous barriers concealing many unreported cases of trafficking and the discrepancies in methods used for measuring. Clearly this is a mainstream problem, but one that persists by safety in inconspicuous or uninviting corners, lost in the business of daily routines for the ‘many’. It’s all too easy to dismiss the problem when it can hide behind the new normal of modern life.
This blog post looks at a couple of important examples of efforts from both the UK government and NGOs to tackle slavery, and reasons that several types of both are needed to have any significant impact on the rising trend of victims in the UK. It should be noted this discussion merely scratches the surface of legislation and action taken to address slavery in the UK. There is no one entity, strategy or program that can claim to be effective at reducing cases on its own. This is a fact which arguably should be attributed to the deep and far-reaching roots of slavery that are tied up in the functioning of life as we know (or decide to know) it.
Taking a look at the process and impact of anti-slavery legislation in the UK:
Photo: Protest outside of the Parliament demanding protections for overseas domestic workers.
Source: Anti Slavery International
This is an example of how the Modern Slavery Act has been a welcomed step forward in uniting action against slavery and trafficking, however there is still significant concern from human rights groups about the effectiveness of the Act in fulfilling its potential to help survivors. Further analysis of the act by Anti Slavery International can be read here.
As part of an international renewed incentive to tackle modern slavery in recent years, the UK has strengthened its stance, particularly with the Modern Slavery Act in 2015. This Act has largely been regarded by the global anti-trafficking community as a positive and relatively successful development. One way to observe this success is through an independent review of the Act, which highlights the importance of the Independent Anti-Slavery Commissioner established in 2015. (3)
Findings suggest introducing an independent Commissioner has been significant in aligning the UK’s response to modern slavery with best practice, improving the national approach to tackling offences and assisting identifying victims. However, there is consensus among stakeholders that to be more effective the Commissioner’s function must be allowed to encourage accountability, transparency and cooperation. Currently many agree this function is limited and restrained by the Government. For example, it is noted that a key process assessing the Commissioner’s effectiveness is carried out by Home Office officials. Many would argue that this process being in the hands of the Home Office defeats the purpose of the Commissioner to be able to critically evaluate and advise on government action against slavery. Any new initiative which does not have effective processes to ensure accountability will be less likely to achieve the desired results.
It could be suggested that an initiative should involve multiple entities operating within distinct channels in order to be the most beneficial in ensuring accountability and a balanced agenda. In practice this initiative could look like private monitoring bodies reporting on government activities or service provision for survivors being composed of both government departments and private organisations that share common objectives with the government.
In contrast, several government initiatives are set up to take on different parts of the anti-trafficking strategy but share staff, resources, budgets and monitoring and evaluation systems. This system may make action sluggish with lengthy operative and communication processes and opportunities for information sharing and transparency may become less formal and more haphazard. However, this is closer to the UK’s current system. Therefore, it is important we advocate for establishing a network of government and independent groups which includes monitoring bodies and businesses. This network would still provide opportunities for partnerships that each serve a specific purpose, but avoid the government’s resources, motivation and application of legislation being stretched too thin.
However, the Commissioner does still facilitate successful cooperation between government agencies and other sectors and interest groups. This facilitation can allow for greater efficiency through joined up services while still ensuring greater accountability in the systems put in place to form the plan for preventing and tackling slavery. Where slavery permeates each branch of society, so must we use a strategy that incorporates government, the public sector and consumers.
Clearly, then, in order to develop a strategy that tackles slavery at every stage of the process, there must be overlap with monitoring, service provision and policy design. It is a delicate but critical balance between independence and efficient partnership in order to tackle slavery at its roots, but also where it is hanging on by a thread.
A joint report by the Anti-Slavery Commissioner and the University of Nottingham in 2017 (2) aims to add to the limited data analysing the implementation of the Modern Slavery Act and how it has tried to stimulate multi-agency partnership in the sector. The report indicates the government’s strategy is starting to prioritise collaboration and highlights some examples of positive practice. However, there is still a considerable lack of specific guidance and no dedicated funding for partnership activity. It could be argued that there is a link between half measures such as these and the presence of gaps in the overall strategy to tackle slavery, which is shown where the Act has not been fully implemented to effectively facilitate organisations working together. This means potential progression in prevention, intervention and aftercare services for modern slavery victims fails to happen, in part due to missed opportunities in mechanisms of communication and shared resources and information.
The report also maps the existing UK partnerships and notes some important characteristics.
Image: Map showing the national/regional partnerships by police force area. The report explains they vary in their arrangement and the type of principles they are based on. Maps showing sub-regional and local level partnerships differ in character, e.g. Scotland and Wales have much higher concentrations of national partnerships than England and yet have very few smaller scale partnership efforts. Moreover, going beyond what the maps tell us, we can observe current trends such as newer partnerships more often taking the form of informal groups and networks.
Source: Report from the Office of the Independent Anti-Slavery Commissioner and the University of Nottingham’s Rights Lab,, ‘Collaborating for freedom: anti-slavery partnerships in the UK’ (4)
Interestingly, most current partnerships are headed by the Police and so naturally coordinated on their force boundaries. Indeed, the majority of UK survey and interview responses agreed that the tendency for police leadership has sustained a narrow focus on enforcement, instead of moving onto strategies and activities beyond prosecution. E.g. A strategy could include engaging agencies in leading efforts in prevention or access to services for survivors, and so providing part of the overall strategy more appropriately implemented by community partners and NGOs rather than police and government officials. However, currently there is still reluctance to transition partnership from just an enforcement focus to wider community resilience. Furthermore, the function of partnerships remains largely to improve intelligence sharing, training of frontline staff and raising awareness, as opposed to undertaking joint commissioning or wider societal issues like supply chains. Should we be asking ourselves: if partnerships are producing positive outcomes in information sharing activities, are we prepared to start rewriting the structures and procedures to make our ‘on-the-ground’ measures more effective? Even if that means extra time and effort to ensure input and transparency between all entities involved.
Encouraging engagement with several different stakeholders is also highlighted by the British Asian Trust who propose the importance of the collaborative and advisory role of NGOs regarding the development of anti-slavery legislation (1). This could have been very effective for example, in using their specific expertise to inform various sections of The Modern Slavery Act, as well as to promote cohesion and transparency in the processes of developing and implementing the legislation. However there has been some positive action already taken from NGOs regarding the Act, which is crucial to show the potential benefits of involving NGOs more closely with the government strategy.
For example, the Corporate Justice Coalition led a report in partnership with several other organisations, which seeks to provide analysis and guidance for companies on how to incorporate the new reporting requirement into their supply chains and business activities. The Report, ‘Beyond Compliance: Effective Reporting under the Modern Slavery Act,’ (2) interprets the legislation for companies by providing them with guidance for wider due diligence when seeking out slavery in their supply chains.
Including NGO input in the due diligence processes of businesses is vital in promoting transparency and accountability for investigations and monitoring of activities in supply chains and production. Equally, structures should be put in place to allow NGOs to report and discuss concerns with government figures to ensure workers actually start to benefit from improvements agreed upon by all sectors: private and public; state and non-state.
This is such an important function for connecting the positive policy change with the follow-up actions needed to actually produce the intended result: eliminating slavery in some form. The great variety of NGOs involved also allowed each organisation to contribute to the final document using their specific expertise in an area of anti-trafficking work. Bridging the gap between civil society and government has proved necessary in making the overall strategy against slavery more robust and encourages uptake of new laws and policies.
So far, seven years into application of the Modern Slavery Act, the situation in the UK still requires attention. We suggest that joined-up action taken on by every sector is the way forward. By starting or continuing to seal up the holes in the projects and laws tackling modern slavery, and tying them together with partnerships, accountability and transparency, we can hope, with confidence in these actions, that fewer and fewer victims will slip through the gaps. References
(1) Global Slavery Index, (2018) Walk Free Foundation in partnership with the International Labour Organization (ILO) and the International Organization for Migration (IOM), Retrieved March 24 2022, from https://www.globalslaveryindex.org/2018/data/country-data/united-kingdom/
(2) UK Government Press Release, (25 March 2021) Department of Health and Social Care, Retrieved March 24 2022, from https://www.gov.uk/government/news/record-number-of-nhs-doctors-and-nurses-in-england
(3) Field, F et al (2019) Independent Review of the Modern Slavery Act 2015: Final Report The Secretary of State for the Home Department by Command of Her Majesty, Retrieved March 29 2022, from https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/803406/Independent_review_of_the_Modern_Slavery_Act_-_final_report.pdf
(4) A research report from the Office of the Independent Anti-Slavery Commissioner and the University of Nottingham’s Rights Lab, (October 2017), Collaborating for freedom: anti-slavery partnerships in the UK, Retrieved 29 March 2022, from https://www.antislaverycommissioner.co.uk/media/1186/collaborating-for-freedom_anti-slavery-partnerships-in-the-uk.pdf
(5) Kevin Groome, Anti-trafficking Programme Lead, the British Asian Trust (17 May 2019), NGOs play a leading role in developing Modern Day Slavery legislation, Retrieved 29 March 2022, from https://www.britishasiantrust.org/latest/blogs/ngos-play-a-leading-role-in-developing-modern-day-slavery-legislation/
(6) News Update by Corporate Justice Coalition, Authored by the Corporate Justice Coalition, (7 March 2016), NGOs Publish New Guidance For Companies On Reporting Under The Modern Slavery Act, Retrieved 29 March 2022, from https://corporatejusticecoalition.org/news/ngos-publish-new-guidance-for-companies-on-reporting-under-the-modern-slavery-act/
(7) Beyond Compliance: Effective Reporting under the Modern Slavery Act, Core Coalition (March, 2016), Retrieved March 29 2022, from https://corporatejusticecoalition.org/wp-content/uploads/2016/03/CSO_TISC_guidance_final_digitalversion_16.03.16.pdf