El proceso de inventario de los activos fijos (Álvarez, 2012).

these confusing circumstances, we chose to arrest her for being an

illegal immigrant.’

Deputy Chief Constable Giles York, Sussex Police, in evidence to the CSJ

‘The central problem is the excessive focus on trafficking as an

immigration crime.’

Detective Chief Inspector Sean O’Neil, Bedfordshire Police

“If a foreign national is trafficked, unfortunately they often get the

‘immigration’ label.”

Assistant Chief Constable Olivia Pinkney, ACPO lead on Migration and Associated Matters, in evidence to the CSJ

‘So what do we do when we find them? We charge them; we nick

them. Is that the best victim care?’

Anonymous police officer1

‘You’d think the victim would be the most important thing but that’s

not always the case.’

It Happens Here | Identifying victims 85

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immigration status and ask questions about their safety and security. It is crucial that modern slavery is separated from immigration in such a way that victims are better understood, and that the problem is responded to. Understanding modern slavery as an immigration issue is also unhelpful not least because a large portion of documented cases in the UK involve UK nationals or people from EU member states, where immigration is not a concern.

4.3 Equipping our frontline

Training and awareness support for frontline staff must be improved if the UK is to find victims and fight this crime. For adults, this includes the police, the UKBA and those working in the criminal justice system.

4.3.1 Identification by the police

Police officers have frequently told the CSJ about their concerns in regard to the lack of knowledge in their force, and the confusion over what human trafficking or modern slavery is. Police should be able to make an assessment when faced with this type of crime, so that victims can be identified and referred to the National Referral Mechanism and an investigation can commence. Without a basic level of training about human trafficking and modern slavery, officers’ responses, their ability to conduct an appropriate investigation and, most significantly, their knowledge of how to offer protection and support to a potential victim will be severely compromised.

2 Directive 2011/36/EU of the European Parliament and of the Council, of 5 April 2011, on preventing and combating trafficking in human beings and protecting its victims, and replacing Council Framework Decision 2002/629/JHA, Paragraph 25

3 The Independent, Police report into brothels dismissed as ‘amateurish’, 15 August 2010 [accessed via: http://www.independent.co.uk/news/ uk/crime/police-report-into-brothels-dismissed-as-amateurish-2053046.html (13/03/12)]

EU Directive 2011/36/EU on preventing and combating trafficking in human beings and protecting its victims, paragraph 25

‘Officials likely to come into contact with victims or potential victims of trafficking in human beings should be adequately trained to identify and deal with such victims. That training obligation should be promoted for members of the following categories when they are likely to come into contact with victims: police officers, border guards, immigration officials, public prosecutors, lawyers, members of the judiciary and court officials, labour inspectors, social, child and health care personnel and consular staff, but could, depending on local circumstances, also involve other groups of public officials who are likely

to encounter trafficking victims in their work.’ 2

‘Generally the country doesn’t want trafficking and we’re at a stage

where they’re trying to reduce the cost of policing by 25 per cent,

so you don’t want to be finding new problems.’

The size of the task before police officers is considerable; modern slavery is by its nature very hidden, and can take on numerous forms.4 _{Victims are often terrified, have been conditioned}

to tell a particular story, do not often see themselves as victims and may have secondary immigration issues. It is not an easy topic to tackle from a policing perspective, particularly in a climate of diminishing police resources.

The Metropolitan Police has developed an e-learning package, delivered through the National Centre of Applied Learning Technology (NCALT) which provides an easy-to-use module to raise awareness of the problem. However, some forces have reported that just two officers in the force have undergone this online training.5 _{Other forces have reported higher numbers}

– 229 officers in one force area – which is encouraging, though this remains a proportionally

low number of the entire force.6 _{Recent reports have shown that almost 90 per cent of}

officers in England and Wales have not accessed the training.7 _{We recommend that a modern}

slavery e-learning package becomes mandatory for all forces, in order to ensure effective sensitisation to this problem; the NCALT training package is an example of a cost-effective way of circulating training.

It is also the CSJ’s recommendation that more targeted and detailed training – as opposed to mere sensitisation – must be given to specific officers, as a matter of priority. The officers assigned to investigate these matters must have the necessary skills to manage the seriousness and complexity of the crime with an appropriately victim-centred approach. Senior Investigating Officers (SIOs), all immigration crime teams, all vice and drugs teams where they exist, and all custody sergeants should be aware of the indicators of human trafficking and modern slavery and the process to be followed upon identifying the victim(s) and investigating the crime. This training must include an awareness of the resources of the UKHTC. The CSJ acknowledges that this will be a challenge given the cuts to police resources

4 See Chapter One

5 Results of CSJ Freedom of Information request, August 2012 6 Ibid

7 Hansard, Written answers and statements, 11 February 2013 [accessed via: http://www.publications.parliament.uk/pa/cm201213/ cmhansrd/cm130211/text/130211w0002.htm#130211w0002.htm_spnew2 (14/02/13)]

‘There is…a lack of knowledge in how to identify a trafficking

victim…The more you deal with it, the more you recognise these

things, but then other people are completely oblivious to it.’

Senior police officer, in evidence to the CSJ

‘A lot of police forces don’t know about the NRM – they haven’t

heard of it. I think at this stage, they should have heard of it.’

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that have taken place and continue to be implemented.8 _{However the human cost of modern}

slavery is too great to be side-lined any longer, and must become a force priority across the country; adequate training is therefore a crucial first step. There should be a role here for businesses and their corporate social responsibility (CSR) agendas: the training of police is a key area for improvement in the UK’s approach to modern slavery and new and innovative funding streams should be explored.

Currently, the limited training available for police is ad hoc and unmonitored, with some forces accepting training from NGOs who are not under any quality assurance standards or from private consultancy companies which are unaccredited. One police officer gave evidence to the CSJ voicing their concerns at the messages that were being communicated by campaigning NGOs.9 _{This is an inefficient use of time and resources, is not cost-effective}

and can have a damaging effect on frontline services’ awareness levels which will then vary depending on what standard of training they have received. The CSJ recommends that the Anti-Slavery Commissioner should develop a system of monitoring or accreditation of available training, ensuring accurate core content, whilst recognising the need for localised specialisms developed by various NGOs and other groups.

Evidence taken by the CSJ reveals how police officers can easily overlook modern slavery victims when engaged with issues related to, for example, brothels or cannabis farms. They are not trained to identify the signs and they are not being tasked to look for it. This, combined with the fact that victims in these situations have often been conditioned to stay silent or repeat a fabricated story, creates a worrying set of circumstances whereby an unknown number of modern slavery victims are not being identified. As one police officer candidly explained: “We do ask if they are a victim of trafficking, but have been told ‘no’. Whether that’s true or not, I’m not sure”.10

8 Metropolitan Police Service, Policing in austerity: One year on, London: Metropolitan Police Service, 2012, p3 9 Senior police officer, Metropolitan Police, in evidence to the CSJ

10 Detective Constable, Nottinghamshire Police, in evidence to the CSJ

‘A lot of people think trafficking is being snatched, tied up and put

in a boot and locked in a room – there is an element of freedom

which I think they struggle to understand. But what about being

ruled by fear? Fear of ending up in a shallow grave.’

Detective Constable Stuart King, West Yorkshire Police, in evidence to the CSJ

‘The nuances of theft are understood among the police. The

nuances of human trafficking are less easy to understand.’

It is important to highlight the challenges here – it is understandable that police officers treat those who appear to be cultivating drugs, for example, as people who are breaking the law. However it is imperative that the added perspective of potential victimisation is included in any police activity that engages with those who may be in situations of modern slavery. An example of a model of best practice can be seen in Bristol, where voluntary sector organisation Unseen has supported the work of Avon and Somerset police. This partnership approach ensures that the police force liaises with Unseen when it is planning an operation on a cannabis farm in the area. During briefings before a raid, officers are informed of the indicators of modern slavery and their duty of care is explained. Unseen has also established an on-call service whereby police are able to call at any time if they suspect they may have identified a victim of modern slavery.11

4.3.2 Identification by the Gangmasters Licensing Authority

The Gangmasters Licensing Authority (GLA) was established in 2005 under the Gangmasters (Licensing) Act 2004, following the death of a number of Chinese workers forced to pick cockles in Morecambe Bay in northwest England. The unpredictable tides swept many out to sea, and 23 were drowned. During the resulting investigation, it came to light that these individuals had been trafficked into modern slavery and were forced into accommodation, driven to the bay and made to work long hours for very little pay. The GLA was subsequently set up to protect workers from exploitation through a system of licensing which helped to regulate labour providers supplying workers to the fresh produce supply chain (agriculture, horticulture, forestry, fish processing, gathering shellfish, dairy farming and packaging/processing food and drink products) and those who use these workers. The GLA regulates this form of employment to help in the identification of potential vulnerabilities.

11 Kate Garbers, Co-Founder and Project Director, Unseen, in evidence to the CSJ, December 2012

‘We should be looking for the story behind this person, not looking

for a quick fix…who is giving this person the opportunity to talk?’

Team member, Sussex Police, in evidence to the CSJ

Recommendations:

„

„ All officers should be sensitised to the basic indicators of modern slavery and human trafficking, and be aware of who they should speak to if these indicators are present; this will be fulfilled by every officer completing, on a mandatory basis, the National Centre for Applied Learning Technologies (NCALT) e-learning package (or equivalent). This should form part of police officers’ Continued Professional Development;

„

„ The Anti-Slavery Commissioner should develop a system of accreditation of training packages used by statutory authorities such as the police;

„

„ There should be more detailed, practical training for Senior Investigating Officers, vice teams, drug teams and Custody Sergeants.

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The GLA estimates that up to 55 per cent of the businesses it licenses also operate in sectors outside of its remit, without similar levels of accountability or regulation; Figure 4.1 is a graph, based on data submitted by the GLA to the CSJ review, showing the additional sectors in which GLA-licensed businesses also operate. These include non-food manufacturing, administration and office work, transport and construction.

It is unrealistic to expect that a large proportion of labour providers which operate outside sectors that the GLA regulates are applying the standards expected by the GLA to those other sectors. The CSJ is troubled by this disparity and reiterates the call for an extension to the remit of the GLA to include additional sectors where high volume, cheap labour is employed. This is not to create a more restrictive environment for businesses, but is simply to ensure that existing standards are being implemented and workers are being protected. Increased transparency in these sectors will also be a step towards improving the picture of modern slavery in the UK; the GLA holds valuable information on the exploitation of workers in the sectors it currently monitors, and it is essential that similar information is gathered in sectors which are currently beyond its remit.

‘There is a risk that slave gangmasters will move away from food