Rendimiento por planta de primera categoría kg/planta

Evidence given to the CSJ has suggested that the Salvation Army model of subcontracting has worked well since it began in July 2011, enabling the UK to provide a range of appropriate accommodation for both men and women and helping those survivors who need to move away from their current location to do so.17 _{The purpose of the new contract was to ensure}

a wider range of services was available, across a wider variety of geographical locations, accessible to a wider range of people. In order to achieve this, organisations that have experience in supporting vulnerable people have had their awareness drawn to the issue of modern slavery and are now able to support this group of vulnerable individuals as part of a broadening of their existing services. However, one enduring concern raised during the course of the CSJ’s evidence gathering is the lack of any minimum standards of care for the variety of aftercare providers offering support in the UK.

Whilst a variety of approaches is to be welcomed there is a need for consistency across all organisations which are providing support. This includes elements such as: an organisation’s approach to providing supporting evidence for a NRM decision; the nature of the support they give during an asylum application or any other legal process the individual may be involved in; and the way in which they support survivors and link them with other services when it is time for them to move on. The quality and scope of aftercare provision was mixed from region to region: the CSJ has seen a substantial need for guidance on minimum standards of care. This is a void that has been filled to some extent by NGOs in the sector; through work with the Human Trafficking Foundation (HTF) – a forum for organisations working in anti-trafficking – some NGOs have developed a group to establish the key elements that should be consistent across the spectrum of provision. This is a good example of coordination among voluntary sector organisations. Local provision is welcome, but monitoring minimum standards is essential practice in this area. It is therefore the CSJ’s recommendation that agreed minimum standards of care, encased in a guidance document for aftercare providers,

It Happens Here | Supporting survivors 165

six

are overseen by the Ministry of Justice. Organisations working outside of the Ministry of Justice contract should also be subject to these minimum standards in a voluntary capacity, and will be advantaged by adopting them should they seek sub-contractual arrangements in the future. Guidelines should not be limited only to those operating under the contract. A similar recommendation was made by the Office for Security and Coordination in Europe (OSCE) in January 2012, after the Special Representative for Combating Trafficking in Human Beings visited the UK. The Special Representative recommended that the UK ‘ensure that quality standards for victim services are maintained while centralizing the co-ordination and the management of the provision of care’.18

6.4.1 Decision making: contributing to the process

Whilst an individual is being supported by the aftercare provider, a parallel process is ongoing whereby the NRM Competent Authorities are gathering information to make a decision about whether the person has been trafficked. Aftercare providers both within and outside of the Ministry of Justice contract expressed confusion over how they can best contribute to the important decisions that are made by the Competent Authorities.19 _{The first concern}

among aftercare organisations focussed on how they should best share information with the decision-maker. The second area of uncertainty surrounded what kind of information should be shared: many aftercare providers were not clear about what information was relevant and whether it should be forwarded as evidence for the decision. This lack of clarity has led to a situation where, across the country, approaches to information sharing vary greatly. The Special Representative upon her visit recommended that the UK should establish:

‘Formalized mechanisms for recognition of the role of experienced NGOs, service providers and social partners during the identification process…[they] should not only have authority to initiate referrals of presumed victims but should also formally contribute with their opinion to the decision making on victim identification by the competent authorities’.20

6.4.2 How should information be shared?

Aftercare providers have raised the subject of how they should contribute to the decision- making process for a Conclusive Grounds decision. It became clear during our research that aftercare providers are unsure of the method and frequency with which they should

18 Giammarinaro MG, Report by Organisation for Security and Cooperation in Europe Special Representative and Co-ordinator for Combating Trafficking in Human Beings, following her visit to the UK, 7–10 March 2011, Vienna: OSCE, January 2012, p6

19 For a full explanation of the role of Competent Authorities in the NRM, see Chapter Three

20 Giammarinaro MG, Report by Organisation for Security and Cooperation in Europe Special Representative and Co-ordinator for Combating Trafficking in Human Beings, following her visit to the UK, 7–10 March 2011, Vienna: OSCE, January 2012, p6

Recommendation:

„

„ Agreed and monitored minimum standards of care provision should be established for aftercare providers.

be contributing information to the decisions of the Competent Authority. Subcontracted aftercare providers are not only significant actors in the process of safeguarding and supporting an individual, but also hold important information about the people with whom they work.

It is therefore essential that these organisations are subject to clear and concise guidance as to what is expected of them, and how they can contribute to a fair and just decision. It is important that Competent Authorities recognise the unique perspective that aftercare providers can offer: at present ‘the opinion of experienced frontline staff is not always given due weight’.21 _{Keyworkers for aftercare organisations spend a sustained period of time with}

individuals, building trust as the individual begins to feel safe.

Aftercare providers are in a prime position to develop a ‘sound understanding of the risks, ethical considerations, and the practical realities related to trafficking [which] can…increase the likelihood that a [victim] will disclose relevant and accurate information’.22 _{This fact must}

not be disregarded. Though aftercare providers and the Competent Authority have different and distinct roles – one to provide support and one to make a fair decision – there is a need for greater understanding between the two agencies. As much information as possible must be gathered in order to provide the Competent Authority with enough insight to make an informed decision. One aftercare provider in the South West has recognised this problem and developed a pro forma document as a means of passing information to a Competent

Authority in an unbiased and standardised way.23 _{However reception of this document by}

Competent Authorities has been mixed, highlighting the inconsistent approaches across the country and the need for a standard process for information to be submitted.

The UKBA Competent Authority guidance says that ‘decision makers should proactively contact the support provider, the first responder, the investigating police force and the Local Authority (in the case of children) to consider whether an extension of the reflection period is warranted’.24 _{It is worrying however that this active seeking of information is often not}

happening. There was a general consensus among all aftercare providers spoken to that much more comprehensive guidance on how to feed evidence to a Competent Authority is crucial to ensuring a fair decision, regardless of where and by which organisation the individual is supported. It is the CSJ’s recommendation that, based on best practice in Bristol, a pro forma document is submitted by all aftercare agencies to the Competent Authority to enable

21 GRETA, Report concerning the implementation of the Council of Europe Convention on Action against Trafficking in Human Beings by the United Kingdom; First evaluation round, Strasbourg: GRETA, September 2012, p51

22 Watts C and Zimmerman C, Ethical and Safety Recommendations for Interviewing Trafficked Women, Geneva: World Health Organisation, 2003, p1

23 Unseen, in evidence to the CSJ, July 2012

24 UKBA, Guidance for Competent Authorities, p33 [accessed via: http://www.ukba.homeoffice.gov.uk/sitecontent/documents/policyandlaw/ asylumprocessguidance/specialcases/guidance/competent-guidance?view=Binary (18/10/11)]

‘They’ll tell you things they won’t tell anyone else.’

It Happens Here | Supporting survivors 167

six

them to make a fair and just final decision. A pro forma approach would also take away the responsibility from the aftercare provider to decide whether information is detrimental to the individual; it would remove the potential for bias. Also included should be an agreed updating procedure, enabling aftercare providers to update the Competent Authority with new information – such as disclosures from the individual – as necessary.

6.4.3 What information should be shared?

Additionally, aftercare organisations are largely unclear as to what level and form of information or evidence they are required to communicate to the Competent Authority and how frequently they should update them. The value of different documents to the decision-making process – such as medical certificates or counsellor’s letters – should also be made clear. Once again, the CSJ was given the impression of national inconsistency. Some organisations have a very positive relationship with their local Competent Authority with regular contact over the telephone when new evidence or information is disclosed. Others submit a substantial report for every individual they work with, including documentation of the individual’s mood and attitudes. Still others only provide information if and when it is elicited directly by the Competent Authority. Some Competent Authorities are therefore overwhelmed with detail, whereas others will not receive the detail they need unless they directly approach the aftercare provider.

Much research has been conducted into the impact and effect of trauma on a person’s ability to interact with others and their capacity to remember and recount traumatic experiences, particularly when under pressure to do so. Research shows that ‘the accounts of many victims

‘They need to give us credibility for the information we pass on –

we work with them [survivors] 24/7 and they tell us things they

would not tell a Competent Authority due to trust issues.’

Becky, victim support worker, in evidence to the CSJ

Recommendation:

„

„ Guidance should be given from Competent Authorities on the information needed from aftercare providers. A pro forma document outlining the evidence and information required should be used as standard practice.

‘A report should be the only standard way of feeding in to the

decision makers. It’s not standard procedure now, but it should be.’

are filled with omissions, distortions, and outright contradictions. Many struggle to recall what happened or how and why they behaved in the way they did’.25 _{It is therefore essential that}

a survivor’s vulnerabilities are recognised and the insight of a key worker is legitimised.