Modern slavery strategy update: LGA submission, November 2021

The Local Government Association (LGA) is the national voice of local government. We work with councils to support, promote and improve local government. We are a politically-led, cross party organisation which works on behalf of councils to ensure local government has a strong, credible voice with national government. We aim to influence and set the political agenda on the issues that matter to councils so they are able to deliver local solutions to national problems.

This summary paper sets out some of the issues that councils are grappling with in their work on modern slavery and is intended to assist the Government as it works to refresh and update its modern slavery strategy. In particular, it sets out some of the challenges councils are experiencing in supporting victims of modern slavery and highlights issues for the Home Office to consider as it continues to reform the National Referral Mechanism (NRM) system.

Councils have a multi-faceted role to play in relation to modern slavery. In terms of disruption, they have various responsibilities and levers:

• Through their regulatory role interacting with local businesses and landlords, council officers are well placed to identify cases of modern slavery and work with law enforcement partners to use regulatory tools to intervene and disrupt it.
• As members of community safety partnerships (and in some places Violence Reduction Units) and subject to a statutory duty to do all that they reasonably can to prevent crime and disorder in their areas, councils are engaged in activity to disrupt criminality such as modern slavery.
• Through their individual and collective buying power, councils have significant leverage to seek to eradicate modern slavery from their extensive supply chains.

Councils also have a role to play in providing support to victims of modern slavery. The picture is complex and varies from case to case, but may incorporate the following service provision:

• Children’s safeguarding and social care, for child victims.
• Housing
• Adult safeguarding and social care, including community mental health support
• Substance misuse treatment
• Support for people with no recourse to public funds (NRPF).

Between 2014 and 2020 the number of referrals into the NRM by councils has grown significantly: rising from 143 to 2,653 child victims and from 29 to 296 adult victims. Alongside an increase in the number child criminal exploitation cases during that time, this also reflects a growing awareness among council officers of modern slavery as a critical issue. However, there is more to do to strengthen and improve practice in terms of recognising and understanding slavery, and in so doing, to improve the ability for councils to support victims and disrupt traffickers. The sector-led support model is the accepted approach for strengthening local authorities’ work in different areas; the Government should consider how this model could help strengthen the response to modern slavery, and consider including it as an objective in the overall programme of support agreed with the LGA and wider sector.

Beyond this type of support, we believe there are two factors that are critical to further developing the response to modern slavery:

Firstly, we need to create clarity, and embed understanding and recognition of modern slavery, throughout key professions, systems and in relevant domestic legislation:

• Training for occupations where officers interact with victims of modern slavery – including social care, housing and law enforcement – should incorporate modern slavery within initial professional training, organisational inductions and continuous professional development to help ensure awareness of modern slavery is evenly spread across key workforces. This should be an ongoing process.
• The Government should consider how key systems such as the role of First Responder could be adapted to help further develop expertise (eg, the creation of SPoC or professional lead roles and nominated First Responders officers) and whether there is sufficient clarity about expectations of local multi-agency partnership working to tackle modern slavery.
• Domestic legislation, rather than international conventions, should clarify the support available to victims of modern slavery, particularly where there is a specific entitlement to access a service because an individual is a victim of modern slavery. This may require updating modern slavery legislation and guidance as well as related legislation and guidance such as the Care Act. The relative responsibilities between local services and the victim care contract, and the handovers and join up between local and national services and different agencies should be clear.

Secondly, and very simply, this work must be fully funded; firstly in terms of services overall, so that key officers have the time and capacity to engage with training, learning and effective implementation of measures to disrupt traffickers and support victims of modern slavery; but also in terms of there being the financial resources required to fund the support victims are entitled to receive.  

To date, councils have not received any new burdens funding to upskill their officers and undertake work on modern slavery nor to provide support to victims, despite the increasing number of both adults and children’s victims. As the age and nationality profile of victims has changed in recent years, there has been increasing demand for support for victims at the local level rather than through the victim care contract, which had previously been the expected form of support for adult victims. While there are good reasons to seek to access local services in this way, and often entitlement to do so, it belies the fact that the services where there are the greatest expectations of councils are those where councils are already under the most acute service demand pressures.

With growing numbers of victims being identified and the victim care contract and local services already under significant pressure, there is a need for sufficient resources to provide the tailored, person centred care that the Government aspires to through its NRM reform programme and commitment to victim support; particularly as more training and better awareness leads to an increasing number of victims being identified. However, there are also some choices about how and by whom support could be provided. 

In the following sections of this paper, we therefore set out some of the specific issues we believe need to be addressed in the new strategy in relation to disrupting slavery and supporting adult and child victims of modern slavery.

We are pleased that the Government is updating its modern slavery strategy and consulting with key partners in doing so. It is seven years since the previous strategy was produced, and six years since the Modern Slavery Act was passed; these were followed in 2020 by the publication of statutory guidance covering the identification of and support for victims.

We are aware of concerns that since 2014, local multi-agency responses to modern slavery have grown organically and differently, with variances in activity, progress and partnership working from place to place. There is a contrast between the more directive approach taken on issues such as counter extremism and terrorism - where expectations of partners are set out very clearly, and clear national standards are in place on issues such as training – and the approach taken on modern slavery, where there has been virtually no guidance or direction on the issue of multi-agency working.

The LGA will always support an approach that allows local flexibility, with partners able to draw on local data and trends to respond to local needs in a way that works for their areas: what is necessary and works in a major city may not suit what’s needed in a rural county. However, this can be balanced with a supportive set of national principles and guidance on the framework within which local areas operate, and we recognise that many local areas would welcome further clarity on the Government’s expectations of how local partners - including councils, the police, NHS, victim care contract sub-contractors and wider voluntary and community sector - should be working together on slavery and the standards that must be met. The revised strategy should seek to strike this balance; the LGA and local areas would support further work with the Home Office to develop this.

The strategy should also reflect a holistic, cross government approach. One of the challenges for councils to manage in responding to slavery is the extent to which modern slavery cuts across a wide range of services and staff; similarly for Government, while the Home Office is the lead department, several others have ownership of legislation and policies impacting on victims. There is a need for join up across different departments and for the strategy to be aligned with related work such as the victim’s strategy and forthcoming Draft Victim’s Bill.

Under the “Pursue” strand of the 2015 modern slavery strategy, there are a range of organisations identified as key players in prosecuting and disrupting individuals and groups responsible for modern slavery. The strategy highlights that Regional Organised Crime Units (ROCUs) are responsible for coordinating and supporting the regional response to serious and organised crime, and local police forces also have a key role in identifying and prosecuting modern slavery.

Since the 2015 strategy was published, the Government has introduced and invested in 18 Violence Reduction Units (VRUs), which bring together police, local government, health and education professionals, community leaders and other key partners to ensure a multi-agency response to the identification of local drivers of serious violence and agreement to take necessary action to tackle these.

The Home Office’s 2020 evaluation of Violence Reduction Units found that just under half of the VRUs also intended to evolve their focus beyond serious violence. This included expansion to target activity beyond the under-25 age cohort to form a more holistic approach for the whole population, and/or to expand their scope beyond knife crime and gun crime to other key themes such as child sexual exploitation, domestic violence and modern slavery.

In the Government’s updated strategy, it would be helpful to reflect on the current community safety landscape and how Violence Reduction Units are currently involved in disrupting modern slavery activity. It is the LGA’s view that VRUs should be extended to all police forces areas, and they should receive sustainable Government funding for a minimum five-year term to support the development of long-term programmes with lasting impact.

It is also important to highlight that alongside the establishment of VRUs there have been and continue to be a number of other changes to the community safety landscape which will affect local responses to community safety issues. The Domestic Abuse Act and the current Police, Crime, Sentencing and Courts Bill are examples of statutory duties placed on local authorities, and wider partners, to prioritise and respond to single-crime types, for example, the proposed duty to prioritise tackling serious violence locally.  It is helpful that the Government’s draft statutory guidance for the proposed serious violence duty proposes that there is flexibility for specified authorities in local areas to include in their strategy

actions which focus on other related types of serious violence (for example domestic violence, alcohol related violence, sexual abuse, modern slavery or gender-based violence) if their strategic needs assessment indicates a need to do so.  

In our view, consideration needs to be given to the full range of community safety issues which the local authority, the police, the Police and Crime Commissioner and the community safety partnership and/or VRU might be expected to assess and direct resources towards.

The updated Government modern slavery strategy should reflect on the current changes to the community safety landscape, including the serious violence duty, and take into account the context in which local authorities and partners will be directing resources to the range of community safety issues locally. 

We would also like to see a clear and equal focus within the strategy on preventing modern slavery as much as disrupting and prosecuting it. One strand of this will be ongoing work to help eliminate modern slavery from supply chains through the actions of businesses and, in future, public organisations (see below). However in particular, we would welcome a focus on steps that can be taken to develop understanding of how the public can be engaged in preventative actions through their consumer choices.

The Modern Slavery Act 2015 (the Act) made the UK the first country to require large businesses to report transparently on the steps they have taken to tackle modern slavery in their operations and global supply chain. The LGA is one of a broad coalition of organisations who have supported the UK Government’s commitment to taking forward an ambitious package of changes to strengthen and futureproof the Modern Slavery Act’s transparency legislation, including extending the reporting requirement to public bodies with a budget of £36 million or more.

Councils spend some £60bn annually on externally procured goods, works and services so are well placed to use this extensive buying power to help mitigate the risks of modern slavery occurring within their supply chains, both domestically and to a lesser degree, globally.

Although councils are still not subject to the supply chain stipulation of the Act (S.54) over half (165 councils) have some form of supply chain provisions in place to mitigate the risk of modern slavery occurring, and crucially have submitted a Modern Slavery transparency statement outlining the due diligence and training they have undertaken in the previous year and what targets they have set themselves on this agenda going forward.

Updating the modern slavery strategy and pressing ahead with legislative change that extends to councils with budgets over £36m the reporting requirements to undertake and submit an annual report on the Government’s new Modern Slavery statement registry is welcomed and will provide long overdue clarity on what councils need to be doing to combat the risk of modern slavery in our supply chains. In line with the principles of sector led support outlined above, this should be supported by the provision of training, guidance and other support - particularly around how to develop a monitoring and reporting framework - to ensure progress is made year on year.

The rapidly increasing numbers of child victim of slavery referred into the NRM in recent years is a tragic indictment of the ruthlessness of criminals willing to exploit some of the youngest people in our society for their own ends. Child victims come from a large number of different countries and backgrounds and include those trafficked into the UK to be exploited through domestic servitude or criminal exploitation, as well as UK children groomed and exploited through county lines and other forms of criminal exploitation. Although there are clearly substantial differences between the different circumstances, all of these instances constitute child safeguarding issues and the responsibility of local authorities to provide appropriate support to those harmed by or at risk from them is clear.

Particularly in the case of victims of county lines criminal exploitation, child slavery cases will often constitute a very different pattern of risk and impact to traditional child safeguarding which focuses on preventing children from being harmed within the home. There is already significant work underway to develop child safeguarding practice and social care support to reflect these more recent patterns of exploitation. A third of councils are signed up to implementing the contextual safeguarding framework developed by the University of Bedfordshire, with other councils also working with partners on approaches to extra-familial harm. These approaches recognise the extra-familial risks children may be exposed to through the places they visit and the people they associate with and seek to target these risks through the lens of child protection.

There is differential progress on this issue and clearly there is more to do to expand and embed this approach so that the learning from early adopter areas is further developed and shared across all councils. The Independent Review of Children’s Social Care, which is due to report in Spring 2022, is looking closely at the support provided to children facing these kinds of risks to identify how practice can be improved further. This includes considering how all statutory safeguarding partners work together, and the role of schools. There is also a focus in the review on the issue of children in care being placed in children’s homes out of their local area due to a lack of sufficiency of placements, which can make them vulnerable to criminal exploitation. The issue of insufficiency is one councils have been raising with the Government for some time, and we hope the review and the associated investigation by the Competition and Markets Authority will help to address this challenge.

There is a continued need to incorporate extra-familial safeguarding risks into early professional training and ongoing professional development across all safeguarding partners, so that people understand current child safeguarding risks from the outset of and throughout their careers; know how to engage appropriately with children who are victims, and can make informed and child centred judgements about the context in which children are making decisions; and are aware of the most effective ways to support children who have become victims of modern slavery and prevent it from reoccurring. Equally, training and practise should emphasise the importance and legality of sharing data about children who are at risk; this challenge is consistently highlighted in serious case reviews and improved understanding and confidence must be embedded across all agencies.

Exclusion from school is a significant indicator of vulnerability amongst young people, with excluded children at higher risk of being a victim or perpetrator of crime. We believe more could be done to prevent exclusions and support children who are excluded or in alternative provision. This includes making schools responsible for children they exclude, as recommended by the Timpson Review of School Exclusion. A more inclusive education and schools system would also provide more support to children at risk.  Both fixed term and permanent exclusions are rising, as is the prevalence of ‘off-rolling’ and elective home education, meaning children are out of sight, which can increase risks.

The issue of criminals grooming children online became more apparent through the Covid-19 pandemic. We are calling for the Government to ensure that the Online Safety Bill ensures protection for children online, including consideration of the cross-platform nature of child abuse risks and the need for platforms to work together to address risk.

Critically, there is also a need to ensure that the system has the resources required to support the increased number of cases children’s services are dealing with. Figures indicate that even prior to the pandemic, the number and proportion of looked after children had increased from 64,470 or 57 in every 100,000 in 2009/10, to 80,080 or 67 in every 100,000 by 2019/20. Alongside this, councils also report that the children requiring support from children’s social care have more complex needs than they did a decade ago.  Rising demand for services means that despite budgets for children’s social care rising by more than half a billion pounds in 2019/20 from the previous year, and more than £1.1 billion between 2017/18 and 2019/20, more than eight in 10 councils were still forced to overspend to ensure children were protected. 

Rising caseloads and increasingly complex needs overall increase the challenges for professionals grappling with the complexity of child criminal exploitation and slavery cases, putting pressure on both casework time and capacity to support training and professional development. Additionally, the trends of increasing demand for child protection services, alongside significant overall cuts to council budgets, has led to a reduction in spending on preventative children’s services: the NAO found that spending in this area had fallen from 41% of children’s services budgets to just 25% in 2017/18.  A reduction in youth services funding from £1.4bn in 2010/11 to £429m in 2019/20, leading to the loss of 4,500 youth work jobs and the closure of 750 youth centres is also a critical factor in relation to county lines exploitation in particular, given the crucial role in providing diversionary activities and youth support work these services can play.

In summary, this adds up to an extremely challenging picture for professionals working in children’s services. The spending review provided an additional £1.6bn per annum for councils over the next three years. This will help councils to meet some, but not all of the extra costs and demand pressures they will face just to maintain current service levels. In children’s services, additional funding for early help for some families and an extension of the Supporting Families programme will provide some extra support, however the funding landscape remains exceptionally challenging. The Independent Review of Children’s Social Care has indicated that its evidence shows additional funding will be required to ensure all children receive the support they need, and the LGA will be supporting the review to make this case to the Government.

Councils, along with their partners in the NHS, police and the voluntary and community sector have a role in providing or signposting to appropriate support for victims and survivors of modern slavery and human trafficking (MSHT). Survivors and victims of these crimes need a range of support which is highly personalised and may need to call on a range of local services which may not always have the resources and capacity to respond appropriately. 

While there are similar capacity and resource pressures linked to supporting adult victims of MSHT as there are for children, the legal framework for entitlement to support for victims is more complex than the child protection framework. Whereas under the Children’s Act there is a clear legal duty for local authorities to support children at risk of harm, which would clearly include victims of MSHT, there is no equivalent legislative provision relating to adult victims, meaning that – in relation to council support at least – victims are considered under a number of different pieces of legislation which councils are bound by.

At the national level, the Home Office’s Victim Care Contract (VCC) (delivered by The Salvation Army and its network of sub-contractors) provides support for people who have been referred and accepted into the National Referral Mechanism. The contract provides for a minimum of 45 days of support while an individual’s case is being assessed for a conclusive grounds decision, and a tailored rest and recovery period based on a recovery needs assessment at the point at which a conclusive grounds decision has been reached.

As noted above, there are increasing expectations that, where they may have entitlement to support – particularly housing - independently of the VCC, adult victims should receive support through outreach services rather than in safe house accommodation. This has led to disagreements between councils and VCC sub-contractors over responsibility for housing victims, with a particular pinch point when victims have initially been identified. At the other end of the NRM process, there are reports of challenges for victims coming out of VCC services and into local services as they move through the process of recovery. A further area where there are often criticisms of councils is in relation to support provided through adult safeguarding and social care.

One of the particular challenges in relation to adult victims is that it appears that some of the commitments the UK has signed up to through international laws and directives[1], as they apply to local authorities, may go beyond what is set out in the domestic legislation that councils apply in relation to adult victims. As set out above, there is a pressing need to ensure that the international duties the UK is bound by, and the increasing case law relating to it, are reflected in UK law, whether the law is covering homelessness, safeguarding and social care, or any other type of support that might be sought for victims. This will help to ensure that there is clarity and understanding about the support that should be provided and by whom; frontline officers with heavy caseloads will not realistically be familiar with or aware of how to apply international conventions they have little exposure to.  Alongside that clarity, should also come the funding to support it.

There is a differential approach within different legal frameworks as to whether individuals receive priority treatment/access to services due to being victims of modern slavery. The homelessness code of guidance was recently updated to more clearly reflect that victims of modern slavery should be assessed as having priority need and therefore eligible for local authority support to relieve homelessness.

We recognise that there is considerable work to be done to promote awareness of the guidance as it relates to victims of modern slavery and to provide training to assist housing officers to understand the indicators of modern slavery, the specific housing needs of modern slavery victims suffering from trauma and how to respond accordingly. In early 2022, the LGA will be publishing guidance and case studies on these issues. We are also working with The Salvation Army and other partners to improve partnership working between councils and VCC subcontractors.

However, the pressures on the availability of suitable housing must also be recognised. Waiting lists for council housing are long, there are currently more than 95,000 households in temporary accommodation (and more than 1.1 million households on housing waiting lists) and Local Housing Allowance (LHA) thresholds, particularly in more expensive parts of the country, will not support individual private rentals. This means that many councils cannot easily provide or support either the type of accommodation that would be most suited to newly identified or recovering victims of modern slavery. In some places, Police and Crime Commissioner funding has helped secure the provision of a small number of emergency beds which can be made available at the point of victim identification, but there is a mixed picture. The LGA’s guidance will include examples of some of the steps councils have taken to try and mitigate the challenges where the only accommodation options available for victims are emergency hostels or bed and breakfast.

While councils will do their best, even priority cases such as victims of domestic abuse or modern slavery will continue to experience the impact of long term, structural issues with the availability of local and national housing stock. The LGA has set out our view of how some of these issues could begin to be addressed. Although it is not for the modern slavery strategy to address these issues, it does need to recognise them and the challenges they create, for example by considering the extent to which dedicated funding for accommodation, and emergency accommodation in particular, could be made more widely available through councils, PCCs or a wider roll out of the places of safety model. This would assist in ensuring that victims are able to access accommodation, particularly at the point they are identified but before they enter the NRM: a period which can be especially challenging.

The LGA will continue to work with councils, the third sector and Government to promote understanding of the housing needs of adult victims of modern slavery.

There has been much focus on whether adult safeguarding can provide a route to support for adult victims given the lack of existing guidance and funding on support for adult victims as flagged above. Adult social care services can be a route of possible support for victims of MSHT, not least because some groups falling within the remit of the services – for example, individuals with learning difficulties or experiencing mental health issues – can be more vulnerable to becoming a victim of slavery in the first place.

The legal framework, approach to and process for adult safeguarding is set out in the Care Act 2014, which recognises modern slavery as a category of abuse.  The Act outlines how councils and key local partners should work with adults at risk of abuse or neglect at both an individual and a strategic level; all of which may frame councils and their local partners response to modern slavery, including:

At the strategic level -

• Working with partners to prevent and stop abuse and neglect, including coordinating Safeguarding Adults Board to implement a joint safeguarding strategy.
• Carrying out Safeguarding Adults Reviews when someone with care and support needs dies as a result of neglect or abuse and there is a concern that the local authority or its partners could have done more to protect them.

Supporting individuals

• Making enquiries, or requesting others to make them, when they think an adult with care and support needs may be at risk of abuse or neglect and they need to find out what action may be needed.
• Making sure that the wishes and preferences of the person concerned remain at the centre, in line with Making Safeguarding Personal

Councils are responsible for looking at any safeguarding concerns for adults who have care and support needs who are unable to protect themselves, and then deciding whether it is necessary for them or a local partner to carry out an enquiry.  A ‘Section 42’ enquiry, which relates to adults who have care and support needs and are unable to protect themselves, will be carried out if abuse or neglect is or is at risk of taking place, and to help decide what should happen to help and support the individual. The circumstances of each case will determine the scope of each enquiry, as well as who leads it and the form it takes.

The fact of being a victim of modern slavery does not in itself provide automatic entitlement to care and support under the Care Act, given the high threshold for care and support needs as defined under the Act.  Victims also will have other needs, such as access to housing, trauma support and access to benefits or employment etc, that will be in addition to meeting care and support needs under the Care Act.  Councils may decide for the response to be led by community safety routes or other bespoke arrangements such as multi agency responses, or will have to resource a decision to go beyond what it is in the current legislative framework for safeguarding in terms of providing wraparound support to victims.

However, in many areas, resource constraints linked to funding pressures have prevented councils from doing so, and, ultimately, from achieving the ambitions (if not the requirements) of the Care Act in relation to support for adults with care and support needs. The system of social care is under huge pressure, impacting the services available to individuals and the time taken to access them.  LGA analysis shows that adult social care costs rose by £8.5bn over the last decade, with councils required to address a £6.1bn funding gap through making £4.1bn savings to social care and diverting funds from other council services. Even before the pandemic struck, adult social care was under significant pressure following years of inadequate funding and piecemeal, sticking plaster solutions, but the pandemic has exacerbated the situation. The LGA has previously estimated that £6 billion would be required to address unmet need across both older and working age adult social care cohorts.  

The Government has recently announced proposals to reform social care. However, the LGA has raised concerns that the money allocated to social care from the Health and Care Levy will not be enough to fund the reform and that it is likely that councils will continue to struggle to meet their statutory duties under the Care Act. The additional funding for local government announced in the spending review is helpful but will not be enough to offset these challenges over the three years of the settlement period.

As with housing, the long-term challenges of the social care system are not an issue for the Government’s modern slavery strategy, but they are relevant to it as an over-stretched, under-resourced system will inevitably face more challenges in supporting victims of modern slavery. The strategy should set out its expectations of the social care framework in relation to victims of modern slavery, and whether these are reflected in the current Care Act; or if not, whether further clarity is required.

In mental health, an area which can be critical for victims trying to recover from the trauma of their experience, councils often commission general mental health and wellbeing support services in the community, while the NHS leads on specialist, medicalised mental health support. NHS mental health services have seen continued investment from government while local government has experienced significant funding reductions. Councils’ adults’ mental health services need parity of funding with NHS mental health services: any improvements to service provision will only be possible if the whole system is fully funded.  

Feedback from our membership has been clear that too often, the specialist mental health support services needed by victims and survivors of experiences such as child sexual abuse or MSHT are either inadequate, inappropriate for those recovering from trauma or facing long waiting lists. We consistently hear from our members about the variability in strength of local partnerships with the NHS and the challenges of supporting the NHS to implement mental health reforms in the face of workforce challenges, rising demand and financial constraints. 

Even in a fully resourced system, it would also be important to reflect on the types of support that victims need and whether there is a natural fit with the services provided through social care.

Domestic abuse support services provided an interesting parallel with support for victims of modern slavery. Like modern slavery, victims of domestic abuse have priority status under the homelessness code of guidance, and domestic abuse is recognised under the Care Act as a form of abuse and safeguarding risk. However, the Government has recognised that these frameworks cannot necessarily provide the types and level of support that victims of domestic abuse need, and the new Domestic Abuse Act introduced a new duty on councils to provide accommodation-based support for victims of domestic abuse. The duty, which came into effect on 1 October 2021 requires that councils provide support in safe accommodation for domestic abuse, including:

• Providing expert specialist support to domestic abuse victims in safe accommodation that best supports their needs, whether in refuges or other safe housing
• Clarifying in guidance that B&Bs or mixed homeless hostels are not the right place for victims to recover from abuse
• Supporting victims to stay in their own homes, if the perpetrator has left and the home can be made safe

Support for victims can include counselling for adults and children, advocacy with services such as GPs, social workers and welfare benefits, support with rehousing, and advice on staying safe as well as the more specialist support that some victims will need, for example, interpreters, immigration advice, or mental ill health, drug or alcohol support. The Government has accepted that this type of support will need to be funded and has made available £125m for the first year of the duty, with a more permanent financial settlement expected.

There are similarities between these services and the wraparound services provided through the VCC / recovery needs assessment model, and other services such as Hope for Justice’s Independent Modern Slavery Advocate model, which focus on tailored support linked to an individual’s specific needs, whether that is navigating legal, health or other services; accessing bank accounts, welfare support or other basic needs, support with language needs and immigration advice.

These are not services that are typically provided through social care. In creating and funding the new domestic abuse duty, Government has recognised the challenges of victims of domestic abuse accessing through existing legal frameworks and local services the type of personalised support that can best protect them and support their recovery. This suggests that despite the objective of exiting victims of modern slavery from the VCC into local services, the necessary services may not always be available, and similar, dedicated provision may need to be specifically funded and made available to victims of modern slavery as well as victims of domestic abuse.  

The revision of the modern slavery strategy is taking place at the same time as the Ministry of Justice is leading work to develop a Draft Victims Bill intended to enshrine victims’ rights in law.  As noted above, we believe that the outcome of the Home Office’s strategy work should be clarity about what support victims of modern slavery need and can expect; and critically whether support can be accessed because an individual is a victim of modern slavery, or whether it can only be accessed in line with the requirements of other legislation.

In looking at victim entitlement, as well as considering international legislation, it will also be important to align with the Draft Victims Bill, and also the work of Police and Crime Commissioners, who have existing responsibilities in relation to victims and receive funding to support this. The strategy should consider what services PCCs could and should specifically commission for modern slavery victims and in particular whether this would be an appropriate route to help plug some of the existing gaps in victim support rather than seeking to incorporate this within domestic legislation it may not fully align with. This type of dedicated support would reflect the approach taken to victims of domestic abuse.

In conclusion, we are seeking the following in relation to victim support:

• A clear national strategy, underpinned by legislation, outlining what support is needed for survivors and expectations of central government/VCC, councils, and others in relation to meeting that need, and 
• National funding for services to enable the delivery of the strategy, with any new requirements on local authorities or other partners funded appropriately, to avoid further impacting on local services.