Open call for evidence

Call for evidence: questionnaire (accessible)

Updated 4 August 2025

Questionnaire

Initial Questions

We would welcome responses to the following questions set out in this Call for Evidence paper. You can respond to these questions via Identification of victims of modern slavery - GOV.UK.

You can also email your response to modernslavery.cfe@homeoffice.gov.uk or write to:

Identification of Victims of Modern Slavery Call for Evidence
Modern Slavery Unit
Home Office
2 Marsham Street
London
SW1P 4DF

Please ensure that call for evidence responses you send by post or email are clearly numbered to correspond with the question numbers as set out in the online Call for Evidence, to enable us to include your perspectives in our analysis.

You can also use the email address or postal address for any queries on the Call for Evidence.

This Call for Evidence can also be accessed on GOV.UK as an Easy Read version, in British Sign Language and in Welsh.

Q1. Mandatory: Please tell us in what capacity you are primarily responding

a) ☐ As a victim, survivor or person with lived experience of modern slavery

b) ☐ As an academic, or on behalf of an academic organisation

c) ☐ As a legal practitioner

d) ☐ As a representative of a UK based NGO or civil society organisation

e) ☐ As a representative of an international organisation

f) ☐ As a representative of a law enforcement organisation

g) ☐ As a representative of a local authority or health and social care trust

h) ☐ As a Parliamentarian or elected representative (such as metro mayor, councillor) or on their behalf

i) ☐ As an individual

j) ☐ Other (please specify)

Q2. IF ticked b-h, or j: What is your organisation?

[Maximum 50 words]

Q3. Before responding to this Call for Evidence, were you aware of the UK’s National Referral Mechanism for victims of modern slavery?

☐ Yes

☐ No

☐ Unsure

☐ Do not want to answer

Q4. What is your geographic location? If you are responding on behalf of an organisation please use the location of its headquarters. Please do not give your address here.

☐ England

☐ Northern Ireland

☐ Scotland

☐ Wales

☐ Overseas, Please state which country

[Maximum 30 words]

Victim Definitions

A clear and well understood definition of a victim of modern slavery is critical to ensuring accurate and timely identification. The Slavery and Human Trafficking (Definition of Victim) Regulations 2022, made under the Nationality and Borders Act 2022, set out the definitions of “victim of slavery” and “victim of human trafficking” for the purposes of accessing protection and support, and apply UK-wide. The Modern Slavery Statutory Guidance provides further detail on definitions to aid both First Responders and decision makers in the Home Office Competent Authorities.

There is no international agreed legal definition of the term ‘modern slavery’. The Slavery and Human Trafficking (Definition of Victim) Regulations 2022 are informed by, and in compliance with, the UK’s international obligations in the UN Protocol to Prevent, Suppress and Punish Trafficking in Persons (Palermo Protocol) and the Council of Europe Convention on Action against Trafficking in Human Beings (‘ECAT’) and definitions of slavery, servitude and forced and compulsory labour used in the European Convention on Human Rights (‘ECHR’).

The definitions of the criminal offences constituting modern slavery are set out in the Modern Slavery Act 2015. The victim identification process is separate from criminal investigation into modern slavery and therefore the criminal offences of modern slavery are not in scope of this Call for Evidence.

Modern Slavery as an umbrella term

‘Modern slavery’ is an umbrella term used by the UK Government to encompass human trafficking, slavery, servitude and forced or compulsory labour.

[ROUTING – If the respondent has ticked Scotland/Northern Ireland to Q4 show]:

While the Slavery and Human Trafficking (Definition of Victim) Regulations 2022 apply across the UK, we recognise that use of the term ‘modern slavery’ differs across all UK nations depending on policy or legislative context. Devolved administrations may frame some issues through the lens of trafficking and exploitation rather than the broader umbrella of ‘modern slavery’. Scotland has separate legislation under the Human Trafficking and Exploitation (Scotland) Act 2015, as does Northern Ireland under the Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015.

For ALL respondents:

Q5a. To what extent do you agree with the following statement?

The term ‘modern slavery’ is helpful for enabling individuals and organisations, such as first responders, police and support providers, to understand who may be a victim.

☐ Strongly Agree

☐ Somewhat Agree

☐ Neither Agree nor Disagree

☐ Somewhat Disagree

☐ Strongly Disagree

☐ Don’t Know

☐ Do not want to answer

Q5b. Why have you chosen this answer?

[Maximum 300 words]

Q5c. Are there other terms that you use to describe modern slavery? What are these and why do you use them?

[Maximum 300 words]

Indicators of Modern Slavery

The Modern Slavery Statutory Guidance includes common indicators that may be present in a situation of modern slavery (further information can be found at paragraph 3.2 and Annex A of the Modern Slavery Statutory Guidance). These are used by First Responders and decision-makers in the Home Office competent authorities to identify whether someone is a victim.

Q6a. To what extent do you agree with the following statement?

The current indicators in the Modern Slavery Statutory Guidance are useful for enabling individuals and organisations, such as First Responders, police and support providers, to identify who may be a victim of modern slavery.

☐ Strongly Agree

☐ Somewhat Agree

☐ Neither Agree nor Disagree

☐ Somewhat Disagree

☐ Strongly Disagree

☐ Don’t Know

☐ Do not want to answer

Q6b. Do you think there are any indicators missing from the Modern Slavery Statutory Guidance that would help individuals or organisations to identify who may be a victim of modern slavery?

☐ Yes

☐ No

☐ Unsure

☐ Do not want to answer

[ROUTING – if ‘yes’ or ‘unsure’ to previous question]

Q6c. Which indicators do you think are missing? We are interested in hearing about indicators relevant to all types of modern slavery and indicators for different groups of victims, such as adults and children.

[Maximum 300 words]

Modern Slavery and Human Trafficking Exploitation Types

Modern slavery takes many different forms, and the NRM involves an individualised case- by-case assessment by trained decision-makers to determine whether individuals meet the definition of modern slavery. We understand that there can be uncertainty and inconsistency in how different forms of exploitation are recognised as a form of modern slavery by frontline practitioners.

We are interested in evidence about what kinds of things may assist frontline practitioners in the UK in understanding when different forms of exploitation are modern slavery, for both adults and children.

Q7a. Please indicate if you want to provide evidence on any of the following types of exploitation (tick as many as apply)

☐ Sexual Exploitation

☐ Criminal Exploitation

☐ Labour Exploitation

☐ Other type(s) of exploitation (such as organ trafficking or domestic servitude)

☐ None

[ROUTING – if ticked ‘Sexual Exploitation’]

Q7b. What would help practitioners understand when sexual exploitation is a form of modern slavery? This may include guidance, training, toolkits. Your answer may reflect on sexual exploitation that affects adults or children, or both.

[Maximum 500 words]

[ROUTING – if ticked ‘Criminal Exploitation’]

Q7c. What would help practitioners understand when criminal exploitation is a form of modern slavery? This may include guidance, training, toolkits. Your answer may reflect on criminal exploitation that affects adults or children, or both.

[Maximum 500 words]

[ROUTING – if ticked ‘Labour Exploitation’]

Q7d. What would help practitioners understand when labour exploitation is a form of modern slavery? This may include guidance, training, toolkits. Your answer may reflect on labour exploitation that affects adults or children, or both.

[Maximum 500 words]

[ROUTING – if ticked ‘Other type(s) of exploitation (such as organ trafficking or domestic servitude)’]

Q7e. What would help practitioners understand when other types of exploitation (such as organ trafficking or domestic servitude) are forms of modern slavery? This may include guidance, training, toolkits. Your answer may reflect on other types of exploitation that affect adults or children, or both.

[Maximum 500 words]

Legal definitions of modern slavery

Please be aware that this section includes technical questions related to the legal definition of victims of modern slavery and therefore requires some familiarity with legal terms and the Slavery and Human Trafficking (Definition of Victim) Regulations 2022 so these questions may not be relevant for all respondents. Please feel free to skip over these questions if you do not feel they apply to you.

The UK’s international obligations include the UN Protocol to Prevent, Suppress and Punish Trafficking in Persons (Palermo Protocol) and the Council of Europe Convention on Action against Trafficking in Human Beings (‘ECAT’) and definitions of slavery, servitude and forced and compulsory labour used in the European Convention on Human Rights (‘ECHR’).

Q8a. Based on the UK’s international obligations, do you think there are any forms of adult exploitation and/or child exploitation which are not captured by the Slavery and Human Trafficking (Definition of Victim) Regulations 2022? This may include current, or new and emerging forms of exploitation

☐ Yes

☐ No

☐ Unsure

☐ Do not want to answer

[ROUTING - IF YES]

Q8b. Please provide examples of this and explain why.

[Maximum 500 words]

Initial Identification

Early identification of victims is a critical first step in the UK’s modern slavery response. At present, a defined list of statutory and non-statutory organisations are designated as First Responder Organisations (FROs) authorised to refer individuals into the National Referral Mechanism (NRM). Individuals who carry out this role within these organisations are known as First Responders (FRs).

While current FROs operate across a broad range of settings, they do not cover all the contexts in which victims may be encountered. Many victims may engage with a broader range of professionals and organisations who are not currently designated as FROs. This includes faith groups, education providers, addiction services, prisons, and healthcare providers, who may be well placed to recognise indicators of exploitation and build trust with people affected by modern slavery.

We are interested in gathering evidence about the effectiveness of current identification practices, including the role of FROs and how FROs work with other organisations who are not designated as first responders, to identify victims of modern slavery.

Q9. Are you a designated First Responder to the National Referral Mechanism (NRM)? We are asking this question as some questions in this section of the Call for Evidence are specifically for First Responders.

☐ Yes

☐ No

☐ Unsure

☐ Do not want to answer

Role of First Responder Organisations and Referral Pathways into the NRM

We are interested in evidence that helps to improve our understanding of what frontline staff in organisations not currently designated as First Responder Organisations do when they encounter a person who they think shows indicators of modern slavery. The Modern Slavery Statutory Guidance includes common indicators that may be present in a situation of modern slavery (further information can be found at Chapter 3 and Annex A).

Q10a. Do you have any evidence of good practice for how organisations that are not designated as First Responder Organisations (FROs) refer individuals showing indicators of modern slavery to designated FROs? This may include, for example, safeguarding protocols, sharing referral protocols, local guidance outlining roles and responsibilities, or other collaborative arrangements.

[Maximum 500 words]

[ROUTING - IF YES to ‘are you a designated First Responder?’]

Q10b. Do you have any evidence or examples of good practice in how your organisation fulfils its responsibilities as a First Responder? We are particularly interested in your internal processes, systems, or approaches that have proven effective in identifying and interacting with potential victims of modern slavery.

[Maximum 500 words]

Awareness and Training

It is important that professionals who may encounter victims of modern slavery have appropriate awareness and training on modern slavery indicators. This enables them to identify victims early and accurately, and crucially to either support adults to make an informed decision about entering the NRM or determine when it is appropriate to complete a Duty to Notify (DtN) in England and Wales. In contrast, children must always be referred into the NRM, regardless of consent. People who may encounter victims work across varied contexts including policing, immigration enforcement, local authorities, NGOs and have different levels of experience with modern slavery.

All First Responder Organisations should ensure they have pathways and protocols in place to support First Responders and ensure that they are trained appropriately. The Home Office has not provided training materials specific to individual First Responder Organisations. However, the Home Office has produced two high level e-learning modules for use by all First Responders.

Q11a. Do you have evidence or examples of training models or materials about how to identify victims of modern slavery that you have found to be effective?

☐ Yes

☐ No

☐ Unsure

☐ Do not want to answer

[ROUTING - IF YES to ‘evidence or examples of training models’]

Q11b. Please describe why you think these training models or materials are effective. We are interested in hearing about things you felt were effective in terms of how the training was delivered (e.g. in-person/online), who delivered it and what topics and themes the training or materials covered.

[Maximum 500 words]

Victim and survivor experience of initial identification

The initial identification of potential victims refers to situations where professionals recognise indicators of modern slavery for the first time. Initial identification is a critical step in the UK’s modern slavery response, often determining whether individuals are referred into the National Referral Mechanism (NRM).

For ALL respondents:

Q12. What do you think can help victims and survivors of modern slavery feel safe and supported during the first interaction with professionals or services who may recognise indicators of exploitation? This may include, for example, the environment this interaction happens in, and the types of training that frontline professionals may need to support safe engagement.

[Maximum 500 words]

Formal Identification

When First Responder Organisations (FROs) have referred individuals to the National Referral Mechanism (NRM), the Competent Authorities begin a decision-making process to determine victim status and formally identify people as victims of modern slavery.

The stage between a positive Reasonable Grounds (RG) decision and a Conclusive Grounds (CG) decision is intended to support recovery and allow for the gathering and assessment of evidence to inform a final decision on victim status. This period- often referred to as the reflection and recovery period – also provides protection from removal from the UK and initiates access to a range of support entitlements, including accommodation, financial assistance, healthcare and legal advice. However, it is important to note that this period of protection and support may not apply in cases where a Public Order or Bad Faith Disqualification is made, as set out under Section 63 of the Nationality and Borders Act 2022. These provisions are intended to exclude individuals who pose a threat to public order or are found to have made improper claims.

Responsibility for formal identification

Currently the NRM decision-making process is undertaken at central and national level by the Home Office Competent Authorities (apart from child devolution pilot sites, where decisions are made by multi-agency structures and then quality assured and communicated to potential victims by the Home Office Competent Authorities).

Historically, responsibility for NRM decision-making was held by the UK Human Trafficking Centre (now part of the National Crime Agency) and UK Border Agency (now UK Visas and Immigration). In 2019, responsibility for all NRM victim status decisions transferred to the Home Office with the creation of the Single Competent Authority (SCA). The Immigration Enforcement Competent Authority (IECA) was introduced in 2021 with responsibility for a specific cohort of adult NRM referrals (as set out in Chapter 4 of the Modern Slavery Statutory Guidance).

There are three broadly recognised models used internationally to structure the formal identification of victims of modern slavery and human trafficking: centralised, devolved (or regional), and multi-agency.

• In a centralised model, a single national authority, such as a government department or designated coordination body, is responsible for making formal decisions on identification.

• A devolved or regional model delegates responsibility for making formal decisions on identification to regional or local authorities.

• A multi-agency model involves a collaborative decision-making process for formal decisions on identification, typically through a panel of statutory agencies, civil society organisations, and where appropriate, survivors.

These models are not mutually exclusive, with some systems adopting hybrid approaches that combine elements of two or more models. For example, a devolved structure may incorporate multi-agency panels to enhance local decision-making with broader expertise and accountability. An example of this in practice is the devolved child decision-making pilot currently in place in 20 local areas, reflecting such a hybrid model, combining local authority-led processes with multi-agency input to support identification decisions for children.

Q13a. What do you see as the benefits and drawbacks of the current centralised model, where modern slavery victim status decisions for both adults and children are made by national Competent Authorities (e.g. SCA/IECA)?

[Maximum 500 words]

Q13b. What do you see as the benefits and drawbacks of devolving modern slavery victim status decision-making for both adults and children to regional or local agencies? We are particularly interested in evidence about the capacity and readiness of local agencies to make these decisions.

[Maximum 500 words]

Q13c. What do you see as the benefits and drawbacks of multi-agency involvement in modern slavery victim status decision-making for both adults and children?

[Maximum 500 words]

Q13d. In a multi-agency decision-making model, which organisations or professionals do you think should be involved in the decision-making process for adult and child cases? [drop down list. Please rank the top five in order of importance (1 = most important)].

Organisation / Professional	Adult Cases (Rank 1–5)	Child Cases (Rank 1–5)
Local Authorities / Health & Social Care Trusts
Police / Law Enforcement
NHS / Healthcare Providers
Mental Health Services
Support Providers
NGOs
Legal Aid Providers / Immigration Solicitors
Home Office Representatives (e.g. SCA / IECA)
Survivor or Lived Experience Representatives
Other (please specify):

Q13e. Do you think certain types of NRM referrals (e.g. for those exploited overseas only, those exploited in the UK only, different exploitation types) are better suited to any of the specific decision-making models? Please explain your reasoning.

[Maximum 500 words]

Providing Information to Support NRM Decisions

Formal identification of victims of modern slavery is inherently complex and often requires detailed and sensitive enquiries. There is a need to ground decisions in robust evidence without delaying decisions, while ensuring that those providing information to inform decision-making have sufficient time to provide this information. These questions seek to explore how the identification process can be trauma-informed, while maintaining the integrity and evidential rigour required for fair and accurate decision-making.

Q14a. What changes could help improve the process of gathering and sharing information with the Competent Authorities to inform victim status decisions after an initial referral has been made (i.e. Reasonable Grounds and Conclusive Grounds decisions, and any reconsiderations of these decisions), while enabling these decisions to be made in a timely and efficient way?

[Maximum 500 words]

Q14b. Have you or your organisation been asked to provide information to the Home Office Competent Authorities after a Reasonable Grounds decision has been made, to support an NRM decision?

☐ Yes

☐ No

☐ Unsure

☐ Do not want to answer

[ROUTING – ask IF YES]:

Q14c. What has worked well?

[Maximum 250 words]

Q14d. What has made things more difficult when providing information to support a decision?

[Maximum 250 words]

Experiences of the Identification Process and Conclusive Grounds Decisions

The current National Referral Mechanism (NRM) Identification process involves two key decision points:

• A Reasonable Grounds (RG) decision, which provides initial access to support and protection while further evidence is gathered.

• A Conclusive Grounds (CG) decision, which formally determines whether an individual is a victim of modern slavery or human trafficking.

The period between these decisions- often referred to as the reflection and recovery period – offers protection from removal from the UK and access to a range of support entitlements. However, this period may not apply in cases where a Public Order or Bad Faith Disqualification is made, as set out under Section 63 of the Nationality and Borders Act 2022.

The Conclusive Grounds (CG) decision marks the formal end of the National Referral Mechanism (NRM) identification process. A positive CG decision may result in the following entitlements, depending on individual circumstances:

• Consideration of a grant of ‘Temporary Permission to Stay for Victims of Human Trafficking or Slavery’. An immigration decision that may grant permission to stay in the UK for a limited period, based on individual needs and circumstances. If granted Temporary Permission to Stay this provides the right to work and recourse to public funds, study is permitted subject to certain conditions.^{[footnote 1]}

• Continued access to support may end unless individuals are eligible for ongoing assistance through statutory child or adult services, depending on individual needs.^{[footnote 2]}(#_bookmark10) Support from government services, including on a needs-basis, healthcare, housing, material or and financial support and support worker.

• Eligibility to apply for the Criminal Injuries Compensation Scheme.[3^] Possible financial compensation for harm caused by a violent crime in the UK.

• Eligibility to apply for the Voluntary Returns Scheme.^{[footnote 4]} Help to return to a home country, including travel and possible financial support, where there is no permission to stay in the UK.

• In addition, those who receive a negative CG decision have a right to request a reconsideration of a negative CG decision within 30 calendar days, under specific grounds.^{[footnote 5]}

For ALL respondent types

Q15. Do you think that having two decisions in the NRM (Reasonable Grounds followed by Conclusive Grounds) supports effective identification of victims of modern slavery?

[Maximum 500 words]

[ROUTING - IF ‘YES’ to answering as ‘victim / survivor/ person with lived experience’ to Q1]

Q16a. THEN: OPTIONAL Have you previously been referred to the National Referral Mechanism and received a positive conclusive grounds decision?

☐ Yes

☐ No

☐ Unsure

☐ Do not want to answer

[ROUTING - If YES to ‘victim / survivor / person with lived experience’ AND YES to ‘Have you previously been referred to the National Referral Mechanism and received a positive conclusive grounds decision?’]

Q16b. Thinking about your own experience, what did receiving a positive Conclusive Grounds (CG) decision mean to you personally? For example, did it change how you felt about your situation?

[Maximum 500 words]

[ROUTING - IF answered YES to ‘As a representative of a UK based NGO or civil society organisation’ in Q1]

Q17a. THEN ‘Do you or your organisation deliver support services directly to people who have been referred into the NRM?’

☐ Yes

☐ No

☐ Unsure

☐ Do not want to answer

[ROUTING - IF YES to ‘’Do you or your organisation deliver support services directly to people who have been referred into the NRM?’ OR YES to ‘Are you a designated First Responder’ in Q1]

Q17b. From your perspective as a support provider or First Responder, what impact does a positive Conclusive Grounds decision have on the individuals you support? For example, have you observed differences in how a positive Conclusive Grounds decision is experienced according to people’s individual situation, for example their age, gender or immigration status?

[Maximum 500 words]

Thank you for participating in this Call for Evidence.

We sincerely appreciate you taking the time to share your views and contribute to this Call for Evidence.

Please note that while all responses will be carefully reviewed and considered, we will not be able to provide individual responses.

We will not be able to process information about individual cases if it is provided through this Call for Evidence.

You can report modern slavery as a member of the public, or report it yourself if you are a potential victim. Call 999 in an emergency. If it is not an emergency you can call the UK Modern Slavery & Exploitation Helpline (run by the charity Unseen) on 0800 0121 700 or report it online.

Thank you once again for your participation.

1. Home Office (2025) Temporary permission to stay: considerations for victims of human trafficking or slavery, published 9 June 2025. Available at: https://www.gov.uk/government/publications/temporary-permission-to-stay-for-victims-of-human-trafficking-and-slavery-caseworker-guidance ↩

2. Home Office (2025) Modern Slavery: statutory guidance for England and Wales (under s49 of the Modern Slavery Act 2015) and non-statutory guidance for Scotland and Northern Ireland, published 2 June 2025. Available at: Modern Slavery: statutory guidance for England and Wales (under s49 of the Modern Slavery Act 2015) and non-statutory guidance for Scotland and Northern Ireland (accessible version) - GOV.UK ↩

3. Get help to return home if you’re a migrant in the UK. GOV.UK. Available at: https://www.gov.uk/return-home-voluntarily ↩

4. Home Office (2025) Modern Slavery: statutory guidance for England and Wales (under s49 of the Modern Slavery Act 2015) and non-statutory guidance for Scotland and Northern Ireland, published 2 June 2025. Available at: Modern Slavery: statutory guidance for England and Wales (under s49 of the Modern Slavery Act 2015) and non-statutory guidance for Scotland and Northern Ireland (accessible version) - GOV.UK ↩