In 2017, ICIBI reported on the identification and treatment of Potential Victims of Modern Slavery (PVoMS) by Border Force, following this up in 2018 with a re-inspection to check on progress made in implementing ICIBI’s recommendations.
Following discussions with the Independent Anti-Slavery Commissioner about where a further inspection might add most value, between October 2019 and April 2020 ICIBI examined the work being done by Border Force, Immigration Enforcement and UK Visas and Immigration to identify, investigate, disrupt and prosecute the perpetrators of modern slavery and human trafficking (MSHT).
The inspection found that while operational activity overall had increased since the Modern Slavery Strategy was launched in 2014, the work of the Home Office’s three Borders, Immigration and Citizenship System (BICS) operational directorates, and that of the wider Home Office, remained siloed and disjointed, with little evidence of a plan to address this.
BICS had had some success in focusing frontline staff on the identification and safeguarding of victims through the National Referral Mechanism (NRM), which was reflected in increased numbers of NRM referrals. It needed to build on this, particularly at the border, where the numbers were still low. But, it was not doing enough to combat the criminals who perpetrate, enable and exploit MSHT, and opportunities to do so were being missed.
The report was sent to the Home Secretary on 16 September 2020 and published on 4 March 2021 (24 weeks). It contained three recommendations, which together looked to reset the BICS response to MSHT. They stressed the importance of creating a clearer, more coherent set of roles, responsibilities and objectives for BICS, and also of ensuring that the Home Office Serious Organised Crime Group (SOCG), which held the departmental lead for MSHT, was more closely engaged with BICS regarding the latter’s efforts to tackle MSHT. Two of the recommendations were accepted and the third “partially accepted”.
In addition, the report repeated a recommendation from ‘An inspection of the Home Office’s response to in-country clandestine arrivals (‘lorry drops’)’ regarding a fundamental review of the criminal investigation and prosecution capabilities and capacity of BICS.
In November 2020, the Home Office “partially accepted” this recommendation, but declined to carry out a fundamental review. Instead, it would take ICIBI’s findings fully into account alongside the findings of the independent review of Serious and Organised Crime (SOC) led by Sir Craig Mackey QPM, which had reported to the Home Secretary in February 2020, and about which it would provide details “in due course”.
The Home Office’s latest response simply quotes its previous statement. It is unclear what progress it has made in the intervening four months. While the necessary improvements in capabilities and capacity will take time to implement, it would have been more encouraging to see reference to some specific actions and deadlines.