As a country with relatively high levels of wealth, and therefore more resources to dedicate to addressing modern slavery, the United Kingdom (UK) has been at the forefront of international efforts to tackle modern slavery and has shown the strongest government response globally. Previously, this reflected strong efforts to coordinate the national response, including by allocating additional funding to anti-slavery efforts domestically and overseas, address underlying risk factors, and strengthen measures to address modern slavery in government and business supply chains. However, in recent years and in particular, post-Brexit, changes to UK immigration policy have threatened to discriminate against and criminalise vulnerable people, increasing the potential for modern slavery. Modern slavery remains prevalent in the UK, while gaps include lack of protections for vulnerable groups such as migrant workers, and the absence of a National Action Plan or strategy.
The 2023 Global Slavery Index estimates that on any given day in 2021, there were 122,000 people living in modern slavery in the UK. This equates to a prevalence of 1.8 people for every thousand people in the country and places the UK among the countries with the lowest prevalence of modern slavery in the region (38 out of 47) and globally (145 out of 160). This estimate does not include figures on organ trafficking, which evidence indicates does occur in the UK.1 In 2022, almost 17,000 potential victims of modern slavery were referred to the UK’s National Referral Mechanism (NRM), representing a 33 per cent increase on the previous year and the highest number of referrals since the NRM began in 2009.2 The UK government links this increase to a rise in the number of detections by regulatory first responders at the British border.3 Despite the rise in referrals, modern slavery likely remains heavily underreported given our prevalence data. Official modern slavery statistics in the UK highlight a gendered aspect, with 78 per cent of all individuals referred to the NRM in 2022 being male. In 2022, for the first time, Albanian nationals overtook UK nationals as the most commonly referred nationality, with Eritrean nationals being third.4
Forced labour exploitation
Potential victims were most commonly referred to the NRM for labour exploitation in 2022, accounting for 30 per cent (2,141) of potential referrals.5 In the same year, more than 7,300 calls for help were received by the UK Modern Slavery helpline, run by Unseen, with an increase of 134% in cases of labour exploitation in comparison to previous years.6 Forced labour is reported in many sectors including farming, hospitality, beauty, construction, manufacturing, car washes, domestic service and other service industries.7 Many of these industries rely heavily on migrant workers.8 Recent evidence shows exploitation of migrant workers within the government’s seasonal worker visa scheme, which has rapidly expanded from 2,500 visas issued in its 2019 pilot, to 47,000 in 2023.9 For example, in 2022, investigations revealed cases involving the exploitation of Nepali10 and Indonesian11 migrant workers, who were made to pay extortionate fees to agents working for UK licenced recruitment companies to secure jobs on fruit farms under the scheme. The Gangmasters and Labour Abuse Authority (GLAA) concluded a subsequent investigation in 2023 resulting in a Nepali agency losing its licence and a Slavery and Trafficking Risk Order handed to the two company directors.12
Domestic workers, who are often migrant workers, are also particularly vulnerable to modern slavery; a recent investigation found that domestic workers – predominantly women from the Philippines and Indonesia – are held in domestic servitude in the households of London-based diplomats.13 According to the investigation, at least 13 migrant domestic workers employed by diplomats were referred through the NRM between 2017 and 2021, after experiencing passport retention, wage withholding, food deprivation, and confinement to the household, among other abuses.14
Forced criminal activity is a prevalent form of forced labour across the UK, including forced begging, forced theft, forced work on cannabis farms, and financial abuse and fraud.15 Children are particularly vulnerable, with the latest government statistics showing that 41 per cent of all NRM referrals were for children, with forced criminality being the most common type of exploitation.16 Since 2020, there has been a sharp increase in the identification of children in “county lines” cases – a term used to describe the recruitment of children by gangs for the purpose of transporting illegal drugs across the country. In 2022, over 2,200 county lines referrals were flagged, accounting for 13 per cent of all referrals received in that year. The majority (75 per cent) of these referrals were for boys.17
Forced commercial sexual exploitation of adults
Fourteen per cent of all referrals made in 2022 were cases of sexual exploitation.18 The NRM experienced a 130 per cent rise in Albanian females being referred to the service, which is largely resulting from reports of sexual exploitation.19
The Salvation Army delivers the UK government’s primary contract to manage support services for survivors of modern slavery in England and Wales. Their latest statistics show that sexual exploitation was the second most common referral, particularly among those of Nigerian, Iranian, and Albanian nationality. 20 While females remain the most impacted (88 per cent of referrals), the number of men identified by the service as having experienced sexual exploitation had nearly tripled compared to the last reporting period.21 UK nationals also experience forced commercial sexual exploitation in the UK.22
Commercial sexual exploitation of children
Commercial sexual exploitation referrals made under the NRM among girls alone rose by 26 per cent in 2022 to 331, and represented the most common form of referral for these individuals.23 Analysis of police-recorded crime data in England and Wales in 2021/22 reveals there were 17,486 crimes logged by police where children had been sexually exploited – an average of 48 offences a day.24 This is an increase of 10 per cent compared to the preceding year, with the majority being female referrals.25 This includes children who were trafficked after being threatened with violence or the promise of a better life. Recent police data analysis also highlights a surge in child abuse image offences, with an increase of almost 66 per cent on figures from five years ago.26 There are reports that organised criminal groups across the UK use social media to produce and share child sexual abuse materials, which may amount to modern slavery.27
Forced marriage remains hidden in the UK and ascertaining the number of victims is a challenge.28 The national Forced Marriage Unit (FMU) reported that it responded to 337 forced marriage referrals in 2021, compared to 759 cases in 2020.29 The significant reduction in referrals was primarily attributed to the impacts of the COVID-19 pandemic, as well as a procedural change that saw more cases (868 total) being categorised as “general enquiries.” For general enquiries the FMU may be required to give general advice, rather than “advice and support” cases, where an individual is deemed at risk of, or affected by, forced marriage.30 Of advice and support cases, the majority of individuals (72 per cent) were in the UK at the time of referral, with 76 per cent being British or dual nationality, compared to 19 per cent who were non-British nationals.31 Of identified cases, 22 per cent were under the age of 15, and 13 per cent were 16-17 years of age.32 In 2018, in the first successful prosecution of its kind, a British woman was found guilty of deceiving her teenage daughter into travelling to Pakistan for a forced marriage.33
While official statistics regarding organ trafficking are unavailable, organ trafficking does occur in the UK. In 2022, Ike Ekweremadi, a Nigerian politician and his wife, were convicted under the Modern Slavery Act for organ trafficking – the first conviction of its kind.34 The couple brought a man from Lagos to the UK to become an organ donor for the couple’s daughter in exchange for GB£7,000 (US$8,700) and the promise of establishing a life in the UK.35
Imported products at risk of modern slavery
The UK is not only affected by modern slavery within its borders: as one of the world’s largest economies, the UK – like other G20 countries – is exposed to the risk of modern slavery through the products it imports. Nearly two-thirds of all forced labour cases are linked to global supply chains, with workers exploited across a wide range of sectors and at every stage of the supply chain. Most forced labour occurs in the lowest tiers of supply chains; that is, in the extraction of raw materials and in production stages.36 Given the G20’s level of influence in the global economy, it is critical to examine their imports at risk of forced labour and efforts to address this risk. The UK imports US$26.1 billion products at-risk of being made using forced labour annually. Table 1 below highlights the top five most valuable products (according to US$ value per annum) imported by the UK that are at risk of being produced under conditions of modern slavery.
Table 1: Imports of products at risk of modern slavery to the United Kingdom
|Product at risk of modern slavery||Import value(in billions of US$)||Source countries|
|Garments||10.1||Argentina, Bangladesh, Brazil, China, India, Malaysia, Viet Nam|
|Fish||0.3||China, Ghana, Indonesia, Thailand, Taiwan|
|Timber||0.5||Russia, Brazil, Peru|
|Survivors identified and supported||Criminal justice mechanisms||National and regional level coordination||Risk factors are addressed||Government and business supply chains||Total|
The UK is among the least vulnerable countries to modern slavery in the Europe and Central Asia region, however several factors drive the risk of modern slavery, including discrimination of migrants and those fleeing conflict and other crises, increasing costs of living, and marginalisation of minority groups.
Discriminatory attitudes towards migrants, asylum seekers and refugees are the strongest drivers of vulnerability, which manifest in a hostile environment for those arriving and living in the UK. The risks facing temporary migrant workers typically result from deception or fees incurred throughout the migration process and limited oversight, monitoring, and enforcement of worker rights and conditions in industries with high numbers of temporary migrant workers. Recruitment and migration fees can leave migrant workers in thousands of pounds worth of debt before entering the UK, which is then exploited by managers and gangmasters.37 While such gangmasters often provide a minimum wage in order to create the appearance of compliance with UK legislation, it is commonplace to deduct pay for the purposes of clothing, accommodation, transportation or training, leaving vulnerable workers in a cycle of debt.38
Refugees and those seeking asylum are also at heightened risk of exploitation in the UK, due to social and cultural isolation, lack of access to basic resources and employment opportunities, often compounded by an insecure immigration status.39 Ukrainian citizens who came to the UK under the government’s flagship Homes for Ukraine scheme are vulnerable to exploitation. An Office for National Statistics survey found that many are struggling to find work, access education, and find rented accommodation. Concerningly, 40 per cent of people surveyed also indicated that they would not know how to report exploitation.40
Growing inequality,41 poverty and lack of access to basic needs drives vulnerability to modern slavery. The cost-of-living crisis in the UK will likely make more people vulnerable to exploitation. In the year 2022, 2.1 million people, or 3 per cent of families, used a food bank.42 Evidence shows that lack of support from authorities on housing, economic situation, mental or education creates a vacuum that can leave children vulnerable to criminal gangs and exploitation in county lines.43 Children who are in care, or who go missing from home or care facilities, are more vulnerable to trafficking and exploitation. ECPAT UK (Every Child Protected Against Trafficking) found that one in three trafficked children in the UK in 2020 went missing from local authority care, which was a rise of 25 per cent since the last statistics in 2018.44 Such children tend to be more susceptible to the attention given by traffickers who groom the children through giving of gifts or attention, and then introduce them to drugs and alcohol before subjecting them to sexual violence or forced criminality.45 Child asylum seekers have also gone missing from hotels, targeted by organised crime groups, and forced to work or sell drugs.46
|Survivors identified and supported||Criminal justice mechanisms||National and regional level coordination||Risk factors are addressed||Government and business supply chains||Total|
Overall, the UK had the strongest government response to modern slavery, both in the region and globally. This reflects some strong efforts to address risk factors, establish criminal justice mechanisms, and tackle forced labour in supply chains. However, significant gaps remain, including the need to strengthen measures to support survivors, while recent and proposed changes to UK immigration policy have increased vulnerability.
The UK had among the strongest criminal justice mechanisms in the region and criminalises most forms of modern slavery in line with international conventions under the 2015 Modern Slavery Act47 and the Anti-social Behaviour, Crime and Policing Act 2014.48 The UK also raised the legal age of marriage to 18, without exception, under the Marriage and Civil Partnership (Minimum Age) Act 2022 in February 2023.49 However, gaps in the criminal justice response remain. The government has not ratified the ILO Domestic Workers Convention, 2011 despite the significant risks that domestic workers face. Additionally, the law does not fully recognise that victims should not be treated as criminals for conduct that occurred while under the control of criminals. Although s45 of the Modern Slavery Act provides some protection from criminalisation, it is narrow in application as it does not apply to all crimes. This is concerning given the number of individuals, including children, who experience forced criminality. The previous UK’s Independent Anti-Slavery Commissioner highlighted that current legal protections were inadequate to protect victims of modern slavery from criminalisation, and that police often did not consider the possibility of forced criminality at the beginning of an investigation.50 Further, the European Court of Human Rights ruled in 2021 that the UK failed to protect two victims of trafficking who had been forced to work on cannabis farms, by arresting and charging them with drugs related offences.51
The UK’s modern slavery strategy was last released in 2014.52 The government committed to review this strategy and publish an updated version in 2022,53 however at the time of writing no new strategy has been published. At the time of writing, there has been no announcement of the new Independent Anti-Slavery Commissioner since Dame Sara Thornton stepped down in April 2022,54 raising concerns that there is no body holding the government accountable for a robust response to modern slavery.55 The Home Office continued funding the Modern Slavery and Organised Immigration Crime Programme with an additional GB£1.4 million (US$1.75 million) to support the police in their response efforts.56 An independent review of the government’s overseas spending on modern slavery programming found the GB£200 million (US$250 million) program had been successful at raising global awareness of modern slavery, that programs were mostly on track to meet their targets, and cross government collaboration had been strong. However, the Independent Commission for Aid Impact review also found there was limited evidence of longer-term impact, survivors were not effectively consulted, and that there was limited overall evidence of effective measures to tackle modern slavery.57 The Department of Justice in Northern Ireland established a Modern Slavery and Human Trafficking Branch in 2021, which was tasked with formulating the government’s strategy to combat modern slavery and human trafficking.58 In January 2022, Scotland released its fourth annual progress report on the Trafficking and Exploitation Strategy, which was developed in consultation with survivors.59
Since 2018, the government has taken steps to tackle forced labour in supply chains, but has fallen short of implementing the full suite of commitments it made in 2020 in response to a consultation on the transparency in supply chains provisions under the Modern Slavery Act. The government had committed to mandate the areas statements produced under Section 54 of the Modern Slavery Act must cover, publish new guidance, oblige companies to submit statements to a centralised registry, establish a single reporting deadline, and extend the Act’s application to public sector bodies.60 The government did publish guidance for tackling modern slavery in government supply chains and released the first government modern slavery statement in 2020.61 In a move to enhance transparency, the government also launched a central registry in 2021 for statements produced under the Act62 and required ministerial departments to annually produce individual modern slavery statements.63 However, the remaining commitments are yet to be implemented, while submitting statements to the registry remains voluntary. Many countries across the European Union have implemented mandatory human rights due diligence legislation (mHRDD), while the EU is considering a Directive on Corporate Sustainability Due Diligence (CSDD), which would surpass any reforms to Section 54 of the Modern Slavery Act.
The government has developed alternative measures to tackle forced labour. In a landmark amendment to the Health and Care Act (art. 81), the government implemented regulations to ban the National Health Service from importing goods or services tainted by modern slavery and set out steps to be taken to assess the level of risk associated with individual suppliers.64 The Procurement Bill has similar regulations.65 The government also established a global human rights sanction regime in 2020, using powers under the Sanctions and Anti-Money Laundering Act 2018.66 These sanctions have also been used against those committing forced labour and forced marriage.67
Despite these positive steps, a number of actions undermine the government’s response to modern slavery. Since Brexit, the government have made or proposed changes to policy that infringe upon or jeopardise human rights. In June 2022, the Bill of Rights Bill68 was introduced to parliament as a replacement for the Human Rights Act, 1998, which incorporates and makes the rights contained in the European Convention on Human Rights (ECHR)69 domestically enforceable. There are numerous concerns over how the Bill of Rights would change or remove existing provisions, including introducing additional barriers to justice for victims of modern slavery via court procedures, and imposing higher thresholds for challenges to deportations,70 and reports have since indicated that the Bill has been halted.71 Similarly, the UK’s shift towards a more hostile and discriminatory environment towards migration has made it increasingly difficult for vulnerable people including modern slavery victims to access essential support and services.72
Most recently, in March 2023, the government proposed the Illegal Immigration Bill,73 which aims to detain and swiftly remove anyone entering the country “illegally” in response to individuals arriving by boat across the English Channel.74 The Bill contravenes multiple human rights conventions that the government has ratified and will prevent modern slavery victims from reaching safety and accessing support. In the absence of alternative avenues to reach the UK and in some cases reunite with family, asylum seekers are risking their lives and traversing the English Channel in often overloaded and unseaworthy boats.75 The increasing curtailment of clear and accessible pathways to safe and legal migration pose a serious threat to the safety of vulnerable people and exposes them to the risk of modern slavery.76
Severe labour shortages after Brexit and COVID-19 have increased reliance on migrant workers,77 but despite this, the UK government have failed to effectively respond to the heightened vulnerability of migrant and seasonal workers, with some policies amplifying their modern slavery risks. The government has committed to establishing a single enforcement body for employment rights to better protect vulnerable workers and ensure a level playing field for the majority of employers complying with the law,78 but the body has yet to be established. As part of a review of visas to tackle labour shortages, the quota for seasonal worker visas for horticulture in the UK has risen to 47,000, an increase of 17,000 compared to 2022 figures, with the potential for a further 10,000 visas should the demand be proven.79 While this would be a positive step if decent working conditions could be guaranteed, the rise coincides with a budget cuts to the national GLAA, with inspections of current labour providers at an all-time low.80 Further, without guaranteed work/ income over the six month period, workers may become unable to repay migration costs and face associated exploitation risks.81 There is urgent need for an increase in regulation and enforcement of the scheme, to avoid further risks of labour exploitation.
In a similar step to plug national labour shortages, the UK and Nepali government announced an agreement in August 2022 to increase the recruitment of Nepalese health workers in the UK.82 Although the Department of Health has hailed the scheme as ethical and regulated, critics have raised concerns about the notorious mistreatment from Nepali recruitment agencies, often unable to be properly regulated by the UK, and the high potential for worker exploitation.83 The UK Overseas Domestic Worker Visa has been criticised for creating exploitation risks.84 This visa allows migrant workers to enter the UK for up to six months to work as domestic workers in private households, but effectively ties them to their employer for their right to remain in the UK.85 The visa remains in force despite evidence of its links to worker exploitation and calls for reform from civil society and survivor groups.86
Survivors identified and supported
Strengthen the National Referral Mechanism (NRM), including by ensuring timely determination of positive status to ensure individuals can access support services and to encourage more to come forward.
Ensure that all of the rights for identified victims under the NRM work in practice.
Expand and improve long-term support and reintegration for survivors of modern slavery, including allowing individuals accessing the NRM the right to work. This should include grants of leave to support recovery and avoid re-trafficking.
Criminal justice mechanisms
Ratify the ILO Domestic Workers Convention, 2011.
Enact legislative provisions that uphold the non-punishment principle, ensuring victims of modern slavery are not punished for conduct that occurred while under the control of criminals.
National and regional level coordination
Release the updated national strategy on modern slavery, with clear indicators and allocation of responsibilities.
Appoint a new Independent Anti-Slavery Commissioner.
Risk factors are addressed
Review all new proposed immigration and human rights legislation and policy to understand the impact on modern slavery potential victims and those vulnerable to exploitation. Seek consultation with experts of modern slavery in legislative review processes, and act upon advice given. Provide longer lead times to conduct effective review processes so the implications can be fully understood and acted upon.
Re-instate the pre-2012 Overseas Domestic Workers Visa to remove restrictions that effectively tie domestic workers to their employers and ensure that all workers on restrictive visas are able to access rights in practice.
Ensure that the Labour Market Enforcement body is fully resourced, to improve proactive approaches to enforcement. Further, implement a separation of powers between Labour Market Enforcement and immigration enforcement to address barriers preventing those with an insecure immigration status coming forward.
Increase monitoring of labour conditions and funding/resources for monitoring bodies, including the GLAA.
Provide safe and legal routes for asylum seekers to seek asylum in the UK.
Government and business supply chains
Enact reforms to strengthen the Modern Slavery Act, including all those announced in prior reviews including:
Establish mandatory reporting criteria and a single reporting deadline and making submission to the UK government registry compulsory.
Implement financial penalties for non-compliance with the MSAs. For example, mirroring forms of mHRDD legislation which establish grounds for penalties up to 2 per cent of a companies worldwide turnover.
Strengthen legislation to go beyond mandatory reporting to include mandatory due diligence. This should include fiduciary duties on directors around reporting.
Provide avenues for redress for exploited workers, including civil, administrative or criminal liability.
Publish a list of companies required to report and create or nominate a body to monitor compliance.
Implement a Tariff Act so that goods tainted by forced labour cannot enter or leave UK markets.