This submission by Anti-Slavery International and FLEX provides information on modern slavery risks arising for migrant workers due to obstacles to safe and accessible regularisation pathways. It reflects on the importance of promoting more numerous and improved regular pathways for migration, including better labour migration schemes, as a longer-term, sustainable solution to irregular migration and modern slavery.

This submission by the Labour Exploitation Advisory Group (LEAG) to the Joint Committee on Human Rights' call for evidence on the human rights of asylum seekers focuses on its recognition that current Government policies regarding people seeking asylum are actively driving individuals towards, and exacerbating, labour abuse and exploitation and calls on the Government to adopt a preventative and person-centred approach.

As UN experts express alarm at the UK Government’s increasing use of unsubstantiated claims and demonising and inflammatory rhetoric against survivors of trafficking and modern slavery and their legal representatives, twenty one anti-slavery organisations have released a statement calling on the Government to end the dangerous rhetoric that delegitimises survivors and their lawyers, to end the roll back of rights, and to recommit to the fight against trafficking and modern slavery to deliver protection, support, and justice to all survivors and focus on prevention.

In this response to the Public Bill Committee call for evidence on the Retained EU Law (Revocation and Reform) Bill, members of the Labour Exploitation Advisory Group (LEAG), together with the Anti-Trafficking and Labour Exploitation Unit (ATLEU) and Hope for Justice outline their serious concerns about the impact of the Bill on the UK’s efforts to tackle labour exploitation and the welfare of low-paid and precarious workers, in particular through weakening of key EU-derived employment rights, without proper consultation or scrutiny.

LEAG's submission to the Home Affairs Committee Inquiry on Policing Priorities focuses on its concerns around the current prioritisation of immigration enforcement over victims’ wellbeing. It describes how fear of immigration consequences currently acts as a major barrier to reporting and seeking help when migrant workers face labour abuses and exploitation. It also outlines how adopting secure reporting practices can help to protect victims, improve public trust (particularly among women and people from minority communities) and allow police to prioritise action against perpetrators and protection of victims.

Members of the Vulnerability Advisory Group have responded to the Home Office's comments on secure reporting in their response to the UCL/ IASC report on the roundtable on the war in Ukraine and associated risks of human trafficking and exploitation, raising concerns that they display a misunderstanding of the meaning and implications of secure reporting and ignore the considerable evidence previously put to them about the need for secure reporting to safeguard victims of crime by ensuring that their personal data is not shared with immigration enforcement without their consent. Members of the group invite the Home Office to revisit its response and create a forum for dialogue on secure reporting, including as it pertains to the impact of the war in Ukraine.

This report and policy briefing based on research led by Nottingham Rights Lab in partnership with FLEX, the Institute of Public Care at Oxford Brookes University, and the London School of Hygiene and Tropical Medicine identifies the factors that put live-in migrant carers at greater risk of exploitation and modern slavery, setting out what can be done to mitigate these risks and recommendations for policy changes to reduce workers’ vulnerability to labour exploitation, particularly for those with precarious immigration status.

We applaud Sir Mo Farah for his courage in sharing his experience of being a survivor of child trafficking and shining a much-needed light on this vital issue. Tragically this experience highlights the harm caused to tens of thousands of men, women and children in the UK who are exploited and subjected to human trafficking or slavery and the nature of child abuse and these serious crimes. 

This is why we have signed a joint statement with colleagues working to prevent and address trafficking calling on the the government to strengthen our identification and support systems, to make sure that they work for victims in practice. The UK must commit to guaranteed support for survivors making the difficult decision to come forward about their abuse. We must urgently implement secure reporting systems to encourage those still in a trafficking situation to know they can access justice without their data being shared with immigration enforcement; end the substantial delays in decision making that leave victims in limbo, without the right study, work or confidence to rebuild their lives. We must ensure access to key entitlements such as child protection and care, specialist legal advice and medical support as well as support to access education and employment to enable recovery. 

In this joint response to the Legal Aid Means Test Review consultation by Anti-Trafficking and Labour Exploitation Unit (ATLEU), Focus on Labour Exploitation (FLEX), Hope for Justice, Simpson Millar, and Survivor Collective, we call for survivors of trafficking and modern slavery to be entitled to non means tested legal aid. Our response is informed by experience of the challenges faced by survivors of trafficking and modern slavery in accessing legal aid. Without access to legal advice, survivors are left at risk of destitution, homelessness, removal, and vulnerable to further exploitation and re-trafficking.

This joint briefing produced with ATLEU, ECPAT UK, Helen Bamber Foundation, and Hope for Justice outlines our concerns about the new draft Slavery and Human Trafficking (Definition of Victim) Regulations, raising concerns that they could have far-reaching damaging consequences for victims of trafficking and modern slavery because they narrow the definition of a victim of trafficking and modern slavery and therefore reduce the scope that victims will be identified.

In this article in the Journal of Poverty and Social Justice, FLEX's Lucila Granada and Meri Ahlberg highlight the role states have in creating the conditions under which labour exploitation can occur. Specifically, it identifies several immigration policy decisions related to the UK’s exit from the European Union that will likely result in an increase in the number of irregular migrants in the United Kingdom and how this increase, when combined with measures that have progressively restricted the rights and entitlements of various immigration categories, creates an environment conducive to labour exploitation. It presents measures that could help address this problem, including changes to immigration policies and the strengthening of the labour market enforcement system.

This position paper highlights the gap in enforcement of sexual harassment protections in the workplace and the steps that need to be taken to better protect workers, especially those in low-paid and insecure work. It is based on primary research and case studies collected by FLEX in the cleaning, hospitality and app-based delivery sectors, as well as engagement with academics, frontline migrant organisations and trade unions. 

FLEX and other members of the Home Office’s Vulnerability Advisory Group have written to the Home Secretary and Minister for Immigration calling for proactive steps to be taken urgently to mitigate additional risks for Ukrainian nationals on the Seasonal Workers' Visa (SWV) and their families as a result of the conflict in Ukraine. These include creating more options for workers on the SWP including recourse to public funds and the ability to work in different sectors. 

With the recognition that adequate and robust support and protections are a key element to prevention, FLEX’s response to the Victims' Bill consultation primarily looks at the proposals with the aim of reducing risk of labour exploitation. FLEX’s underlying position and recommendation is that all workers, regardless of employment and immigration status, should be able and supported to report abuse and access vital protections. FLEX is concerned that the immigration enforcement-centred approach to human trafficking (in conjunction with broader ‘Hostile Environment’ policies) has created and exacerbated vulnerabilities that impede victims’ ability to access support and exit their exploitation.

As the Nationality and Borders Bill reaches reporting stage in the House of Lords, this joint briefing with other organisations in the anti-trafficking sector raises concerns around clause 39 of the Bill which will criminalise victims of trafficking who arrived in the UK in breach of the immigration rules, preventing them from reporting crime such as domestic abuse or exploitation. It calls on Peers to support an amendment to ensure victims of trafficking and abuse can safely report crime without fear of immigration repercussions through secure reporting.

Data received from a Freedom of Information request made by FLEX on behalf of the Labour Exploitation Advisory Group (LEAG) to the Home Office shows that between 2017 and 2021 victims of modern slavery have been identified at increasing rates from within immigration detention. This briefing summarises the policy and wider context regarding decision-making for victims of modern slavery who have been detained. It finds that the data is clear that government decision makers agree with the vast majority of trafficking referrals from immigration detention. This is in contrast with claims made in the New Plan for Immigration and the framing of the Nationality and Borders Bill of ‘false trafficking claims’ and abuse of the modern slavery system. It suggests instead that focus needs to be on ensuring that victims are not detained but should be supported to early identification and to access entitlements to rebuild their lives. 

FLEX's written evidence to the EFRA Committee inquiry into labour shortages in the food and farming industry highlights the risks of labour exploitation on the Seasonal Workers' Pilot (SWP), drawing on its own research in this area and its response to the recent Government review of the first year of the SWP.  The UK needs to ensure it is not facilitating exploitation by treating workers as commodities who cannot access legal rights or safeguards. It needs to plan for a more sustainable, fairer approach that ensures the protection of workers and industries rather than proceeding with unplanned opening and closing of routes without consultation, or proper monitoring of recruitment and working conditions, learning from existing schemes as to the practicalities and risk areas, or even allowing time for parliamentary scrutiny. 

On Human Rights Day 2021, FLEX signed this open letter coordinated by Kalayaan calling on the UK government to restore basic rights for domestic workers under the UK Overseas Domestic Workers Visa.

This briefing on the experiences and drivers of exploitation for young migrant workers analyses age as a risk factor for labour exploitation, considering how it intersects with other vulnerabilities. It is based on data collected through participatory research with workers in cleaning, hospitality, and app-based deliveries, alongside existing literature, as part of a three-year project aimed at addressing the knowledge gap concerning experiences and drivers of labour abuse and exploitation in these under-researched, low-paid sectors of the economy. The focus of the briefing is on workers aged 16-24, as young people are most likely to be working in sectors with the highest levels of precarious employment, temporary jobs, and casual contracts, yet there is a lack of research and understanding of their experiences of work.

FLEX's written submission in response to the call for evidence on the UK Modern Slavery Strategy Review highlights the need to identify and address the structural factors which create vulnerability to exploitation as the basis of prevention in the context of modern slavery, as well as to take account of the interactions between slavery and other proposed and existing legislation.

This report explores the experiences of migrant workers in low-paid and insecure work during the Covid-19 pandemic, focusing on barriers to accessing employment rights and social protections, and the associated risks of labour abuse and exploitation. The report is the result of a partnership between FLEX, the Independent Workers’ Union of Great Britain (IWGB) and United Voices of the World (UVW). It provides a basis for understanding why a well-functioning social security system is crucial for preventing labour exploitation and outlines key changes needed to ensure the UK’s social safety net does not fail the growing number of people in low-paid and insecure work.

This report is the second of three working papers exploring the experiences and drivers of labour abuse and exploitation in three understudied low-paid sectors of the economy: cleaning, hospitality and the app-based courier sector. It highlights key workplace issues in the hospitality sector, finding it to be a high-risk sector for labour abuse and exploitation, with workers experiencing frequent issues with pay, inability to take time off sick, dangerous working conditions and work-related violence. Like the cleaning working paper, it uses a feminist participatory action research (FPAR) approach where workers from the sector are involved at every stage of the research process, from design to data collection and analysis.

FLEX has joined Corporate Justice Coalition and other civil society organisations in responding to the Business, Energy and Industrial Strategy Committee report: ‘Uyghur forced labour in Xinjiang and UK value chains’, supporting its conclusion that the Modern Slavery Act is not fit for purpose to ensure that companies are taking steps to address modern slavery risks in their supply chains and calling for new legislation to hold companies accountable for human rights abuses.

This report, based on research carried out over the past year by FLEX with consultant Caroline Robinson and Fife Migrants Forum, provides unique independent evidence of worker experiences on the Seasonal Workers Pilot (SWP), a temporary labour migration programme that seeks to respond to concerns about labour shortages in agriculture, particularly following the end of free movement. Drawing on primary data collected with workers in Scottish farms, the report highlights the risk of human trafficking for forced labour for workers coming to work on the Seasonal Worker Visa and provides details of these risks in line with a range of ILO forced labour indicators, including deception about the nature of the work, degrading living conditions, excessive dependency on employers and lack of freedom to change employer. It proposes strategies to the UK and Scottish governments to tackle these risks and to protect current and future workers, particularly in light of the recent expansion of the scheme.

This joint parliamentary briefing, compiled by FLEX and seven other organisations with expertise on immigration detention and/or human trafficking, outlines the new regulations the government has introduced that downgrade protections afforded to potential victims of trafficking held in immigration detention, expressing concerns about the changes  and calling on MPs to show their opposition and sign Early Day Motion 1696, tabled by Sir Keir Starmer MP and others, which seeks to annul the regulations. 

Together with Anti-Slavery International (ASI), Doughty Street Chambers and Hope for Justice, FLEX and The Anti-Trafficking Monitoring Group compiled a letter to ministers urging them to revoke a new policy that will make rough sleeping grounds for removal from the UK. We brought together a coalition of 150 charities, trade unions, lawyers and local authorities, to warn that these new rules will have severe consequences for victims of modern slavery – and will put the wider homeless population at significant risk of exploitation.

Our submission to this call for evidence draws attention to how the activities of Immigration Enforcement undermine (i) their own stated operational priority to tackle modern slavery crimes and (ii) the national Modern Slavery Strategy's four pillars of pursue, prevent, protect and prepare. 

Following a court order in which the Home Office agreed to review its policy on the immigration detention of human trafficking victims, FLEX and the Taskforce on Victims of Trafficking in Immigration Detention have submitted this letter to the Secretary of State for the Home Department highlighting the main gaps in the current policies and providing recommendations for their improvement.

Our briefing on the forthcoming second reading of the 2020 Immigration Bill explains key issues with its content and important gaps, and provides clear recommendations for parliamentarians to ensure the provisions do not exacerbate modern slavery offences.

This executive summary compiles the main findings from the report "Opportunity Knocks: improving responses to labour exploitation with secure reporting". It explores the barriers documented and undocumented migrants face reporting workplace abuse and exploitation to the police and labour inspectors in the UK. It analyses how information about peoples’ immigration status becomes available to the Home Office following workers’ interaction with police and labour market enforcement agencies, providing practical recommendations for the introduction and strengthening of secure reporting systems to identify and prevent labour exploitation.

On 25 March 2020 FLEX and the US-based Worker-Driven Social Responsibility Network organised a webinar to explore Worker-Driven Social Responsibility, or 'WSR', as a tool for tackling labour abuse in supply chains. This is a recording of that webinar.

WSR is an exciting new model for tackling labour abuse in supply chains that has demonstrably improved working conditions in a range of contexts. It is similar to collective bargaining in that it involves a group of workers jointly negotiating their rights, with the difference that it targets companies at the top of supply chains instead of direct employers.

FLEX has provided this submission to influence the selection of issues against which the UK will be reviewed under the ICCPR, which contains provisions against slavery and related practices.

FLEX is the co-chair of the Modern Slavery Strategy Implementation Group: Task and Finish Sub-Group on Prevention ('MSSIG Prevent'). This is a stakeholder body which advises government on prevention policy and activity. These minutes represent a record of discussions at the MSSIG Prevent's meeting on 27th January 2020 regarding the theme of immigration policy and its intersection with prevention work and aims.

For 2019's General Election, FLEX lays out nine key policies needed to tackle labour exploitation in this handy simple sheet.

This submission focuses on LEAG’s concerns around the new Single Enforcement Body’s proposal to work more closely with other enforcement bodies, more specifically immigration enforcement. It describes how fear of immigration consequences currently acts as a major barrier to reporting and seeking help when migrant workers face labour abuses and exploitation. This collaboration is seen to negatively affect labour inspectorate’s ability to support workers and identify employers in breach of employment law in the UK. It recommends that UK labour enforcement activities abide by article 3(2) of the International Labour Organisation Convention 81 and recommendation by the former Special Rapporteur on the Human Rights of Migrants, and protect the rights and interests of all workers, irrespective of immigration status.

A joint response from Focus on Labour Exploitation and Latin American Women's Rights Service to the Government Equalities Office Consultation on Sexual Harassment in the Workplace. The response highlights the importance of taking into account outsourced, agency and self-employed workers when introducing a preventative duty for employers on sexual harassment. It also emphasises the need for sexual harassment in the workplace to be addressed not as an isolated issue but in the broader context of labour abuse and exploitation of women at work.

This report draws on the frontline experiences of Labour Exploitation Advisory Group members, including Ashiana Sheffield, Latin American Women's Rights Service and Bail for Immigration Detainees, to explore why and how victims of trafficking are being detained under immigration powers in the UK. It makes strong recommendations to government and calls for an overhaul to the system enabling this to take place.

This briefing presents the findings of a project, led by University of Liverpool in partnership with FLEX and funded by the British Academy with the Department for International Development. The project assessed how transparency in supply chains for chocolate (please see separate cocoa briefing) and clothes can help to protect human rights and the wellbeing of workers in low and middle-income countries. This briefing examines the findings from research into the garment sector in Bangladesh and Myanmar to provide key policy recommendations for businesses and governments on working conditions.

This briefing is complementary to FLEX's report, The Risks of Exploitation in Temporary Migration Programmes: A FLEX response to the 2018 Immigration White Paper, also published in May 2019. It describes the three temporary migration programmes proposed by the Government in itds 2018 Immigration White Paper and the risks these pose of labour abuse and exploitation. It provides key recommendations for Government to ensure such schemes do not create or facilitate human trafficking for labour exploitation.

Corporate human rights reporting is a commonly expected practice and is increasingly becoming a legal requirement for businesses. But is it working? This report, a joint publication from FLEX and the International Corporate Accountability Roundtable, explores this crucial question. Providing an in-depth review of current modern slavery legislation around the world, it highlights commons gaps in existing laws and encourages a more risk and outcomes oriented approach to reporting in future. It concludes with clear recommendations for governments and companies to enhance modern slavery reporting in the future.

The UK Government recently announced a new two-year pilot scheme to bring temporary migrant workers from outside the EU to work in the UK agricultural sector. How the pilot scheme is structured will have significant implications for the level of risk faced by migrant workers, ranging from labour abuses like unpaid overtime to the severe exploitation found in cases of forced labour and human trafficking.

This policy briefing highlights the risks of the Government’s proposed new temporary migration programme for the agricultural and horticultural sectors and future schemes like it, and outlines steps required to prevent labour abuse and exploitation after Brexit. 

The UK Modern Slavery Act 2015 introduced the Transparency in Supply Chains (TISC) provision that requires companies with an annual turnover of £36 million or more to produce an annual Modern Slavery Statement. Based on FLEX's consultation with workers, academics, company representatives and experts in Bangladesh and UK, this briefing outlines the core components of effective transparency in supply chains legislation.

In this submission to the Australian Senate's Legal and Constitutional Affairs Legislation Committee, the Advisory Committee of the Modern Slavery Registry recommends that the Modern Slavery Bill 2018 be strengthened with a public list of reporting entities, procurement incentives, a requirement for companies to describe how they identify risks, and phased-in penalties for non-compliance. FLEX has joined other members of the Advisory Committee (Business & Human Rights Resource Centre, Humanity United, Freedom Fund, Anti-Slavery International, Trades Union Congress, Ethical Trading Initiative, Unicef UK, Freedom United, CORE Coalition and Principles of Responsible Investment (PRI)) in calling for these reforms based on our learning from the UK Modern Slavery Act 2015 and its implementation.

This action plan sets out steps for governments to ensure that the interests of workers are central to efforts to tackle human trafficking and forced labour in global supply chains. The blueprint is the result of in-depth engagement with trade unions, businesses, academics and civil society. 

In this submission FLEX draws upon its research and expertise on labour abuse and exploitation of agency workers. FLEX has conducted research on labour exploitation in high-risk sectors of the UK labour market including construction, bakeries and fisheries and has produced a guide to tackling exploitation in the UK labour market.

This submission focuses on gendered aspects of labour abuse and exploitation by drawing on discussions and case studies from the Labour Exploitation Advisory Group (LEAG) and the LEAG Working Group on Women Workers on four highly feminised sectors: care, cleaning, hospitality and domestic work.

This submission sets the backdrop to modern slavery in the UK and the official response, it outlines the UK’s international commitments to tackle modern slavery in general and labour exploitation in particular. It examines the threat to the aims of the Modern Slavery Act 2015 and the UK’s commitment to tackle modern slavery posed by deregulation, including: cuts to resources for UK labour inspectorates; curtailment of labour inspectors’ powers to proactively identify cases of labour abuse and exploitation; and reductions to regulations protecting workers from threats to their labour rights such as accident recording and employment tribunals’ wider recommendation making powers.

This briefing outlines the potential detrimental impact of the EU (Withdrawal) Bill 2017-19 on the UK’s efforts to prevent human trafficking and modern slavery, and the changes to the Bill that could prevent this.

A significant proportion of workers’ rights in the UK come from the EU. The Withdrawal Bill leaves these rights vulnerable to being changed or weakened post-Brexit, without proper parliamentary scrutiny. The watering down of employment rights increases workers’ vulnerability to labour exploitation, including forced labour, slavery or servitude. FLEX supports Amendment 21 to the Bill, which would ensure that changes to employment standards that come from the EU can only be made if they do not reduce or weaken these rights and protections.

In this submission, drawing from a 2017 inspection report from the UK Independent Chief Inspector of Borders, FLEX notes the difficulties associated with identifying potential victims of trafficking at border crossings. Recognising these challenges, FLEX emphasises the crucial importance of labour inspections in reducing vulnerability to exploitation and identifying potential victims of trafficking, particularly in sectors where the use of recruitment agencies/labour providers is high. FLEX therefore highlights the Gangmasters and Labour Abuse Authority’s (GLAA’s) licensing and inspection scheme for labour providers as an example of good practice for Member States.

This briefing outlines key drivers of labour exploitation in the construction sector in London and sets out interventions to tackle the problem. 

In this submission, FLEX urges the Australian government to take this opportunity to learn from and build upon the experience of the UK Modern Slavery Act reporting requirements, and to view with clarity the specific role and the limitations of that legislation. 

FLEX Statement to the Fifth Thematic Consultation on the Global Compact for Safe, Orderly and Regular Migration: “Smuggling of migrants, trafficking in persons and contemporary forms of slavery, including appropriate identification, protection and assistance to migrants and trafficking victims”. 

This paper explores the impact of the United Kingdom leaving the European Union (Brexit) on workers’ vulnerability to labour exploitation. Combining desk-based research and interviews with members of the Labour Exploitation Advisory Group (LEAG), this paper sets out how migrant worker vulnerability to exploitation has been affected by the UK referendum vote to leave the European Union. It looks both at the immediate impact of that decision and considers the key risk areas for the future as the UK transitions out of the EU.

Labour abuses over time can take a huge toll and leave workers vulnerable to situations of severe exploitation. This short animation builds awareness of the reasons why people fall into exploitation and shows the solutions FLEX seeks to end exploitation.

FLEX responses to the United National Special Rapporteur on Contemporary Forms of Slavery consultation questionnaire on access to justice and remedy.

This policy paper presents research findings and policy recommendations for EU policy makers on three key issues: the need for sustainable support and access to accommodation for victims of trafficking for labour exploitation; the increasing conflation of labour inspection and immigration control and the need for more proactive and victim-centred identification efforts; and the lack of access to legal remedies for victims of trafficking for labour exploitation. The paper was developed as part of the Pro-active Identification and Support of Victims of Trafficking for Labour Exploitation in the EU (Pro-Act) Project.

FLEX research into identification and support of victims of human trafficking in the UK has revealed the critical need for better information and support for potential victims of trafficking who enter the UK National Referral Mechanism – the UK’s official framework for identifying and supporting victims of trafficking. This short film, Support Without Recovery: the UK anti-trafficking response, gives an insight into the fear and uncertainty faced by those who have to wait for months to be recognized as victims of trafficking, with little or no support to help them move on with their lives

Labour Exploitation Advisory Group (LEAG) Guidance: understanding victim perspectives in identifying and reporting cases of labour exploitation. This guidance provides a summary of some of the key issues statutory agencies and frontline professionals should be aware of when encountering and supporting victims of labour exploitation.

Access to compensation can play an important role in the recovery of survivors of human trafficking. Compensation awards can help victims move on with their lives and reduce their risk of further exploitation. This paper considers the ability of victims of human trafficking and other forms of modern slavery to access compensation, one year on from the enactment of the Modern Slavery Act. The findings of this research indicate that little has changed for victims seeking justice who are still facing significant legal and practical barriers to obtaining compensation for the abuses committed against them.

An illustrated guide to support entitlements in the UK National Referral Mechanism for victims of human trafficking.

Focus on Labour Exploitation (FLEX) has joined leading charities to publish guidance on best practice in addressing modern slavery in corporate activities. The guidance sets out steps companies could take towards eradicating labour exploitation from their supply chains. It has been produced by leading NGOs in this sector including the CORE Coalition, FLEX, CAFOD and Amnesty International.

Since the inclusion of company reporting requirements in the UK Modern Slavery Act last year, this has become a hot topic for businesses and NGOs alike. This guidance provides a roadmap for businesses that truly want to take meaningful action in this area.

This briefing covers three key areas relating to Part One of the Immigration Bill
1.    The Director of Labour Market Enforcement
2.    The Offence of Illegal Working
3.    New Government amendments in response to the Consultation - ‘Tackling Exploitation in the Labour Market’ 

FLEX believes that labour inspection and enforcement is key to preventing modern slavery. Whilst FLEX supports the establishment of a Director of Labour Market Enforcement to coordinate labour inspection efforts, the central role of the UK labour inspectorates in preventing exploitation risks being undermined by a politically motivated Director who lacks a clear mandate. The victims of modern slavery with whom FLEX works express deep fear and distrust of authorities as well as a real concern for immigration repercussions should they come forward. The Clause 8 Offence of Illegal Working will exacerbate such fears and play in to the hands of traffickers who seek to exploit and coerce vulnerable individuals in to exploitation. Finally the Gangmasters’ Licensing Authority is recognised as a best practice model worldwide. The Government is now proposing reducing its licensing role by introducing ‘flexibility’ in licensing despite just 19% of respondents to a recent Government consultation on labour exploitation supporting such moves. Further amendments requiring the GLA to carry out its functions in accordance with the Director’s strategy mean that its role as a Non-Departmental Public Body and the expertise it has developed as an independent authority is severely threatened. 

In this document FLEX responds the the Government's consultation on tackling exploitation in the labour market.  This consultation proposes an expanded role for key UK labour inspection agencies, proposing extra powers of criminal investigation for the Gangmasters Licensing Authority (GLA) and for labour inspection priorities to alter according to an annual strategy proposed by a new Director of Labour Market Enforcement.  The consultation also proposes a shift away from licensing towards voluntary schemes. In this response, FLEX warns that threats to the GLA licensing and license monitoring functions should be resisted and that increasing criminal powers of the GLA could distract from these core licensing and monitoring functions.  FLEX notes that the UK has one of the weakest labour inspectorates in Europe and is proposing weakening it further through by asking it to do more with less resources. 

This latest FLEX Parliamentary Briefing on the Immigration Bill looks at Part One of the Bill and seeks improvements to ensure that the proposed Director of Labour Market Enforcement acts in the interests of those most vulnerable to labour exploitation. Further FLEX advocates the removal of the 'offence of illegal working' from the Immigration Bill on the grounds that it will be used by unscrupulous employers to control vulnerable migrant workers but also that it will prevent the identification of trafficking as victims will be unwilling to come forward for fear of immigration repercussions. This briefing also touches upon the Government's ongoing consultation on 'Labour Market Exploitation: Improving Enforcement' that closes on 7th December 2015. 

This Policy Blueprint sets out a framework for labour inspection to combat trafficking for labour exploitation in the UK. It highlights ways in which labour inspection can succeed in preventing modern slavery from taking place as well as how it can help victims of severe exploitation to exit such situations. It argues that only with victim-centred labour inspection and enforcement will the UK stand a chance of meeting its international commitments to prevent modern slavery.

This submission sets out key legal definitions of relevance in considering the role of the Director of Labour Market Enforcement set out in Part One of the UK Immigration Bill. It also sets out key laws and regulations of relevance to modern slavery indicators to be considered within the remit of the Director. Finally it argues that victims of modern slavery will be made more vulnerable to exploitation by the Immigration Bill proposed Clause 8 ‘offence of illegal working’.

The focus of this article is on advocacy opportunities provided by the anti-trafficking framework in a new political climate. Through the case study of the UK Modern Slavery Act 2015 deliberations the article explores opportunities to use political interest in human trafficking to advocate labour rights and protections for vulnerable workers. The article explores how, largely cynical, political motivations for the debate on ‘modern slavery’ in the UK, provided an opportunity to reframe the anti-trafficking discourse in this context.

This article considers the changes coming into force under the Modern Slavery Act, and discusses the work to be done to ensure that these new measures strengthen the protection of victims’ rights and prevent the exploitation of vulnerable workers.

In March 2015 the Modern Slavery Act 2015 received Royal Assent, but what difference does the law really make for actual and potential victims of severe exploitation? Of course this largely remains to be seen, but there are some areas in which the new law has potential to improve the situation of exploited workers. Whilst the Act shows progress in the UK’s approach to forced labour, slavery and human trafficking, it is far too heavily weighted towards prosecution, rather than prevention and protection, and effective responses have been thwarted by immigration concerns.

Prevention is considered the foundation of any anti-trafficking response yet UK efforts to prevent trafficking to date have been patchy and prevention work has largely been left to the poorly resourced Gangmasters Licensing Authority (GLA). This paper sets out a roadmap for prevention for the UK including four measures that would improve prevention, including improved labour standard monitoring, the enforcement of employment law and ensuring that immigration responses do not contribute to trafficking for labour exploitation.

FLEX Parliamentary Briefing including recommendations for the UK Modern Slavery Bill at Lords Report Stage in the Houses of Parliament. This briefing calls for the Gangmasters’ Licensing Authority (GLA) and Employment Agency Standards Inspectorate to have their resources increased in order that they might conduct pro-active labour inspection to prevent trafficking for labour exploitation. The briefing called for the GLA to have its remit extended to all ‘high-risk’ labour sectors in order to ensure its licensing standards cover all vulnerable workers.

This briefing raises concerns that the Modern Slavery Bill is narrowly focused on criminal justice issues, with minimal provision for prevention and the protection of victims. It highlights how, without prevention and protection, the two core planks of the ‘three Ps’ response, efforts to eradicate modern day slavery will fail. The briefing calls for measures to prevent trafficking and forced labour abuses by providing for a strong labour inspection system as a first line of defence against labour exploitation. It also highlights the need to protect victims by adopting a broader approach to justice that extends beyond prosecutions and prioritises protection for victims.

In August 2013 the UK Home Secretary declared modern slavery a personal priority and a draft Modern Day Slavery bill was hastily published by December, outlining the government's blue-print for the UK's approach to ending human trafficking. FLEX support strong efforts to tackle this crime. However, too often politicians and activists eager to abolish 'modern day slavery' demonstrate a desire to 'unchain' or save victims from their enslavement, that focuses on the end point, rather than the beginning of the trafficking process. A more victim-centred response adopts lower-profile but more effective steps to prevent victims from being enslaved in the first place.

Instead of offering legal clarification, the bill offers confused definitions, a blinkered focus on prosecution and an anti-slavery commissioner whose resources and activities would be controlled by the home secretary. Far from a credible attempt to address a complex problem, the bill in its current form is more concerned with what the UK is seen to be doing than the real impact of our actions.