Commissioners respond - HMICFRS report on modern slavery super-complaint 


The Independent Anti-Slavery Commissioner, Dame Sara Thornton, and the Victims’ Commissioner, Dame Vera Baird QC, have responded to a report by Her Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS), the College of Policing and the Independent Office for Police Conduct in response to a super-complaint submitted by Hestia about the police response to victims of modern slavery.

In 2019, Hestia submitted a super-complaint about how police identify, deal with and support victims and how modern slavery crimes are investigated. A super-complaint is a complaint that “a feature, or combination of features, of policing in England and Wales by one or more than one police force is, or appears to be, significantly harming the interests of the public (Section 29A, Police Reform Act 2002). The system is designed to examine problems of local, regional or national significance that may not be addressed by existing complaints systems.

Hestia’s super-complaint raised several concerns about the police response to victims of modern slavery:

  • Non-specialist police officers fail to recognise the signs of exploitation and fail in their duty to report modern slavery to the Home Office;
  • Police officers aren’t taking immediate steps to make a victim feel safe;
  • Victims of modern slavery are treated as immigration offenders;
  • Victims of modern slavery are treated as criminals when they have been forced to commit criminal activities by their exploiters, despite the existence of the section 45 defence in the Modern Slavery Act 2015;
  • Police forces don’t adequately investigate cases that come to their attention; and
  • The adequacy of training provided to frontline officers.

Responding to the super-complaint, HMICFRS carried out a range of activities to investigate whether there is evidence that the concerns set out by Hestia are features of policing. This included fieldwork in six forces, discussions with experts and organisations with extensive knowledge of modern slavery, and a review of information provided by police forces and other public bodies.

This report finds that whilst the police response to modern slavery has broadly improved since a 2017 HMICFRS modern slavery inspection, there is still inconsistency throughout forces, and more needs to be done to recognise and support victims of slavery, and to ensure that these crimes are investigated effectively. The report finds that modern slavery victims do not always receive the response and treatment they deserve, and there is not enough support for victims during modern slavery investigations. These factors contribute to the low numbers of modern slavery prosecutions.

The report sets out a series of recommendations for the Home Office and for police leaders:

  • For the Home Office (in consultation with chief constables, the IASC, Victims Commissioner, Crown Prosecution Service and support providers) to commission research to better understand the victim experience of the police response to modern slavery and the wider response from immigration and other law enforcement agencies;
  • For chief constables to assure themselves that police officers and staff are supported to identify possible victims, understand the referral process and recognise where victims may have been forced to commit an offence by their exploiters;
  • For chief constables to assure themselves that their resources are being deployed to enable effective investigation of modern slavery offences;
  • For chief constables and police and crime commissioners to work together to understand the support needs of victims of modern slavery;
  • For the Home office to assure themselves that the support mechanisms provided by bodies under government funding are consistently making available high-quality provision for victims of modern slavery.  


Read the report: The hidden victims - Report on Hestia’s super complaint on the police response to victims of modern slavery 



The Independent Anti-Slavery Commissioner, Dame Sara Thornton, and the Victim' Commissioner, Dame Vera Baird QC, said:


“Victims of slavery and exploitation require specialist support: from identification through to recovery and reintegration. We must provide victims with robust and professional support that gives them a pathway from being a victim to being a survivor. Providing the right support helps to bring traffickers to justice and ensures that perpetrators cannot continue to exploit and abuse vulnerable people for profit. 

“Hestia’s super-complaint raised concerns that the police response to modern slavery undermines the confidence of victims and hinders successful prosecutions. This response from HMICFRS, the College of Policing and the Independent Office for Police Conduct finds that whilst improvements have been made since the 2017 HMICFRS modern slavery inspection, a lack of specialist knowledge, training and resource for investigations remains a barrier to a consistent response where access to justice for victims and survivors is assured.

“Prosecutions for offences under the Modern Slavery Act remain low. The Independent Anti-Slavery Commissioner’s office has recently undertaken work to explore the barriers to successful prosecution. Lack of effective support for victims as prosecution witnesses was a key concern. We welcome the recommendation made by the report for chief constables and police and crime commissioners to ensure that there are options for support available pre-NRM, post-NRM and for those who do not consent to the NRM process. 

“The Act contains a defence for victims who have offended as a result of their exploitation, and the report finds that this defence is not always considered. A review by the Independent Anti-Slavery Commissioner’s office on the use of the defence published last year identified similar findings: that police are not identifying victims early enough or proactively considering whether this defence may apply. Consequently, the protection for victims is not yet adequate and this needs to change. Unless victims receive the care they require at first point of contact with the criminal justice system, we’ve got no hope of victims supporting a case through court. 

“We are disappointed that the report failed to hear directly from victims about their experiences. The report calls for research to be undertaken to better understand victim experiences, and this is something we would support. But it was a missed opportunity not to engage as part of this super-complaint. We must incorporate the expertise of survivors and ensure that practices and policies reflect the needs and views of those they seek to serve. 

“Overall, more needs to be done. Last year the Independent Anti-Slavery Commissioner formally requested HMICFRS to undertake a new inspection of forces’ response to modern slavery. HMICFRS did not feel able to accommodate this within their inspection plans. This must be reconsidered if we are to ensure this report’s recommendations are being taken forward. Victims and survivors of modern slavery deserve access to justice and we must ensure that the police response continues to improve.”




Notes to editors

  • Part 4 of the Modern Slavery Act 2015 created the role of the Independent Anti-Slavery Commissioner. The Commissioner has a UK-wide remit to encourage good practice in the prevention, detection, investigation and prosecution of slavery and human trafficking offences and the identification of victims.
  • The Commissioner is given an annual budget with which to appoint staff and carry out her duties. She is accountable through her strategic plan and annual reports, which the Secretary of State lays before Parliament, setting out the extent to which objectives and priorities are achieved. 
  • The Commissioner's Strategic Plan 2019 – 2021 was launched in October 2019 and her Annual Report 2019 – 2020 was launched in September 2020.
  • Dame Sara Thornton was appointed as the Independent Anti-Slavery Commissioner by the Secretary of State following consultation with the Scottish Ministers and the Department of Justice in Northern Ireland. She took up post at the beginning of May 2019 and her appointment is for three years.
  • The Victims’ Commissioner for England and Wales is dedicated to promoting the interests of victims and witnesses. The Victims’ Commissioner is appointed by ministers but is independent of government and free to advise, challenge and offer her own views.
  • Dame Vera Baird QC was appointed Victims’ Commissioner in June 2019.