Dame Sara comments on ICIBI modern slavery report and Government response
The Independent Anti-Slavery Commissioner, Dame Sara Thornton, has released comments on an Independent Chief Inspector of Borders and Immigration (ICIBI) report on modern slavery and Government response to the report laid in Parliament today (Thursday 4 March 2021).
The ICIBI publication, ‘An inspection of the work of Border Force, Immigration Enforcement, and UK Visas and Immigration to identify, investigate, disrupt and prosecute perpetrators of modern slavery and human trafficking’ reports on an inspection which took place from October 2019 to April 2020.
This latest report follows an ICIBI inspection in 2017 on the identification of potential victims of modern slavery by Border Force and a re-inspection on progress on this issue in 2018. The latest report was informed by discussions with Dame Sara about where further inspection might add most value.
Today’s report found that while operational activity overall has increased since the Modern Slavery Strategy was launched in 2014, the work of the three Borders, Immigration and Citizenship System (BICS) operational directorates, and that of the wider Home Office, remains siloed and disjointed.
The report’s four recommendations are:
- Review the roles and responsibilities of Border Force, Immigration Enforcement and UK Visas and Immigration business areas and functions in relation to each strand (the “4 Ps”) of ‘Modern Slavery Strategy’. The review should be led by the Director General Serious Organised Crime Group (SOCG) and the Modern Slavery Unit (MSU), and the results presented to the BICS Board for sign off and to the Home Office Executive Board for information, then published on Horizon and shared, as appropriate, with partner agencies.
- In support of the updated statement of ‘Modern Slavery Strategy’ roles and responsibilities across BICS;
a) Produce BICS-specific guidance in relation to the identification, reporting and pursuit of perpetrators of modern slavery and human trafficking (MSHT) that complements ‘Modern Slavery Act 2015 – Statutory Guidance for England and Wales’, revising forms, work and information flows, points of contact, advice and expertise, etc. as necessary.
b) Conduct a skills gap analysis to identify where business areas and staff are not equipped to fulfil the MSHT ‘Pursue’ roles and responsibilities assigned to them and produce an improvement plan, incorporating a training plan, to bring them up to speed as quickly as possible.
- Create a cross-BICS/SOCG governance board to oversee the Home Office input to the ‘Pursue’ strand of the ‘Modern Slavery Strategy’. Membership should be at Director/Deputy Director level and the board should be accountable to Director General SOCG. Its responsibilities should include
a) agreeing a performance/delivery plan that takes full account of the priorities and taskings of the National Crime Agency Modern Slavery Threat Group (MSTG)
b) holding BICS/SOCG business areas to account for their performance
c) producing monthly performance reports for the BICS Board and “headlines” for the Home Office Executive Committee.
- ‘An inspection of the Home Office’s response to in-country clandestine arrivals (‘lorry drops’) and to irregular migrants arriving via ‘small boats’ (May 2019 – March 2020) was sent to the Home Secretary on 13 March 2020, but at the time of writing has not been published. Recommendation 1 from that report applies also to this inspection:
“[The Home Office should] Carry out a fundamental review of the Borders, Immigration and Citizenship System’s criminal investigation and prosecution capabilities and capacity, looking at clandestine entry (incorporating people smuggling, trafficking and modern slavery) and other immigration-related crimes, and revisiting with the National Police Chiefs’ Council (NPCC) and the National Crime Agency, and others if appropriate, where the underlaps are at National Intelligence Model (NIM) Levels 1, 2 and 3.”
The Government has accepted the first two recommendations and partially accepted the second two.
The Independent Anti-Slavery Commissioner, Dame Sara Thornton, said:
“The Independent Chief Inspector of Borders and Immigration (ICIBI) report laid in Parliament today outlines the critical role that Border Force, Immigration Enforcement and UK Visas and Immigration play in disrupting the activities of perpetrators of modern slavery and human trafficking. The report finds that the Home Office is not doing enough to identify, investigate, disrupt and prosecute the perpetrators of modern slavery, and opportunities to do so are being missed.
“The report follows discussions I had with Chief Inspector David Bolt on where this latest inspection could add the most value. The ICIBI conducted an inspection on the identification and treatment of potential victims of modern slavery by Border Force in 2017 and a re-inspection on progress made since that report in 2018. Both reports were carried out in cooperation with my Office.
“This latest report is focused on operational activity to identify, investigate, disrupt and prosecute perpetrators of modern slavery and human trafficking. The report finds that while operational activity has increased, the work of the Home Office and its three Borders, Immigration and Citizenship System (BICS) operational directorates is still siloed and disjointed, with little evidence of a plan to address this. The Chief Inspector sets out his recommendations for a clearer set of roles and responsibilities for BICS. He also advocates a much greater responsibility for the Home Office lead on serious and organised crime to provide leadership and coordination to the operational BICS units.
“The need for leadership and coordination is absolutely essential notwithstanding the challenges posed by upcoming Home Office reorganisation and the long wait for the review into serious and organised crime commissioned in November 2019.
“I will be scrutinising the Home Office response to these recommendations and look forward to seeing tangible action at both a strategic and operational level to disrupt and prevent these crimes from taking place at our borders.”
Read the ICIBI report ‘An inspection of the work of Border Force, Immigration Enforcement, and UK Visas and Immigration to identify, investigate, disrupt and prosecute perpetrators of modern slavery and human trafficking’
Read the Government response to the ICIBI report 'Response to the Independent Chief Inspector of Borders and Immigration’s report on work to identify, investigate, disrupt and prosecute perpetrators of modern slavery and human trafficking'