Expand nationwide the Independent Child Trafficking Guardians (ICTG) program and train more social workers and care providers to better safeguard child victims. • Vigorously prosecute and convict suspected traffickers, including in Scotland and Northern Ireland. • Implement reforms to the NRM, including timely determination of victim status, to encourage more victims to come forward. • Expand long-term care and reintegration support and monitor and assess outcomes of post-NRM support. • Ensure victims are not penalized for unlawful acts, including immigration violations, their traffickers compelled them to commit. • Establish a database on investigations, prosecutions, convictions, and prison sentence data across the UK, categorized by type of trafficking. • Ensure the statutory definition of trafficking under the MSA and similar provisions in Northern Ireland do not require movement of the victim as an element of the crime. • Continue to provide adequate information to foreign workers, especially the most vulnerable, on their legal rights and how to maintain their status in the UK post-exit from the EU. • Provide a clear route to residency for foreign victims and ensure potential foreign victims who are referred into the NRM can work. • Provide a trafficking-specific long-term alternative for foreign victims at risk if returned to their home country.

The government maintained prosecution efforts. The MSA, applicable to England and Wales, and similar statutes in Scotland and Northern Ireland, criminalized sex trafficking and labor trafficking and prescribed penalties of up to life imprisonment, which were sufficiently stringent and, with regard to sex trafficking, commensurate with those prescribed for other serious crimes, such as rape. Inconsistent with international law, the laws in England, Wales, and Northern Ireland required the element of movement of a victim in the definition of “trafficking.” However, these jurisdictions criminalized “slavery and servitude, and forced or compulsory labour” in other provisions of their law, which could be utilized to prosecute trafficking offenses that did not involve victim movement. Scotland, by contrast, did not require victim movement in the definition of trafficking.

In June 2020, there were 1,845 active law enforcement investigations of suspected trafficking crimes, compared with 1,479 in June 2019. The CPS prosecuted 267 defendants on trafficking charges, compared with 349 defendants prosecuted in 2019. Courts convicted 197 traffickers in 2020, a decrease from 251 convictions in 2019. The conviction rate increased slightly from 72 percent in 2019 to 74 percent in 2020. CPS data did not differentiate between sex and labor trafficking, nor did the government provide data on the range of sentences of convicted traffickers or percentage of convicted traffickers serving prison time. Court operations were curtailed throughout the reporting period due to the pandemic, leading to a backlog of more than 54,000 cases—including trafficking cases—in England and Wales by January 2021. The government reported it increased its use of intelligence, digital downloads, and financial information as investigative techniques for trafficking cases; these often resulted in guilty pleas. Police collaborated closely with the CPS and referred more cases for early investigative advice, leading to more evidence-led prosecutions; the government reported that relying on evidence over victim testimony was particularly successful in “county lines” cases, in which gangs exploited vulnerable individuals to transport drugs across county lines.

Scottish authorities convicted five individuals for trafficking offenses under the Scotland Human Trafficking and Exploitation Act (2015) between April 2019 and March 2020, the most recent period for which data was available. Police Scotland had a specialized anti-trafficking unit to coordinate information and intelligence and work with law enforcement agencies across Europe to investigate trafficking cases. In 2020, authorities in Northern Ireland arrested eight people and charged three people on trafficking or related crimes. Northern Irish authorities continued to prosecute five suspects in four separate cases; trials were pending at the end of the reporting period. 



In November 2020, media reported police arrested two suspected traffickers in Glasgow following police raids at two properties in the city; authorities reportedly identified 12 potential victims of sex trafficking during the operation. As part of an investigation started in 2017, courts sentenced one trafficker in 2020 in Northern Ireland to 12 months in prison—suspended for two years—on multiple counts of human trafficking and money laundering; despite the inadequate sentencing, this was the Police Service of Northern Ireland (PSNI)’s second operation to successfully lead to a conviction without victim testimony and the fourth conviction under Northern Ireland’s 2015 human trafficking law. Observers noted the greatest impediment to the timely prosecution of alleged traffickers in Northern Ireland remained inherent delays in the legal system, often taking two or more years from the time of initial arrest to conviction. The PSNI’s Modern Slavery and Human Trafficking Unit, which added five detectives in the previous reporting period, added three uniformed constables and a financial investigator in 2020. Through Project AIDANT COVID-19, the National Crime Agency (NCA) and Gangmasters and Labor Abuse Authority (GLAA) launched a series of counter-trafficking operations and awareness-raising activities throughout the UK in June 2020 focused on the food packaging and processing, shellfish, textiles, and garment industries; authorities initiated 27 new investigations, made 16 arrests, and referred 13 potential victims as a direct result of this operation. In May 2020, the government released a report noting that Project AIDANT had resulted in more than 770 trafficking-related arrests from 2017-2019.

The government provided a wide variety of anti-trafficking training to law enforcement officers, prosecutors, and first responders. The Home Office committed £2 million ($2.73 million) for law enforcement under the new Modern Slavery and Organized Immigration Crime program. The government trained prosecutors on building strong cases and identifying victims in the criminal justice system who may be subject to criminal exploitation; the training for new prosecutors included a module on the non-punishment of victims for unlawful acts traffickers compelled them to commit. Law enforcement created specialized training in May 2020 to raise awareness of trafficking among national helpline operators as they came into contact with potential victims during the pandemic. The Modern Slavery and Organized Immigration Crime Unit created guides for police on all elements of a successful trafficking investigation, from identification through prosecution. The PSNI hosted two courses for investigators; more than 50 officers had completed the course by the end of the reporting period. The Independent Anti-Slavery Commissioner (IASC) reported training for criminal justice officials had improved but was still insufficient.

The UK participated in 18 Joint Investigation Teams (JITs) with eight EU Member States, including a JIT with Romania established in December 2020 to investigate the suspected sex trafficking of Romanian women by Romanian suspects in Northern Ireland and Romania. Police Scotland participated in a JIT with international law enforcement partners to investigate a nationwide organized crime group involved in trafficking throughout Europe. Given the high number of potential trafficking victims from Vietnam, the government arranged for the secondment of two Vietnamese officers to Police Scotland for a period of six months, starting in October 2020. Furthermore, in the wake of the October 2019 incident involving the deaths of 39 Vietnamese nationals while being transported in the back of a refrigerated truck in Essex, the government engaged with Vietnamese authorities to identify and repatriate potential victims, share information, and conduct joint investigations. News reports highlighted multiple raids on properties in the cities of Glasgow and Aberdeen, as well as in England and Romania, in September 2020, leading to 24 arrests by police from both countries and the identification of a number of potential trafficking victims. Following the UK’s exit from the EU in December 2020, the government retained access to EU fingerprint, DNA, and passenger name record data, all of which it could use in trafficking investigations; however, the government lost access to some EU databases, which could impede some investigations. The 2019 decision by the Employment Tribunal that diplomatic immunity did not protect against trafficking charges was sent to the Supreme Court and a final decision was pending at the end of the reporting period. The government did not report any investigations, prosecutions, or convictions of government employees complicit in trafficking offenses.

The government maintained protection efforts. Through the NRM, authorities referred 10,613 potential trafficking victims for care nationwide in 2020; authorities referred 10,616 victims to care in 2019 and 6,993 in 2018. The Home Office maintained a detailed database online with disaggregated information, including source of referral, nationality, jurisdiction handling the referral, type of trafficking, and disposition of review. Of the referred victims, 74 percent were male and 26 percent were female. Authorities identified 4,946 children, an increase from 4,547 in 2019. Authorities flagged 1,544 referrals as “county lines” referrals, the majority (1,247) of which were boys. The majority of identified victims were UK citizens (3,560), followed by Albanian (1,638) and Vietnamese (653) nationals. Labor trafficking, including forced criminality, was the most common form of exploitation of adults and children. In Scotland, 387 potential victims were referred to the NRM, a decrease from 512 in 2019. In Northern Ireland, officials reported a significant increase in the number of potential victims referred to the NRM from 91 in 2019 to 128 in 2020.

The NRM was the framework for identifying and providing care and support for victims. First responders, such as police, Border Force, local authorities, and NGOs, continued to refer potential victims into the NRM throughout the pandemic. The Home Office’s single case management unit handled all NRM referrals and ensured victims continued to receive support. After a “reasonable grounds” decision that an individual was a trafficking victim, adult victims received a recovery and reflection period during which they could access support and protection measures, while awaiting a “conclusive grounds” decision, which was made no sooner than 45 calendar days after the “reasonable grounds” determination. If authorities recognized an individual as a victim per the “conclusive grounds” determination, they guaranteed the victim a minimum of 45 additional days of move-on support; the government utilized a recovery needs assessment to tailor ongoing support to the victim’s specific recovery needs and to determine the point at which a victim would exit the support services under the Modern Slavery Victim Care Contract. As of June 2020, authorities completed 1,132 recovery needs assessments. The Home Office published updated guidance in August 2020 that incorporated feedback from key stakeholders to improve operational processes and provide policy clarity on the recovery needs assessment process. In Northern Ireland potential victims received support for a minimum of 45 days while authorities reviewed their cases, and in Scotland potential victims received support for 90 days or until authorities made a conclusive grounds decision. The Wales Anti-Slavery Leadership Group’s “Survivor Care Pathway” provided a long-term post-NRM individualized plan for survivors.

NGOs and independent experts expressed concern victims often faced long wait times to receive a conclusive grounds determination under the NRM and that the current system did not adequately ensure victims exiting the system had a plan for sustainable independence, particularly foreign victims who may not be allowed to work, putting them at greater risk of re-trafficking. According to the Home Office, of the 10,613 NRM referrals during 2020, 8,665 were awaiting conclusive grounds determinations at the end of the year. Independent experts cautioned the end of the Brexit transition period at the end of 2020 could lead to further restrictions on foreign victims’ ability to work while in the NRM. In December 2020, the High Court ruled the Home Office’s policy on discretionary leave for trafficking victims under the NRM was unlawful; the Home Office planned to appeal the ruling. According to NGOs, authorities detained at least 2,914 potential victims of trafficking for immigration violations between January 2019 and September 2020. The government continued to explore ways to amend the NRM, including by issuing possible reforms via a press release in March 2021; NGOs roundly criticized the press release for insinuating criminals were abusing the NRM system and conflating immigration and human trafficking, and because the proposed changes risked deterring victims from being identified and criminalizing some potential victims. In response to the pandemic, the government produced e-learning tools on victim identification and referral for first responders. The NCA partnered with the legal sector to highlight “red flag indicators” to assist in victim identification and worked with the health service to improve guidance and training on interacting with sex trafficking victims. The Modern Slavery Police Transformation Unit continued to deliver trainings to law enforcement officers and first responders across the UK to identify and safeguard trafficking victims.

The government awarded a five-year, £281 million ($383.88 million) contract to an NGO to coordinate the provision of care for adult victims in England and Wales under the NRM. In January 2021, the government announced the introduction of minimum standards of care in all future contracts for support services to adult trafficking victims and an associated inspection regime. In response to the pandemic, the government distributed phones and data plans to facilitate remote support and appointments, provided payment cards for the distribution of pre-paid victim support payments, increased cleaning and provided personal protective equipment for safe houses, secured transportation for symptomatic victims, and implemented a temporary policy to ensure victims could remain in safe houses for at least three months. The IASC urged the government to increase efforts to provide safe mainstream accommodation for victims after they exit a safe house. An NGO further observed many female trafficking victims were not offered safe house accommodations, but were rather placed in unsafe asylum housing. The government included £1.73 million ($2.36 million) for services for trafficking victims in its £750 million ($1.02 billion) pandemic-related relief package. In July 2020, the government increased weekly payments to potential victims receiving other forms of support, such as medical, legal, and educational services; increased weekly payments for child dependents; and introduced new weekly payments for pregnant and young child victims. In May 2020, the Scottish Government announced approximately £1.5 million ($2.05 million) in additional funding to the two NGOs providing victim protection and support. To avoid re-traumatization, authorities encouraged police to use intelligence-led investigations, pre-recorded cross-examination for vulnerable victims, and allowed victims to apply for reporting restrictions and other measures to maintain anonymity. The government encouraged efforts of private companies to assist in reintegration, particularly through employment of survivors. Under the “Bright Future” campaign, a national retail cooperative continued to hire and train survivors in partnership with an NGO, a model the government promoted for expansion; as of October 2020, Bright Future had successfully placed 63 survivors into permanent employment. The government engaged directly with survivors to better understand their recovery needs and experiences with the NRM and worked with the independent regulator for health and social care services to solicit survivor feedback for the creation of an inspection regime for government-commissioned victim support services.

Children received care through children’s services offices in local jurisdictions; social workers worked with potential child victims to assess needs and create a care plan that included health, legal, education, and accommodation support. The rollout of ICTGs continued throughout England and Wales and focused on areas with the highest need; these guardians provided an additional source of advice, support, and advocacy for child trafficking victims. Nevertheless, an NGO noted the government did not provide a timeline for full implementation of the ICTG service, which has supported over 900 children since its inception in February 2017. NGOs highlighted concerns about the difficulty of safeguarding children who the government relocated away from their home to parts of the country where services are available; criminal gangs actively targeted vulnerable children who are taken out of their communities and run away or go missing. The Home Office launched a pilot program to devolve NRM decision-making for children to local authorities. Throughout 2020, the IASC collaborated with the Home Office to convene roundtables for local authorities to discuss potential approaches to devolved decision making. The MSA review committee recommended implementation of the ICTG system nationally, along with sufficient duration for providing services to child victims, in addition to requiring police to track cases of missing children until they are located, regardless of timeframe. NGOs continued to express concern that child victims who reached the age of 18 and therefore were no longer eligible for the ICTG service would be at risk of re-trafficking. The government committed to extending the ICTG service to individuals over the age of 18 in select sites as part of the continued rollout. In October 2020, the government assessed the role of the ICTG Regional Practice Coordinators (RPCs). RPCs worked with the social workers that supported children who had a parental figure, whereas ICTG direct workers provided direct support to children without a parental figure. NGOs expressed concern children assigned an RPC did not receive the full benefits of an ICTG direct worker who could advocate on their behalf. Scotland and Northern Ireland also required the appointment of independent legal guardians for child trafficking victims and trained the guardians on the support services available.

The government did not automatically grant foreign victims legal status in the UK; authorities reviewed requests for permission to remain in the UK outside the immigration rules, known as “discretionary leave” on a case-by-case basis. Discretionary leave decisions were not linked to an individual’s status as a confirmed trafficking victim but were judged on individual circumstances. Foreign victims who were granted a reflection period could not be removed from the UK during that period. Foreign victims who assisted with investigations were eligible for residency. However, observers reported residence permits were only issued in a minority of cases and then often only for 12 months. NGOs continued to express concern some foreign victims may have declined to enter the NRM for fear of deportation upon exiting the system. Under the EU Settlement Scheme, EEA citizens had to apply for legal status to remain in the UK by June 2021; in January 2021, the Home Office published reasonable grounds for missing this deadline, of which being a victim of exploitation was included. The government increased funding to local authorities and organizations who assisted victims with applying for status under the scheme and made resources available on the government’s website. Foreign overseas domestic workers (ODW) could legally change employers during the six-month period of their visa. Workers on the ODW visa identified as trafficking victims could apply for a two-year visa as a domestic worker, although NGOs contended workers who had suffered abuse would be unlikely to want to return to the same sector. NGOs urged the government to adopt reforms to the ODW visa, particularly in light of the heightened exploitation overseas domestic workers faced as a result of the pandemic. Foreign nationals identified as trafficking victims could apply for discretionary leave to remain in the UK if supporting the investigation of a trafficker, seeking compensation through a civil claim against the perpetrator, or in some cases, based on personal circumstances. Foreign victims could petition for asylum, based on risks faced if returned to their country of origin.

Victims had a statutory defense for most crimes committed as a direct result of being subjected to trafficking; the defense did not apply to the most serious crimes, such as sexual offenses or offenses involving serious violence. In these cases, the CPS had to consider whether it was in the public interest to prosecute the trafficking victim. The IASC concluded the statutory defense was inadequate to protect trafficking victims and police often did not consider the possibility of forced criminality at the beginning of an investigation, risking the punishment of victims. The European Court of Human Rights ruled in February 2021 that the UK failed to protect two victims of trafficking by punishing them for unlawful acts traffickers compelled them to commit. In another case, the government granted a last-minute reprieve from deportation to 10 Jamaican citizens in December 2020, some of whom the government identified as potential trafficking victims. Following criticism from NGOs and independent observers that the government did not sufficiently screen migrants crossing the English Channel for indicators of trafficking, the government issued a statement in October 2020 urging law enforcement authorities not to arrest smugglers who showed signs of exploitation by criminal gangs. Observers expressed concern the government stripped citizenship from British citizens who went to Syria and Iraq to join ISIS without screening them for indicators of trafficking, despite indications some of them may have been child victims of trafficking. The courts allowed victims to testify by video, behind a screen, or with the public removed from the courtroom during hearings. Courts could grant restitution, but only after conviction of the trafficker and if satisfied that the defendant had the means to pay. However, NGOs noted courts infrequently granted restitution and although victims could apply for compensation, this remedy was difficult to access given the small number of legal aid providers available to file such claims. Moreover, traffickers could appeal or contest a compensation order and observers noted traffickers often moved assets, meaning that awards were often not paid in practice. In October 2020, the British Embassy in Slovakia and the Slovak government issued a press release informing Slovak trafficking victims who had been exploited in the UK about the possibility of receiving restitution from the seized assets of convicted traffickers and highlighted an August 2020 UK court ruling that convicted two Slovak nationals to six-year prison sentences and ordered them to pay £52,000 ($71,040) and £78,000 ($106,560), respectively, to their two victims.

The government increased prevention efforts. The Home Office published its 2020 annual report in October, with detailed data on anti-trafficking efforts across the UK as well as an outline of achievements and remaining challenges to fully implement the MSA. The Ministry of Justice produced a draft Modern Slavery Strategy for 2021-2022 and opened it to public consultation from October 2020 to January 2021. In its draft Organized Crime Strategy for 2020-2021, the government listed human trafficking among the top operational priorities for the Organized Crime Task Force. The IASC encouraged good practice in the prevention, detection, investigation, and prosecution of trafficking offenses as well the identification of victims. In May 2020, the Scottish Government published its third annual progress report on its anti-trafficking strategy. The Criminal Justice Inspection Northern Ireland published its first in-depth assessment of how the criminal justice system in Northern Ireland addressed trafficking and noted good working relationships amongst law enforcement; the report made several recommendations, including improving enforcement powers, increasing efforts to counter child trafficking and protect child victims, and providing additional training for front-line police officers.

The government invested £10 million ($13.66 million) over a five-year period to fund a new Modern Slavery Policy and Evidence Centre to better understand trafficking and how to confront it and to develop research to inform policy choices. In 2020, the government partnered with a university to launch a program to pair policy officials and academics to strengthen collaboration to counter trafficking. The government conducted awareness campaigns across the UK with a wide range of partners. The “Hidden in Plain Sight” campaign targeting front-line professionals in the financial, health care, and recruitment sectors in four English regions reached more than 17 million people and led to a 30 percent increase in calls to the National Modern Slavery Helpline. The GLAA coordinated with an NGO to raise awareness among job seekers about fake online recruitment advertisements, including those placed by gangs to lure young Romanian men to nonexistent jobs. Building on established collaboration with the retail, construction, and textile industries, the GLAA partnered with an NGO to create a hospitality protocol; the launch was postponed due to the pandemic. Sixty-five percent of signatories to the GLAA’s construction protocol reported implementing reforms to due diligence measures to identify and prevent labor exploitation in their supply chains. The GLAA coordinated with the Church of England to develop and launch an application to combat rural labor exploitation. Following allegations of labor exploitation in the garment industry in Leicester, England, the government established a multiagency taskforce in July 2020 to gather and share intelligence, raise awareness, and persuade workers to report concerns. Nevertheless, NGOs continued to raise concerns that some apparel companies operating in Leicester used forced labor in their operations. A parliamentary committee urged the creation of a garment industry watchdog that could monitor compliance with labor laws, issue recommendations, and impose fines for non-compliance. Despite having a national remit, extended powers as of 2018, and 50 dedicated investigators, NGOs argued that since 2018 the GLAA reported fewer trafficking cases and dedicated fewer resources to investigating labor exploitation, focusing instead on awareness raising.

The MSA required organizations with annual turnover exceeding £36 million ($49.18 million) to publish an annual statement detailing efforts to ensure its operations and supply chains were free of human trafficking. However, observers noted the MSA did not include a mechanism to ensure compliance; an NGO report issued in February 2021 stated that since the law’s inception in 2015, the government had not issued any penalties to companies despite approximately 40 percent of companies not complying with the law. In September 2020, the government announced measures to strengthen reporting requirements, introduced mandatory reporting topics, extended the reporting requirement to public bodies with a budget of at least £36 million ($49.18 million), and required entities to publish statements on a new registry launched in March 2021 in an attempt to increase compliance. In addition to publishing in March 2020 the world’s first government modern slavery statement outlining steps taken to encourage responsible procurement practices, the government launched the Modern Slavery Assessment Tool to assist public sector organizations in coordinating with suppliers to improve protections and reduce the risk of exploitation of workers in their supply chains. The government extended into 2021 the seasonal workers pilot to ensure that fruit and vegetable farmers could legally employ non-EU migrant farmers for seasonal work for up to six months, with an expanded quota of 30,000 available visas. NGOs noted the pilot left migrant workers vulnerable to exploitation; according to an NGO study, many of the workers accrued large debts and were limited in their ability to change employers. NGOs expressed concern the government’s strict immigration policies, which criminalized the act of working while undocumented, continued to prevent trafficking victims from seeking help. In January 2021, the government published a whole-of-government strategy to counter all forms of child sexual abuse; the strategy included a national action plan on combating international child sex tourism. The government did not report making efforts to reduce the demand for commercial sex acts but criminalized soliciting a sex trafficking victim.

The government funded a wide range of anti-trafficking programs globally, including continued implementation of programs under the £33.5 million ($45.77 million) Modern Slavery Fund, of which the government committed £7.8 million ($10.66 million) to a range of anti-trafficking efforts in 2020. The government has invested more than £10 million ($13.66 million) since 2017 in programs in Nigeria, Albania, and Vietnam to provide rehabilitation and reintegration services, targeted outreach to at-risk communities, and training for law enforcement and other first responders on how to apply a victim-centered approach in their work. In Nigeria, the government delivered the second phase of the “Not for Sale” campaign to counter trafficking and worked with civil society and government stakeholders in India to address bonded labor. Through the Modern Slavery Innovation Fund, the government funded projects to strengthen workers’ rights in Malaysian factories and provided direct assistance to trafficking victims in Ethiopia. The UK’s Commonwealth Parliamentary Association (CPA UK) works with Commonwealth countries to pass human trafficking legislation, using a tailored approach suited to each country’s needs and capacity. In February 2021, CPA UK organized a virtual anti-trafficking workshop for Caribbean countries, the organization’s first focused engagement on trafficking with the Caribbean region. Experts reported many of the government’s global anti-trafficking aid programs did not demonstrate direct impact in reducing the prevalence of trafficking and did not adequately include monitoring and evaluation mechanisms.

As reported over the past five years, human traffickers exploit domestic and foreign victims in the UK, and traffickers exploit victims from the UK abroad. Although the government reported 10,613 potential victims came through the NRM in 2020, one NGO estimates the actual number of victims in the UK is closer to 100,000. The UK, Albania, and Vietnam are the leading nationalities of potential victims referred into the NRM. Twenty-six percent of potential victims assert their exploitation occurred entirely outside of the UK. Labor trafficking, including forced criminality, is the most common form of exploitation among adults and children. Migrants crossing the English Channel in small boats are vulnerable to exploitation; more than 8,000 migrants crossed the channel in 2020, many of whom were unaccompanied children. Nearly half of all victims identified are children. Children in the care system and unaccompanied migrant children are particularly at risk of trafficking. Youth trafficked by gangs are forced to act as drug couriers from larger cities into rural areas across the UK. Traffickers force adults and children to work in agriculture, cannabis cultivation, construction, food processing, factories, domestic service, nail salons, food services, the hospitality industry, car washes, food supply industry, and warehousing, as well as on fishing boats. In Scotland, most victims are from Vietnam with many forced to work in agriculture, cannabis farms, and nail bars. In Northern Ireland, there are cases of perpetrators forcing victims into shoplifting and the cultivation and distribution of illicit drugs. Young women and girls from Albania, Bulgaria, and Romania, including ethnic Roma, remain vulnerable to sex trafficking in Northern Ireland.