when it comes to interviewing victims, especially if they are minors. Specialist training should be
necessary for conducting interviews with victims with special needs, such as minors or traumatized
victims. Where there are multiple interviewers, they should all take turns explaining their roles to
the victim.35 Better planning of interviews with victims who have extreme vulnerabilities is
advisable, not only for the conduction of the interview, but also for purposes of presentation in
C. National Referral Mechanism
The National Referral Mechanism (NRM) is a single framework centered on victim
identification and referral to appropriate support.37 The NRM was introduced in 2009 to meet the
United Kingdom’s obligations under the Council of Europe’s Convention on Action against
Trafficking in Human Beings.38 First responders (such as police, immigration authorities, local
authorities, and certain non-governmental organizations)39 handle the initial referral. They may
refer all suspected victims of trafficking to a competent authority for a decision on whether the
individual is a victim of trafficking.40 The competent authorities that decide whether an individual
is a victim of trafficking are the Modern Slavery Human Trafficking Unit (MSHTU) of the
National Crime Agency (NCA) and the Home Office Competent Authority (HOCA) section of the
Home Office’s Visas and Immigration (UKVI) unit.41
Under the NRM, a first responder initially completes a referral form42 recording the
encounter with a potential victim. The first responder provides adequate information on the form
to enable a decision on whether the subject has "reasonable grounds" for being treated as a victim
of trafficking. A reasonable grounds decision is based on "I suspect, but cannot prove"43; general
indicators of a potential victim's behavior, circumstances, and responses to questions assist in the
All referrals to the NRM from first responders must initially be sent to the MSHTU.45 The
MSHTU also manages the data on NRM referrals. The MSHTU has jurisdiction in cases that
involve a U.K. or European Economic Area (EEA) national.46 When the MSHTU receives a
referral of a U.K. or EEA national who is subject to immigration control or part of an asylum case,
the MSHTU will refer the case to HOCA, which makes the reasonable and conclusive grounds
36 Human Trafficking, Smuggling and Slavery, CROWN PROSECUTION SERV., https://www.cps.gov.uk/legal-guidance/human-trafficking-smuggling-and-slavery (last visited May 24, 2018).
37 A full list of first responders is available at National Referral Mechanism, NAT’L CRIME AGENCY, NAT’L REFERRAL
MECHANISM, http://www.nationalcrimeagency.gov.uk/about-us/what-we-do/specialist-capabilities/uk-human-trafficking-centre/national-referral-mechanism (last visited May 24, 2018).
38 CROWN PROSECUTION SERV., supra note 36.
39 National Referral Mechanism, supra note 37.
40 CROWN PROSECUTION SERV., supra note 36.
41 National Referral Mechanism, supra note 37.
42 Referral forms are available at Modern Slavery Victims: Referral and Assessment Forms, 16, GOV. U.K.,
https://www.gov.uk/government/publications/human-trafficking-victims-referral-and-assessment-forms (last updated
May 22, 2018).
43 CROWN PROSECUTION SERV., supra note 36.