processes, which should continue in tandem.63 Where HOCA does not reach a reasonable grounds
conclusion, but the child is able to subsequently disclose further details, or other professionals are
able to provide more information, the case can be resubmitted to the first responder or support
provider for reconsideration.64
Evidence collected from referrals may help to produce a national picture and can inform
the decisions of policymakers and operational staff. NRM referrals and the intelligence they
provide can potentially contribute directly to efforts to tackle modern slavery and may ultimately
lead to a reduction in these cases seen in the United Kingdom. The NRM referrals also encourage
a multiagency working approach, as well as a more comprehensive view of the collected evidence
The NRM itself was reviewed in 2014, and an interim report was published later that year.66
Although not immediately implemented, the key recommendations of the report were to:
a) strengthen the first responder role (the point when potential victims are first identified and
referred) by creating new Slavery Safeguarding Leads (SSLs);
b) streamline the referral process by removing the “reasonable grounds” decision once the
successful implementation of accredited SSLs has occurred, allowing direct referral to
specialist support for potential victims;
c) establish new multidisciplinary panels headed by an independent chair with a view to cease
the sole decision-making roles of the UKVI and MSHTU; and
d) create a single case management unit within the Home Office to replace the case
management units in the MSHTU and UKVI.67
In October 2017, the U.K. government’s Modern Slavery Taskforce announced three new
measures to improve the way in which victims of modern slavery are identified and supported:
a) A single expert unit will be created in the Home Office to handle all cases referred from
frontline staff and to make decisions about whether someone is a victim of modern slavery.
This will replace the case management units in the NCA and UKVI, which will be
completely separate from the immigration system.
b) An independent panel of experts will be introduced to review all negative decisions.
c) A new digital system to support the NRM process will be introduced, making it easier for
frontline responders to refer victims for support and enabling data to be captured and
analyzed to better aid prevention and law enforcement.68
D. A Wider Definition of Labor Trafficking
The prosecution and courts are expected to give consideration to all circumstances when
determining whether a person is a victim of slavery, servitude, or forced labor.69 These can include
63 HOME OFFICE, supra note 53, at 16.
64 Id. at 22.
65 Id. at 24.
66 See generally HOME OFFICE, INTERIM REVIEW OF THE NATIONAL REFERRAL MECHANISM FOR VICTIMS OF HUMAN
TRAFFICKING, available at https://www.gov.uk/government/publications/interim-review-of-the-national-referral-mechanism-for-victims-of-human-trafficking (last updated Nov. 12, 2014).
68 Rt. Hon. Amber Rudd, Modern Slavery Taskforce Agrees New Measures to Support Victims, GOV. UK (Oct. 17,
69 CROWN PROSECUTION SERV., supra note 36.