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IJM UK's Statement on the New Plan for Immigration


IJM UK's Statement on the New Plan for Immigration

The UK has played a pivotal role in addressing modern slavery at home and abroad. IJM welcomes the review of the 2014 Modern Slavery Strategy, yet changes to the process of identifying and supporting survivors proposed in the New Plan for Immigration provide legitimate cause for concern and risk undoing progress made. Below, IJM UK outlines several recommendations.


n recent years, the UK has played a pivotal role in focussing attention and resources on addressing modern slavery both domestically and internationally.

This has led to a greater collective understanding of the issue and more effective identification of survivors. There is always room for improvement, to learn the lessons learned from experience, and so IJM UK welcomes the proposed review of the 2014 Modern Slavery Strategy and hope this presents an opportunity to build on past success.

The New Plan for Immigration proposes a number of changes to the process of identifying and supporting survivors of modern slavery in the UK. IJM is concerned that several of these changes risk undermining progress which has been made.

A number of the changes appear to raise barriers to support or otherwise disadvantage survivors who are unable to disclose details of abuse, or whose account contains inconsistencies. It is vital that systems of identification understand the impact of trauma and fear on an individual and their willingness or ability to share such details.

IJM teams work with local authorities and law enforcement to tackle slavery and violence: identifying people who are suffering exploitation and helping them to safety; and supporting the criminal justice system ensure laws are enforced and traffickers held to account. Through casework in collaboration with law enforcement and other actors, we have seen the importance of strategies that centre on the needs of survivors, acknowledge the complexity of their experiences, and strengthen access to justice. A number of the proposals outlined in the New Plan for Immigration risk undermining these principles.

Modern slavery is not only a crime, but also a symptom of systemic problems: a consequence of conditions which leave particular groups vulnerable to abuse. This is why, in order to tackle it effectively, we must take a holistic view which questions whether laws, policies, language and behaviour, intentionally or otherwise, place people at greater risk.

IJM UK urges the Home Office to enact policies that are committed to the following three principles.

1. Making justice systems truly accessible through trauma-informed policies

IJM’s work and theory of change is premised upon the strengthening of the rule of law in countries where we work. Public justice systems must be able to fairly and visibly enforce just laws, shifting the balance of power away from traffickers to those who are vulnerable.

Therefore, strengthening rule of law requires strengthening access to justice. Perpetrators cannot be held to account unless survivors are able to safely come forward and access appropriate, trauma-informed support.

We recommend that systems for identifying and supporting survivors of modern slavery must be built on an understanding of the impact of trauma. Survivors of modern slavery have suffered great physical, sexual and psychological trauma. As a result, disclosing details of their exploitation can prove to be a difficult and retraumatising process due to trauma, or fear.

A number of the proposed reforms to the National Referral Mechanism appear to underestimate the impact of trauma. Only systems that are genuinely trauma-informed can be considered accessible, and only systems that are accessible may be considered effective.

2. Acknowledging the complexity of victims’ experiences

In recent years, as our collective understanding of modern slavery has improved and become more nuanced, we have understood that everyone’s experience of exploitation is different, and everyone’s response to trauma is different.

There is no ‘perfect victim’, who is able to consistently explain without retraumatisation, every detail of their experience of exploitation. Expecting that survivors can do so underestimates or does not understand how trauma can affect stress levels, fear and, crucially, memory. In order for victims to access justice, it is vital that our system of support is sensitive to this complexity and considerate of individual needs.

Sometimes people are forced to enter the UK illegally, and won’t know where they are being taken. In those cases, traffickers can control their victims with threats of prosecution for illegal working. To further limit rights to protection or asylum on the basis of crimes they have been forced to commit, or how they have entered the country risks creating even greater vulnerability.

A victim-centred approach to addressing modern slavery means believing those who are brave enough to come forward, or who show signs of having suffered exploitation.

3. Long-term support for survivors

The support provided must be tailored to meet the individual needs of survivors. It must prioritise the individual’s needs over other concerns and come from a place of trauma literacy.

Long-term support is necessary not only for the individual’s own recovery, but to help law enforcement efforts to disrupt trafficking networks.

Through our collaborative casework approach around the world, including in our cross border programme in Europe, IJM have seen that when justice systems are trained and equipped to proactively hold perpetrators to account and protect vulnerable people, the prevalence of exploitation can be substantially reduced.

In order for this to succeed, it must be done in tandem with providing specialist support for survivors. This means from the first interaction with the individual through to after the Conclusive Grounds decision has been reached. Crucially, support must also extend to those who have chosen to return to their country of origin.

In summary, IJM UK welcomes the government’s intention to review its Modern Slavery Strategy as an opportunity to apply what has been learned in the years since the Strategy’s introduction – so long as this is guided by the principles outlined above. The UK is at a pivotal moment as it seeks to redefine its position on the world stage, and so we urge the government to adopt a posture of compassion, generosity and welcome for those most in need of support.

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