Futures of Work ~ Reflections and suggestions from the second U.Ok. Impartial Anti-Slavery Commissioner

The function of the Impartial Anti-Slavery Commissioner was established by the Fashionable Slavery Act 2015 to encourage good follow within the prevention, investigation and prosecution of contemporary slavery offences and the identification and help for victims.

In 2019, I used to be appointed because the UK’s Commissioner and served for 3 years. This text displays upon my expertise in that function, makes observations on latest developments and suggestions for future laws on fashionable slavery.

My strategic plan set 4 high-level aims in 2019: enhancing sufferer care and help; supporting regulation enforcement and prosecutions; specializing in prevention; and getting worth from analysis and innovation.

Enhancing sufferer care and help

The main target of sufferer care had traditionally been on identification and instant help, and whereas this remained necessary, I used to be additionally eager to extend help over the long run and allow survivors to dwell lives of sustainable independence. Key to this have been points similar to entry to training and coaching, job alternatives, first rate lodging, settled immigration standing and long-term psychological help. I labored intently with survivor teams on this agenda and employed a survivor in my workplace.

Nevertheless, my work to help victims passed off in an more and more hostile atmosphere. Shortly after I took up my appointment, there was a change of presidency, and fashionable slavery was now not a political precedence; victims of trafficking have been seen nearly completely by an immigration lens. The main target of ministers was on immigration laws and suggestions of the Impartial Evaluation into the Fashionable Slavery Act[1] to amend and strengthen the Act, which the federal government had largely accepted have been by no means applied. The New Plan for Immigration was revealed in March 2021, and the accompanying press launch claimed ‘an alarming rise in folks abusing our fashionable slavery system by posing as victims so as to forestall their elimination and allow them to remain within the nation’[2].

The proof of this alleged abuse was by no means produced, and annual will increase within the variety of victims recognized have been seen as proof of abuse – with no account taken of the Residence Workplace’s constructive evaluation of 85-90% of instances. This technique laid the best way for 2 items of laws: the Nationality and Borders Act in 2022 after which the Unlawful Migration Act in 2023. Each severely undermined sufferer safety generally. As a consequence of the change in authorities, many of those provisions haven’t been enacted, however they continue to be on the statute e-book.

Nevertheless, because the political concentrate on irregular arrivals on small boats throughout the Channel has intensified, it was inevitable that the present Labour authorities would return to the difficulty. In September 2025, an Eritrean man who had arrived within the UK by small boat and was as a result of be returned to France beneath the “one in, one out” returns pilot scheme between the UK and France received a last-minute authorized declare to briefly block his elimination to France.[3] His legal professionals efficiently argued that he wanted extra time to current proof that he could be a sufferer of contemporary slavery.

The federal government has put a lot retailer by the settlement with the French, and it was no shock to listen to the Residence Secretary observe, “Migrants abruptly deciding that they’re a contemporary slave on the eve of their elimination, by no means having made a declare earlier than, make a mockery of our legal guidelines and his nation’s generosity”.[4] The Residence Workplace instantly challenged this determination within the Court docket of Attraction however was unsuccessful. This skirmish within the courts has led the Residence Secretary to vow to look once more on the Fashionable Slavery Act[5] and the Prime Minister to argue that we have to look once more on the interpretation by the courts of the European Conference on Human Rights (ECHR) and different worldwide treaties in immigration instances.[6] There may be rising unease that some provisions of worldwide regulation are being interpreted too expansively to permit states to deal with the fashionable scale of migration. Victims of contemporary slavery in want of safety might be impacted.

Supporting regulation enforcement and prosecutions

I used my information and networks as a former chief constable to encourage prioritisation and professionalisation. Circumstances of slavery and trafficking are advanced and complex – they require the event of experience and ample resourcing. I convened and supported regulation enforcement, and particularly, inspired using monetary investigation and prosecutions that didn’t depend on the testimony of weak victims. The Home of Lords report on the Fashionable Slavery Act in 2024 reported that the prosecution fee was low at 1.8% however acknowledged the problem of proof gathering given the hidden nature of the crime and the similarity to charges for home abuse and sexual offences, that are respectively 1% and three%. [7]

‘Observe the cash’ was initially about political corruption, however it’s a good response for anti-slavery. I pursued this theme whereas encouraging good follow with each regulation enforcement and the monetary companies sector. I revealed two stories on monetary investigation and beneficial to regulation enforcement that they make a step change of their use of economic investigation, monetary intelligence from suspicious exercise stories and their funding in public-private partnerships.[8] [9] Monetary investigation can present important proof for the prosecution, nevertheless it additionally will increase the chance of returning the proceeds of crime to victims.

Nevertheless, because the political concentrate on fashionable slavery diminished, it was inevitable that the regulation enforcement focus would accomplish that too. In the previous few months, the Impartial Anti-Slavery Commissioner has reported that “the management and coordinated motion that when drove progress have pale. The policing constructions constructed to sort out fashionable slavery are being dismantled, leaving hard-working officers ill-equipped to sort out fashionable slavery.”[10]

Specializing in prevention

Defending victims and prosecuting traffickers isn’t sufficient. There must be a larger concentrate on prevention. Given an estimated 28 million folks in compelled labour throughout the globe, extra must be accomplished to sort out the worldwide techniques and constructions that permit this devastating crime of contemporary slavery to thrive[11]. Aggressive business practices and company negligence intersect with fragile communities, migrant labour, corruption and criminality, leading to exploitation throughout the globe. Fashionable slavery and human trafficking are financial crimes producing US$236 billion a yr in revenue[12]. In my time as Commissioner, I revealed a number of stories on the function of enterprise in stopping exploitation.[13][14]

Within the 4 years since I stepped down because the Commissioner, I’ve targeted my efforts on the function of enterprise in stopping fashionable slavery. On the College of Nottingham’s Rights Lab, we associate with Sainsbury’s to analysis their salient and evolving human rights dangers, interpret how these dangers will have an effect on their enterprise sooner or later and perceive how they will reply. [15] At CCLA Funding Administration, now we have benchmarked the highest UK firms on their efficiency in addressing fashionable slavery in order that buyers can maintain them to account and encourage enchancment.[16]

And lastly, I used to be eager to bridge from the academy to coverage and follow. Constructing collaborations with many analysis centres and supporting their work was a precedence. And no,w as a member of a analysis centre, I’m persevering with that work from the opposite aspect of the bridge.

Suggestions

It’s tempting to collate a protracted want listing of suggestions, however I’ve tried to concentrate on the priorities and restricted myself to 3.

Gentle-touch approaches to compelled labour in companies and their provide chains haven’t impacted the enterprise fashions the place short-term revenue is pursued on the expense of long-term hurt. The transparency in provide chains necessities of the Fashionable Slavery Act have to be tightened as much as embody the general public sector, to mandate the knowledge required by fashionable slavery statements, and to impose civil penalties for non-compliance. However in the end, this laws is about disclosure. Laws must immediate motion to determine dangers and forestall and mitigate them. Whereas this authorities urges companies to conduct human rights and environmental due diligence, the Joint Committee on Human Rights just lately concluded that items made with compelled labour have been getting into the UK – cotton, tomato merchandise, photo voltaic panels and important minerals.[17] Voluntary approaches are clearly not succeeding, and the federal government ought to introduce laws to carry firms to account for conducting human rights and environmental due diligence.
The conflation of contemporary slavery and immigration places the Impartial Ant-Slavery Commissioner within the political crosshairs. The independence of the function must be strengthened: the appointment and renewal shouldn’t be within the arms of a minister the place there’s an apparent battle of curiosity; the appointment ought to be for 5 or seven years so {that a} publish holder can converse with out concern of favour and there ought to be ample resourcing.
Fashionable slavery is probably the most egregious type of exploitation, nevertheless it thrives the place labour inspection, enforcement of requirements and employee engagement are poor. The institution of the Truthful Work Company is a chance to make a step change within the safety of staff; it should not be wasted.

Dame Sara Thornton, a former chief constable, served because the U.Ok.’s Impartial Anti-Slavery Commissioner from 2019-2022. She is a Professor of Follow in Fashionable Slavery Coverage on the Rights Lab, College of Nottingham and a marketing consultant in fashionable slavery at CCLA Funding Administration.

[1] https://www.gov.uk/authorities/publications/independent-review-of-the-modern-slavery-act-final-report/independent-review-of-the-modern-slavery-act-final-report-accessible-version

[2] https://www.gov.uk/authorities/information/alarming-rise-of-abuse-within-modern-slavery-system?utm_medium=e-mail&utm_campaign=govuk-notifications&utm_source=6c102776-b34d-40fa-be92-832918e4befd&utm_content=day by day

[3] https://www.bbc.co.uk/information/articles/c1dqe2443l1o

[4] https://www.bbc.co.uk/information/articles/cj3yrrnydero

[5] https://www.theguardian.com/uk-news/2025/sep/23/home-office-blocked-from-appealing-against-halt-to-deportation-of-eritrean-under-one-in-one-out

[6] https://www.bbc.co.uk/information/articles/cd72p30v574o

[7] https://publications.parliament.uk/pa/ld5901/ldselect/ldmodslav/8/8.pdf

[8] https://www.antislaverycommissioner.co.uk/media/jk0ohl1i/financial-investigation-of-modern-slavery-march-2021.pdf

[9] https://www.antislaverycommissioner.co.uk/media/n5emst4j/financial-review-part-2-november-2021-iasc.pdf

[10] https://www.antislaverycommissioner.co.uk/news-insights/report-policing-response-to-modern-slavery-how-has-it-changed-in-the-last-10-years/

[11] https://www.ilo.org/publications/major-publications/global-estimates-modern-slavery-forced-labour-and-forced-marriage

[12] https://www.ilo.org/useful resource/information/annual-profits-forced-labour-amount-us-236-billion-ilo-report-finds