Last year, after the General Election and the change to a Labour Government, the UK saw a significant change to the UK political landscape.
At the Modern Slavery and Human Rights Policy and Evidence Centre (PEC), we responded by publishing our wide-ranging report on priorities for modern slavery policy for the new UK Government. We pointed out how the Government faces significant challenges, including increases in the scale of modern slavery identified in the UK alongside reduced political momentum globally. However, at the same time, we see substantial opportunities for the Government to provide a renewed, ambitious, joined-up and prevention-centred UK policy response which ultimately would reduce the significant harms to individuals and communities affected by modern slavery.
We are already seeing a shift in tone and action on modern slavery and human rights from the new Government.
Firstly, responsibility for modern slavery policy in the Home Office is now wholly under the purview of the Minister for Safeguarding and Violence Against Women and Girls, Jess Phillips MP. Under the previous government, the Minister for Immigration had responsibility for aspects of modern slavery policy which had led to concerns about conflation of immigration and modern slavery policies in ways that were detrimental to survivors. The Minister, who herself has experience of frontline work with survivors of modern slavery, has taken an early focus on re-setting relationships with key partners, including by hosting two roundtables with anti-slavery organisations during Anti-Slavery Week.
This shift can also be seen in more subtle ways, for example in the language used by the new UK Government in their response to a recent House of Lords Committee report. The Government stated the Committee’s recommendations will steer their work to implement “a reformed modern slavery system that puts victims first and rebuilds the UK’s international standing.”
On human rights, both the Prime Minister and the Attorney General have been unequivocal about the Government’s commitment to international law, including the UK’s obligations under human rights treaties, which provides an opportunity for a human rights-based approach to modern slavery policy, as explored in the recent blog by the PEC Director Murray Hunt.
There are areas where the new Government has signalled an intention to do more but where the details haven’t been set out yet. It is likely that the ongoing Spending Review – the Government’s process for setting departmental budgets - will be a significant factor shaping the detail of some of these policies.
For example, the Government’s response to the House of Lords Committee report highlighted the Minister’s commitment to making sure survivors’ voices are at “the heart of the government’s work”, but we don’t yet know how that will work in practice. Our policy priorities report recommended the government puts in place a mechanism to meaningfully and ethically engage people with lived experience of modern slavery in policy development, which should be appropriately resourced and remunerated, and take a non-tokenistic and trauma-informed approach.
Minister for Safeguarding Jess Phillips set about to reset relationships with anti-slavery organisations, here with the PEC delegation.
We’ve broken down where we expect to see activity on specific areas of modern slavery policy in 2025.
Survivor identification and support
One of the new Government’s earliest announcements on modern slavery was the plan to recruit 200 new decision-makers to the Home Office. We hope this plan will go some way to speed up decision-making timelines and reduce the backlog of people waiting within the National Referral Mechanism – the UK’s system for identifying and supporting survivors.
However, a key question in this policy area was what the new Government would do about the previous Government’s immigration legislation, which had proposed removing support and protections for some potential victims of modern slavery. We had some answers on this last week, with the introduction of the Border Security, Asylum and Immigration Bill in Parliament.
This new Bill will repeal most of the Illegal Migration Act, an Act which could have resulted in potential victims who had arrived in the UK irregularly being denied support. It will also completely repeal the Safety of Rwanda Act, under which potential victims may have been removed from the UK to Rwanda.
Under the new Bill, measures to disqualify certain potential victims from support on ‘public order grounds’ will be retained. Analysis by the Modern Slavery PEC Research Fellow Dr Marija Jovanovic shows how it’s incompatible with the UK’s domestic and international human rights obligations and highlights ways this ‘Public Order Disqualification’ needs to be amended.
The Government has committed to “long term reform of the modern slavery system” to ensure “tailored and holistic support is available for victims”. It is likely that we will begin to see the foundations of this reform in 2025. Typically, government reform programmes involve elements such as consultations on policies, reviews of existing policies and possibly even piloting or testing new policy measures. The Home Office is already running pilots of a devolved decision-making model for children affected by modern slavery.
This year will also see further movement on the Home Office’s Support for Victims of Modern Slavery Programme which was set up to procure a successor contract to the current Modern Slavery Victim Care Contract for adults.
Prevention
As we set out in our Policy Priorities report, investment in preventing modern slavery will ultimately reduce the significant harms to individuals and communities, as well as reducing overall social and economic costs of modern slavery to the UK.
Our report highlighted how moving to a more prevention-centred strategic response requires integrating modern slavery prevention into the delivery of the Government’s wider Missions. Evidence shows that modern slavery is interconnected with a wide range of other policy areas – for example the design of certain work visas can increase vulnerability to modern slavery, and lack of support for children with special needs and disabilities can put them at higher risk of being exploited.
The Government is taking action in some of these areas, for example the Employment Rights Bill, currently going through Parliament, will establish a new Fair Work Agency to uphold workers’ rights. It is important this new Agency is appropriately resourced to enforce labour standards, and that there are secure reporting pathways for workers to report abuse. The Government also made a manifesto commitment to developing a new homelessness strategy and it’s important this identifies ways to reduce risks of exploitation for people who are homeless.
As our Policy Priorities report outlined, there is a need for an effective cross-Government collaboration mechanism, involving all relevant departments and agencies, to ensure that the response to modern slavery is fully joined-up.
We look forward to seeing how the Scottish Government approaches this challenge when it refreshes its Human Trafficking and Exploitation Strategy, expected this year.
Modern slavery in supply chains
Modern Slavery PEC evidence has shown that public procurement has huge potential as a lever to address modern slavery in supply chains. There is Government activity on this front, with a live public consultation (deadline 13th February 2025) on new regulations that will be implemented to address modern slavery risks in NHS procurement. In addition, the Procurement Act will go live in February 2025 and includes stronger measures to exclude government suppliers linked to modern slavery.
This year, the Home Office’s focus seems to be on improving the transparency in supply chains provisions in the Modern Slavery Act, in ways that do not require new primary legislation. For example, it is currently working to refresh the guidance for businesses on these laws, and to improve the currently voluntary online registry that houses businesses’ modern slavery statements. While these improvements are welcome, research and evidence have demonstrated that improving the effectiveness of these transparency measures would require new primary legislation. This would include introducing penalties for non-compliant businesses and extending the transparency reporting requirements to public sector organisations.
2025 will see ongoing Parliamentary interest - confirmed at our recent event in Parliament - in how the UK can go even further to address modern slavery in supply chains, especially given legislation in other countries in this area is increasingly overtaking the UK’s transparency laws. Modern Slavery PEC reports have explored evidence around the effectiveness of some of these measures such as mandatory human rights due diligence laws and we’ll soon be publishing an update of our report on effectiveness of forced labour import bans, authored by Dr Sofia de Aguinaga, a PEC Research Fellow at the Bingham Centre for the Rule of Law at BIICL. (You can already sign up to a lunchtime seminar on this subject).
Legal enforcement and criminal justice
There is a challenging backdrop for activity in 2025 in this policy area, including well-documented lengthy delays in criminal cases going to court, significant issues with capacity in the prison system, and concerns around the effectiveness of the use of the statutory defence for people who were forced to commit crimes by their traffickers.
Against this, the Minister for Safeguarding has stated that increasing prosecutions for modern slavery offences is a key priority for her. Prosecutions remain stubbornly low and there is a need for the Government to connect its aims on increasing prosecutions alongside improving support for survivors, given that evidence shows that co-operation and engagement from survivors is often critical for supporting prosecutions. There is also a need to address the barriers that survivors face when seeking compensation, including improved access to legal advice. The open consultation on civil legal aid (deadline 21 March 2025) offers an opportunity to comment on proposals being considered.
We also expect to see increased policy attention on child criminal exploitation, a form of modern slavery, in 2025. The Government committed in its manifesto to introducing a new criminal offence of child criminal exploitation. This commitment raises a number of complex legal and policy issues which we will explore in more detail in our forthcoming policy report. What we know is that there is a need to increase understanding of the scale and nature of this form of exploitation. To this end, we have recently announced a new project exploring child criminal exploitation in Northern Ireland.
Overall, the arrival of the new Government in 2024 saw a shift in tone and early action on modern slavery, and 2025 will be the year that we begin to see how this translates into concrete changes to laws and policy. At the Modern Slavery and Human Rights PEC, we’ll monitor those very closely and as always, will aim to provide evidence and analysis to meaningfully inform those changes.
