Section 4: Action Area 3 – Address the conditions that foster trafficking and exploitation
Action Area 3 focusses on addressing the conditions that allow trafficking to take place. Key issues for this group include public awareness of trafficking, the role of businesses and other communities in preventing trafficking, and addressing the wider conditions, including poverty and inequality, which make trafficking possible and profitable.
The Action Area 3 Implementation Group met for the first time on 15 August 2017 and meets on a quarterly basis. The group is chaired by the Scottish Government.
Membership of the group includes:
- The Scottish Government (human trafficking policy, procurement policy, homelessness policy, organised crime policy, equality policy)
- Police Scotland
- Gangmasters and Labour Abuse Authority ( GLAA)
- Independent Anti-Slavery Commissioner’s office
- Renfrewshire Council
- Stirling University Centre for
Child Wellbeing and Protection
- Brightwork Recruitment
- Hope for Justice
- International Justice Mission
Key outcome: people know about the extent of trafficking in Scotland
A fundamental challenge in addressing trafficking in Scotland is identifying where it is taking place. Trafficking can be a hidden crime, with perpetrators going to great lengths to keep it so. Victims of trafficking can only get the support they need if they come to the attention of those who are able to help them. The public have an important role in recognising the potential signs of trafficking and reporting any concerns appropriately, in order to help bring agents of trafficking to justice and get support to those who have been exploited.
In March 2017, during the development of the Trafficking and Exploitation Strategy, a public survey was conducted, with face-to-face interviews conducted in homes with 1,025 adults across Scotland. The survey asked a range of questions relating to public perceptions of what human trafficking is, whether it takes place in Scotland, and what people would do if they had a concern.
A key finding of this research was that while 63% of Scottish adults believe human trafficking is an issue to a great extent in the rest of the world (outside Europe), and 30% believe it is so in the UK, only 14% would say this of Scotland. Just 5% would say this of their local area.
Yet the evidence shows that human trafficking is taking place in local communities across Scotland.
A significant amount of activity has been undertaken by the Scottish Government and its partners over the last year with the aim of strengthening public awareness of what trafficking is, that it is happening in communities in Scotland and how to report any concerns.
The Scottish Government undertook a marketing campaign between August and October 2017. This included working with STV to produce a hard-hitting 60 second film which was screened during advert breaks over the course of the campaign. It also featured a series of six digital adverts which highlighted particular contexts where the public might encounter trafficking.
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Human trafficking marketing campaign
The Scottish Government funded a national awareness raising campaign which ran between August and October 2017. The key messages of the campaign were:
- Human trafficking is happening in Scotland
- You should report any concerns to the Modern Slavery Helpline, operated by Unseen.
The campaign included a 60-second film featuring Bronagh Andrew, Operations Manager of TARA, which was produced with and screened on STV during advert breaks, including during peak viewing times.
The campaign also included digital adverts placed on Facebook and other websites, with versions designed to capture attention on a mobile screen. These highlighted some of the key industries that can be affected: construction, takeaways, nail bars, and hand car washes.
The two-pronged approach was designed to reach a diverse audience, so that the message could be seen by all sectors of the Scottish public. Analysis showed that the television advert reached over two million people in Scotland, and the digital adverts also reached at least two million people.
The adverts directed people to the Modern Slavery Helpline, to learn more or report concerns, and both the helpline itself and the online portal saw significant increases in contacts during the campaign: from about 2 potential victims identified in Scotland per week up to about 10 per week during the campaign. Over weekends or time periods when the film was playing on television, multiple callers from Scotland specifically mentioned that they heard about the helpline from an advert/film on television.
All marketing campaign materials directed people to the UK-wide Modern Slavery Helpline (08000 121 700) for more information, or to report any concerns. A specific web-page giving information relevant to Scotland was developed for the Modern Slavery Helpline website and the digital adverts linked directly to this, providing an online route for reporting concerns.
Modern Slavery Helpline, operated by Unseen
The UK-wide Modern Slavery Helpline, is a 24-hour confidential free phone service for accessing advice and reporting concerns about human trafficking and exploitation across the whole of the UK. It is operated by the charity Unseen, with support from a range of partners including BT and Salesforce.
Through the Helpline potential victims, members of the public, businesses and statutory agencies can speak to fully trained call handlers to get information, advice and support, and report concerns about possible trafficking and exploitation.
The Modern Slavery Helpline website  also provides information and an online route for reporting concerns. This includes a page for Scotland-specific information. A new Modern Slavery Helpline smartphone app will be launched in the near future.
Police Scotland has developed a Memorandum of Understanding with the Modern Slavery Helpline, to assist in sharing information through Helpline referrals.
During the marketing campaign a significant increase was seen in the number of people from Scotland accessing the Modern Slavery Helpline, operated by Unseen, both through phone calls and web referrals. The number of potential victims identified went from about 2 per week before the campaign to around 10 per week during the campaign. This was a very positive result. However, after the end of the campaign, Scottish referrals through the Modern Slavery Helpline tailed off again.
In order to maintain momentum and help keep the key messages of the campaign – that trafficking is happening in Scotland and that members of the public should report any concerns appropriately – in the public eye, the Scottish Government established a joint communications group. This group includes Police Scotland, TARA, and Migrant Help. The aim of the group is to share upcoming opportunities and coordinate communications activity. Key successes for the group so far have included media coverage of increased funding to TARA and Migrant Help and the 90 day statutory support period, of the first convictions under the 2015 Act and the first use of Trafficking and Exploitation Prevention Orders, and of the increase in NRM referrals in Scotland for 2017.
The Scottish Government has worked with key partners to support research on trafficking in Scotland and the rest of the UK, including the Independent Anti-Slavery Commissioner’s report Combating Modern Slavery Experienced by Vietnamese Nationals En Route to, and within, the UK, and the UK Government publication A Typology of Modern Slavery Offences in the UK. A sub-group of the Action Area 3 Implementation Group has been established to consider what further research may be needed in Scotland.
Other activity to raise public awareness in Scotland has included: the joint Scottish launch of the Independent Anti-Slavery Commissioner’s 2017 Annual Report on Anti-Slavery Day (18 October), support for the UN House human trafficking conference on 23 March 2018, and a range of other engagements and presentations with different groups in Scotland.
One potential impact of activity to raise awareness during and following the Strategy’s launch can be seen in the significant increase in Scottish referrals to the National Referral Mechanism (see section 6). In 2017, 207 potential victims were identified and entered the NRM process, a 38% increase on the previous year. This suggests that we are getting better at noticing and reporting potential signs of trafficking, and helping to ensure trafficking victims are directed towards the help that they need.
A follow-up public survey  of 1,008 adults was undertaken in March 2018, asking the same questions as the previous survey, with some additional questions on media and marketing. This showed increases in awareness of trafficking taking place around the world and in Scotland, but no improvement in awareness of trafficking in local communities. There was a significant shift in what people said they would do if they suspected trafficking was taking place – more people said they would contact the police and fewer said they would talk to family or friends. One in four respondents said they had seen materials from the Scottish Government marketing campaign. Overall, these are positive results in terms of the key messages of awareness raising activity. However, there is clearly more work needed to raise awareness of trafficking in local communities. Further detail on the findings can be found in section 6.
Key outcome: people and businesses are aware of how what they do and buy can contribute to this crime
Human trafficking is a highly profitable criminal activity. The International Labour Organization has estimated that annual profits from the trafficking of human beings generates $150 billion around the world  . The corporate sector has an important role to play in tackling and preventing this crime and through the Strategy we aim to help businesses fulfil their legal and ethical obligations.
We have engaged directly with a number of key businesses that volunteered to take an active role in Scotland’s work on human trafficking. We have met with HSBC to discuss the role of the financial sector in identifying suspicious financial activity, and with Police Scotland helped deliver joint training to key HSBC staff on human trafficking. We have also worked closely with The Co-op, including delivering an awareness session for their Scotland suppliers forum.
HSBC Risk and Compliance Centre
In 2015, HSBC chose Edinburgh as the location for establishing a new UK centre for its Risk and Compliance teams in Edinburgh. Over the last year, HSBC has expanded its presence in Scotland, including significant development of the Edinburgh risk centre of excellence.
In that building, fifty per cent of the employees are directly involved in anti-money laundering activity designed to prevent the financial crimes that underpin human trafficking as well as arms trafficking and drug dealing. It is a hive of technological and human intelligence.
Alison McGregor, chief executive of HSBC in Scotland, is a prominent supporter of efforts to tackle human trafficking in Scotland and internationally, and HSBC is a member of the Scottish Government’s corporate group supporting Strategy implementation.
In November 2017, the Scottish Government held a corporate engagement event, bringing together representatives of a select group of business interests in relevant sectors, including large organisations and representative bodies covering smaller businesses. This event included input from Police Scotland, Gangmasters and Labour Abuse Authority, Border Force, Migrant Help, International Justice Mission, Brodies Solicitors and Staffline. The event was well received and helped make further links in the corporate sector.
Following on from the corporate engagement event, we have established a Corporate Group, to sit alongside the other implementation groups and take responsibility for moving forward specific elements of the Strategy. This group met for the first time on 27 March 2018, and will meet on a quarterly basis. The group includes membership from:
- The Co-op
- Brightworks Recruitment
- British Association of Beauty Therapy and Cosmetology ( BABTAC)
- Petrol Retailers Association
- Edinburgh Airport
- Scottish Trades Union Congress
- Scottish Business Resilience Centre
- Brodies Solicitors
- Hope for Justice
- Stronger Together
- International Justice Mission
The group has established sub-groups to look specifically at training and guidance for businesses, at Slavery and Human Trafficking Statements, and at spreading awareness and good practice.
Bright Future programme
The Co-op Bright Future programme offers the opportunity of a four week paid work placement leading to a non-competitive interview for a job in their food business to those who have been rescued from human trafficking. In February 2018, this programme was extended to Scotland, through a partnership with Migrant Help.
Frank (not his real name) was unemployed and living in Romania with his wife and young family. He was contacted by a childhood friend in November 2014, who put him in touch with a male who offered him employment and accommodation in the UK. Frank was happy to accept this opportunity as he needed work to support his family. About two weeks later he was sent a ticket for a flight to Glasgow and met at the airport by a male who took him to an address. Frank was told that it would cost him £75 per week for the bed space. Within weeks of arriving in the UK, Frank was forced, under the threat of violence to him and his family, to open bank accounts for a group to use. After this experience he tried to get out of the group’s control without success, so he decided to sell all his belongings in order to fund a deposit for a flat of his own with a reputable landlord. He changed his telephone number several times so the group could not contact him.
Frank contacted the police and agreed to enter the National Referral Mechanism. Migrant Help provided him with practical, emotional and moral support, as well as financial support as he struggled to take care of his family and had recently lost a job. Migrant Help informed Frank about an opportunity to join the Bright Future programme, and Frank volunteered to be the first participant in Scotland.
After completing the Bright Future placement, Frank was given an opportunity of non-competitive interview and secured his employment. He is happy with his job as it is very convenient for him. It is close to where he lives and flexible shift patterns allow him to spend time with his young family.
Businesses in Scotland must be clear that they are not profiting from trafficking, either knowingly or unknowingly. Larger companies may not be directly employing trafficked people, but it is possible that through contractors, sub-contractors, or agencies supplying labour, they may be making use of trafficked labour. Under Section 54 of the Modern Slavery Act 2015, all businesses in the UK (including Scotland) with a turnover of £36 million or more have to make available on a public platform a Slavery and Human Trafficking Statement. This can include detail on policies, training and due diligence, as well as setting out structure and supply chains and highlighting where there is a risk of human trafficking taking place. While many businesses in Scotland are fulfilling this obligation, not all are. Transparency in supply chains has been a key focus of engagement with business so far, and helping to highlight the legal requirement, and encouraging the publication of meaningful Slavery and Human Trafficking Statements, will remain a key focus for the Corporate Group.
It is also important that the public sector works to eliminate human trafficking in its supply chains. We have been working to spread awareness of human trafficking in public procurement. In October 2017, the Scottish Government and Stronger Together delivered an awareness raising session on human trafficking and transparency in supply chains at Procurex, the national annual procurement conference. More recently the Action Area 3 Implementation Group helped update the national sustainable procurement tool, to ensure that it takes account of human trafficking considerations. The tool will be shared with the Corporate Group.
Key outcome: people at most risk get help to increase their resilience against trafficking
As well as the wider awareness raising work, it is important to ensure that communities and sectors which are particularly at risk of trafficking are aware that they have a right not to be exploited or abused, and that they can access support and help to escape risky situations. This will include work to address the wider social factors that can enable and foster trafficking, including poverty, inequality and homelessness.
The 2017 marketing campaign was national in scope and was targeted to reach all sectors of the Scottish population, including those at risk of trafficking. The campaign materials were produced in consultation with trafficking victims, to ensure they reflected their voices and to help make the messages accessible to those at risk of trafficking. In addition, posters using the campaign imagery and leaflets on how to report concerns or access support have been printed in a range of languages, including Vietnamese, Romanian, Lithuanian, Polish and Bulgarian. These have been shared and distributed with the aim of raising awareness in affected communities.
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Victims of human trafficking are at significant risk of homelessness. Similarly, people who are homeless are potentially vulnerable to exploitation through promises of accommodation or employment. The Scottish Government has established the Homelessness and Rough Sleeping Action Group which has four main areas for action:
- How to minimise rough sleeping for winter 2017/18;
- How to eradicate rough sleeping;
- How to transform temporary accommodation; and
- How to end homelessness.
The group has met since October 2017 and has provided recommendations to the Scottish Government on the first two issues which have been accepted by the Scottish Government in principle. Some of the recommendations apply to people without recourse to public funds who, along with people at risk of sleeping rough, may be vulnerable to being exploited or abused.
Refugees and asylum seekers are at risk of victimisation by traffickers. The second New Scots refugee integration strategy was published in January 2018. It is led by a partnership between the Scottish Government, COSLA and the Scottish Refugee Council and involves a wide range of partners across different sectors. The Strategy was informed by an engagement process involving over 2,000 people, including over 700 refugees and asylum seekers.
The New Scots vision is for a welcoming Scotland where refugees and asylum seekers are able to rebuild their lives from the day they arrive, and the Strategy sees integration as a long-term, two-way process, involving positive change in both individuals and host communities, leading to cohesive, diverse communities. It recognises that refugees and asylum seekers may have been trafficked on their journey to Scotland and can be vulnerable to exploitation by traffickers and others as they seek safety.
Violence against women and gender inequality make women vulnerable to trafficking and exploitation. Equally Safe, Scotland’s strategy for preventing violence against women and girls, continues to be implemented. In November 2017, the Scottish Government and COSLA published a delivery plan containing 118 commitments across four priority areas. The Strategy and Delivery Plan focuses efforts on prevention, building the capability and capacity of services to respond effectively and ensuring an effective Justice response to supporting victims and tackling perpetrators. There is increased focus on commercial sexual exploitation, with a commitment to establish a multi-agency working group and look at improvements to services in this area.
Poverty is a key route cause of trafficking. Work continues to address child poverty in Scotland. On 29 March 2018, the Scottish Government published Every Child, Every Chance: The Tackling Child Poverty Delivery Plan 2018-22. This is the first of three delivery plans which will be published by the Scottish Government in order to meet the ambitious targets set out in the Child Poverty (Scotland) Act 2017. The Plan sets out a range of actions aimed at meeting the targets by increasing family incomes and reducing household costs. Key commitments include:
- An additional £12 million for parental employment support, helping parents to enter and progress in work; alongside launching Fair Start Scotland, the new devolved employment service;
- A new guaranteed minimum amount for School Clothing Grant, providing more money for school uniforms and sports kits;
- £1 million investment to provide help for children experiencing food insecurity during the school holidays;
- A commitment to introducing a new income supplement for low income families, and introducing the new Best Start Grant from summer 2019;
- Investing £2 million to expand the Children’s Neighbourhoods Scotland programme to improve a range of outcomes for children; and
- A new £7.5 million innovation fund with the Hunter Foundation.
The 17 UN Global Goals  (also known as the Sustainable Development Goals) were formally agreed by the UN at the Sustainable Development Summit in New York in September 2015, and came into effect in January 2016. Target 8.7 is to “Take immediate and effective measures to eradicate forced labour, end modern slavery and human trafficking and secure the prohibition and elimination of the worst forms of child labour”. Global Goal 16 is to “Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels”.
The First Minister committed Scotland to the Global Goals in July 2015. An internal mapping exercise was carried out, aligning the Global Goals with the National Performance Framework and Scotland’s National Action Plan ( SNAP) on Human Rights. Many of the Goals align with work already underway internationally through the International Development Fund and Climate Justice Fund, and domestically, to tackle poverty and inequality, through Scotland’s National Performance Framework and SNAP. The Global Goals are being implemented in Scotland via the mechanism of the National Performance Framework. The Scottish Government has recently completed extensive public engagement exercises on the National Outcomes, the content of which will be used to shape the refreshed National Outcomes.
In August 2017, the Minister for Public Health and Sport endorsed the Pontifical Academy of Sciences Statement on eliminating trafficking for organ donation, and following this awareness raising activity was undertaken with nephrologists and transplant surgeons to help prevent Scotland being targeted for this type of trafficking.
Now that the Corporate Group has been established, it will take an active role in moving towards the outcomes in the Strategy, with a particular focus on:
- Analysis of Slavery and Human Trafficking Statements published by Scottish businesses and how we can improve uptake and quality;
- Joining up existing research activity in Scotland;
- Pulling together the training and guidance currently available to businesses and considering whether there is a need for standard guidance or a Code of Practice for businesses; and
- Building on existing networks and finding new ways to share good practice and increase awareness in the corporate sector.
Public awareness raising activity will continue, with the joint communications group coordinating opportunities and approaches. A key focus will be on Anti-Slavery Day, 18 October 2018, with a series of events planned in the run up to this.
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