Trafficking and Exploitation Strategy 2025: partial business and regulatory impact assessment

Section 2: Engagement and information gathering

Engagement approach

The Strategy has been developed through collaboration with key stakeholders. A broad range of engagement forums has shaped the work—from statutory agencies and local authorities to specialist third sector organisations, survivor networks, and industry representatives. While the Delivery Plan for the Strategy is being developed we plan to engage with business and economy stakeholders to in shaping the final BRIA, mapping out the interest the business sector has in preventing trafficking and exploitation in its supply chains.

Internal SG engagement/engagement with wider Public Sector

Engagement internally has involved a range of key Policy areas. Including, but not limited to, Serious and Organised Crime, Violence against Women and Girls, Child Protection, and Health and Social Care. COSLA, Police Scotland, and NHS Scotland have been key partners as well as wider organisations such as the Crown Office and Procurator Fiscal Service, who have contributed through working groups and direct engagement. When considering the revised strategy, policy areas with mutual interests and strong alignment, including in the business policy areas, have been included and they will continue to be engaged as it is implemented. During the implementation of the Strategy we plan to further engage with Scottish Government policy groups for the sectors which have elevated vulnerability to trafficking and exploitation, such as fisheries, construction, social care and hospitality amongst others.

We have not yet engaged with the Regulatory Review Group nor with DITI as no new regulations were made and investment interests are unaffected by the Strategy.

UK/Devolved Administrations

The Scottish Government has worked regularly with the UK Government and other Devolved Administrations. The Scottish Government is a member of the Modern Slavery Engagement Forum, hosted by the Home Office. Recently we have also contributed to the Forced Labour Forum which has led to refreshed Statutory Guidance about responsibilities under Section 54 of the Modern Slavery Act^[2]. This has supported policy development, facilitated cross-border understanding, and enabled joint working.

Wider Public Sector

We have engaged with COSLA who also form part of our Action Area groups and therefore have regular information exchange and awareness of developments in relation to trafficking and exploitation. We have not engaged with other regulatory bodies nor with enterprise agencies as this was deemed unnecessary.

International

We have not yet engaged with government organisations in other countries of which the trade with Scotland may be affected by the policy proposals, or with policy makers in foreign governments who are planning or may have implemented similar regulations but plan to do so going forward. Encouraging transparency in supply chains from production to sale and address risks identified is relevant for the implementation of the Strategy, particularly for Scottish businesses who wish to trade in countries where there are higher instances of labour exploitation. Considerations of this will be taken forward on this as part of the delivery plan development.

Business/Third Sector engagement

For the partial BRIA we have not yet engaged directly with business representatives but plan to do so as part of the Strategy implementation. We have engaged with Scotland Against Modern Slavery^[3] which is represented within our Action Area implementation structure and exists to help eradicate human trafficking and raise awareness across the Scottish business community of this evil trade.

Public consultation

In September 2023 we published a review^[4] of the existing Trafficking and Exploitation Strategy, published in 2017, following extensive engagement with stakeholders including survivors of trafficking, third sector organisations, service providers, COSLA, Public Health Scotland, the Independent Anti-Slavery Commissioner, academics and researchers, Police Scotland and other law enforcement organisations.

The review concluded that some specific areas required attention, such as the requirement for a more strategic approach to awareness raising and training opportunities; a greater emphasis on evidence, data collection and sharing and an increased focus on prevention. Stakeholders also remarked that a number of the overarching objectives within the Strategy remain core aspirations and continue to provide important guidance. As such, a new Strategy would improve the interconnectedness of work under each Action Area, improving the flow of information sharing, cross-group working and learning.

A number of the goals within the Strategy, as set in 2017, were considered to be no longer relevant, either as a result of progress or as a result of evolving priorities. As such, it was concluded that the Key Performance Indicators warranted a refresh to bring them in line with policy and operational developments.

From the extensive engagement undertaken, it was clear that stakeholders’ unanimous view was that a refresh of the Strategy should be prioritised and this would allow us to reflect the changing landscape and evolving workstreams in our attempts to combat human trafficking.

We then embarked on a consultation process, involving in-person workshops, online discussions and written feedback on draft versions of the Strategy with our stakeholders, culminating in the final version of the Strategy.

Other stakeholders and actions

The Strategy is also informed by a series of evidence reviews carried out by the Scottish Government’s Justice Analytical Services (JAS), exploring current understanding of prevention strategies and interventions in relation to human trafficking and exploitation in the United Kingdom (UK) and other existing forms of research and evidence.