Trafficking and Exploitation Strategy: fifth progress report

Section 2: Action Area 2 – Identify perpetrators and disrupt their activity

Action Area 2 focuses on the identification of perpetrators of human trafficking and exploitation, with the intention of disrupting their criminal activity. Action Area 2 is chaired by Police Scotland.

Membership of the strategic partners group includes:

• UK Border Force
• British Transport Police (BTP)
• Convention of Scottish Local Authorities (COSLA)
• Crown Office Procurator Fiscal Service (COPFS)
• Gangmasters and Labour Abuse Authority (GLAA)
• Glasgow City Council Health and Social Care Partnership
• Her Majesty’s Revenue and Customs (HMRC)
• Home Office Immigration Enforcement (HOIE)
• Maritime and Coastguard Agency
• Justice and Care
• Migrant Help
• National Crime Agency (NCA)
• Police Scotland
• Scottish Business Resilience Centre
• Scottish Government
• Scottish Prison Service (SPS)
• Trafficking Awareness Raising Alliance (TARA)
• Survivors of Trafficking in Scotland (SOHTIS).

The group continues to meet on a quarterly basis, adopting a partnership approach to ensure that all member agencies feel free to share information on current trends and any enforcement action taken by their respective organisation. The group is action driven, ensuring a degree of consistency across the country, in terms of strategic direction for enforcement agencies, third sector bodies and support organisations.

Police Scotland’s Tactical Group (including BTP) is made up of the National Human Trafficking Unit (NHTU), Divisional Human Trafficking Champions from enforcement agencies (including Ports and Borders), Organised Crime and Counter-Terrorism Unit and the Senior Investigating Officers of large-scale human trafficking investigations. They lead investigations, raise awareness of Human Trafficking and Exploitation and develop local partnership working. They are supported through specialist training and interactive forums, to ensure a robust and consistent national approach. The tactical group advise the Strategic Group on current trends and enforcement action.

Action Area 2 – fourth progress report

The fourth progress report set out a number of priorities for Action Area 2, including:

• developing further use of Trafficking and Exploitation Prevention and Risk Orders
• progressing ways of working with international law enforcement and third sector partners
• improving victim engagement
• advancing Police Scotland’s Partners’ Intelligence Portal.

More information on these topics can be found within this chapter.

Key outcome: Public bodies and others report concerns appropriately

Police Scotland has recognised Trafficking and Exploitation as a policing priority in the Annual Policing Plan 2023-202413.

The NHTU are based within the Public Protection Command of the Specialist Crime Division of Police Scotland, located at the Scottish Crime Campus. The unit encompasses three distinct areas: Investigations Team; Intelligence Development Team; and the Coordination, Partnerships and Policy Unit.

The remit of the NHTU includes:

• undertaking large-scale and complex human trafficking investigations
• reporting human trafficking cases to COPFS and to international prosecutors as appropriate
• developing intelligence into actionable investigations
• developing and delivering training and guidance to promote national consistency in approach
• developing and cultivating partnership working with national and international law enforcement, statutory and third sector partners.

The NHTU are part of the Scottish Crime Campus law enforcement community, facilitating collaboration with both internal Police partners and crucially, other agencies including COPFS, HMRC, the National Crime Agency and the Home Office.

Work is ongoing between Police Scotland and the Scottish Government in consideration of the practical implementation of the Duty to Notify (DTN) process in Scotland, which fulfils the objectives outlined in Section 38 of the Human Trafficking and Exploitation (Scotland) Act 2015. DTNs are currently received by Police Scotland on a voluntary basis from agencies such as Border Force, who use DTN in their work in England and Wales.

Police Scotland continued to deliver training to law enforcement officers and partners on human trafficking legislation, ongoing and historical investigations, patterns and trends, recognising the signs and how to report concerns around human trafficking and exploitation.

All frontline Police Officers, up to the rank of Inspector, are required to complete an online human trafficking training course. To date around 82% (around 13,500 officers) have successfully completed this training.

In addition, specialist training was delivered to 72 Human Trafficking Investigators at the Scottish Police College in 2023-2024. The training involves a one-week intensive, assessable training course, where a number of internal specialist officers and external organisations provide inputs to candidates. The candidates are then examined in two practical exercises to assess their operational knowledge, skills and competence. Upon successful completion, those investigators from across local and national policing divisions in Scotland will, in turn, support local officers in conducting human trafficking investigations.

Human trafficking training modules have been delivered during specialist training courses to newly promoted officers, Sexual Offences Liaison Officers, Joint Investigative Interview, Ports Procedure, Advanced Investigators and Senior Investigating Officers. Over 300 officers received this training in 2023-2024.

Over 60 Police Scotland Human Trafficking Champions received training and guidance on human trafficking legislation, policy and procedure, ongoing investigations and current trends.

NHTU delivered six human trafficking training inputs to over 100 delegates from external partners, including Scottish Prison Service, Dungavel Removal Centre, Border Force and other law enforcement bodies. The inputs were tailored for each group and included legislation, the human trafficking context in Scotland, recognising the signs of human trafficking, supporting victims, exploitation in supply chains and how to report concerns.

Victim Navigators have provided strategic advice to 63 additional human trafficking investigations. These include deployments with police across the country to conduct welfare checks and follow up on reports of exploitation within factories, hospitality, agriculture and brothels. Navigator input has included influencing victim approaches, advising on safeguarding and support options available to potential victims, including use of the NRM, providing advice on cultural context, and helping to identify locations of interest. Navigators provided information and guidance to police officers on use of the new NRM prompt sheet, supporting officers in gathering the correct information in order to improve NRM submissions for victims of human trafficking.

Victim Navigators have worked on rolling multi-agency operations involving Police Scotland, Border Force, His Majesty’s Revenue & Customs and Home Office Immigration Enforcement, providing expert advice on victim identification and approach. Navigators have also assisted Border Force at Glasgow Airport with intensification exercises for Operation Aidant14, coordinated by the National Crime Agency (NCA). This operation is run across the UK each year and involves local police forces working alongside partner agencies to focus on vulnerability, exploitation and modern slavery.

Specific examples of strategic advice have included:

• assisting Border Force at Glasgow Airport to provide potentially vulnerable students and skilled workers arriving in the UK with information around labour and financial exploitation
• Victim Navigators provided strategic advice and support in relation to a day of action aimed at identifying cases of labour exploitation within the fishing industry, after police were alerted by a victim that he was not being paid nor given enough food and was being subjected to physical threats and assaults by his exploiters. Navigators were consulted and involved from an early stage of planning for this operation, providing advice on how to approach and engage with the victims in this case, including cultural advice, liaising with relevant Home Office contacts and additional external stakeholders, and making arrangements for reception centres for potential victims. In May 2024, this led to the identification and removal from exploitation of four Ghanian fishermen who were being subjected to labour exploitation. The Navigators supported three of the victims into new employment and one is currently volunteering, increasing their confidence and reducing their vulnerability to future exploitation
• during several other deployments with police in response to intelligence and Modern Slavery and Exploitation Helpline15 referrals, no indicators of exploitation were found but Navigators were able to provide advice and information to those present on their rights and how to protect themselves, to safeguard them from vulnerability to exploitation in the future.

The GLAA has continued to deliver support and training to a wide range of organisations focused on increasing awareness of human trafficking across Scotland. Awareness raising sessions have been delivered to various organisations including British Transport Police, Border Force, Marine Scotland and UK Visas & Immigration alongside tailored inputs provided to officers from Police Scotland.

They have worked closely with Justice and Care and, in addition to having their own embedded Victim Navigator to ensure that all potential victims GLAA encounter are offered support and advice, they have delivered joint presentations on human trafficking awareness to partner agencies.

Collaboration has taken place in the operation of reception centres to triage potential victims of trafficking and GLAA have participated in operations at Glasgow Airport, alongside Border Force, designed to engage with students and workers entering the UK by providing advice and signposting them to assistance available with a view to preventing them from being exploited.

The GLAA have worked with partners from the Seasonal Agricultural Workers Scheme to compile an educational video16 aimed at informing potential workers of what to expect when they come to work in an agricultural setting. The video is used to prepare workers for the conditions and types of work they may be engaged in and to advise them of their rights regarding pay, hours of work and accommodation with a view to reducing potential exploitation in these areas.

Partnership working with the Scottish Government, Hope for Justice, Scotland Against Modern Slavery (SAMS) and SOHTIS and, using the knowledge the GLAA have gained in their work, they have assisted in the creation, review and updating of strategic responses to tackling human trafficking in Scotland.

Key outcome: Intelligence is shared so that local areas and/or other countries are aware of patterns

The former Chief Constable of Police Scotland, in partnership with the Santa Marta Group, held a summit on Thursday 15th June 2023 at the Scottish Crime Campus, Gartcosh. The conference brought together political leaders, faith leads, third sector partners and various Chief Constables in a bid to raise awareness to eradicate human trafficking/modern slavery. The summit was a huge success, with discussions taking place around developing moral leadership and refocusing energy on combatting human trafficking as a serious organised crime. During the conference, consensus was reached around the need to make a clear distinction between human trafficking and immigration issues. These discussions contributed towards the key priorities set out in the Santa Marta Group’s Strategic Plan 2023-2026+17.

On a local level, Police Scotland have long-standing intelligence sharing practices, allowing for efficient and effective information dissemination and allocation. The National Human Trafficking Intelligence Unit maintain a national and strategic oversight of all intelligence received relating to trafficking and exploitation. This is assessed and disseminated accordingly to local officers for consideration of safeguarding and/or enforcement activity. The Intelligence Unit also produce quarterly strategic reports, informing Senior Leadership Teams of emerging trends, patterns and areas of vulnerability and risk.

Despite the challenges of operating in a post-Brexit environment, Police Scotland continue to maintain strong links with Europol, the European Union law enforcement intelligence agency. The UK Liaison Bureau within Europol is a multi-agency unit consisting of a number of officers and staff from UK law enforcement agencies, including Police Scotland. Through these established links, information and intelligence sharing takes place on a daily basis between Police Scotland and EU member states, allowing analytical oversight at Europol to identify links, crossovers and vulnerability across borders.

Police Scotland continue to strengthen EU relations, participating in Joint Investigation Teams (JITs) to investigate and prosecute large scale human trafficking operations. A number of JIT’s have been established with the NHTU and other EU member states, including Romania and Hungary. These JITs enable law enforcement in different countries to share intelligence and evidential material in real-time in order to effectively investigate perpetrators of trafficking and exploitation. COPFS are involved in this process and work collaboratively in these arrangements.

Police Scotland participated in Operation Limelight, a multi-agency safeguarding operation which has been running since 2013, taking place at the UK border, that focuses on harmful practices such as Female Genital Mutilation, Forced Marriage and other forms of “honour”-based abuse. Police Scotland Officers worked alongside Border Force and Edinburgh Airport staff to assist in the safeguarding of vulnerable persons and target and disrupt persons engaged in criminality at their expense. The main aim of this approach was to maximise opportunities for information sharing between agencies when assessing potential victims of human trafficking. Operation Limelight remains a national operation delivered by Police and Border Force, also including health and third sector organisations who specialise in responding to harmful practices.

The NHTU forms part of the UK Modern Slavery & Organised Immigration Crime (MSOIC) programme, which focuses on intelligence sharing and directed activity tackling and disrupting crime groups responsible for Organised Immigration Crime (OIC).

Police Scotland’s National Serious Organised Crime Interventions Unit is progressing multi-agency work around early identification of unused/derelict commercial properties, following the observation of a crime trend whereby such buildings were being utilised for cannabis cultivations. Local Authorities are mapping these premises by examining business rates. Through the Freedom of Information Act, Police Scotland and other partners will cross-refer these buildings with current intelligence and use available enforcement powers where necessary. Work is in its early stages involving key partners, including Home Office Immigration Enforcement, to develop processes adapted from the Yorkshire and Humber area and apply the principles to Scotland.

Police Scotland were granted funding from Home Office for the secondment of two Romanian Police Officers, commencing March 2024 and concluding in July 2024. The officers worked closely with Border Force at Glasgow Airport on a weekly basis covering flights from Romania and Hungary. They also assisted the NHTU with ongoing operations involving Romanian nationals, attending incidents and speaking with both perpetrators and victims. In addition, the Romanian officers have assisted several divisions, including Edinburgh and the Scottish Borders, by attending suspected brothels and saunas, assisting with initial translation and providing cultural background information.

The seconded officers delivered continuous professional development inputs around the country, including travelling to Aberdeen with representatives from Border Policing to speak with front-line officers. They also attended Police Scotland’s Human Trafficking Investigators course, where they delivered an input on Romanian culture and reasons for clandestine travel to the UK.

This secondment has proven to be extremely worthwhile, informing Police Scotland’s understanding of Romanian culture and the associated trafficking and exploitation issues in Scotland, as well as strengthening our working relationship with the Romanian authorities.

The GLAA continue to receive a steady flow of referrals either through the Modern Slavery and Exploitation Helpline or directly to their own reporting desk. The GLAA also regularly receive disseminations of intelligence from partner agencies and reports of exploitation from other associated groups.

As a result of these reports, GLAA have led on or assisted with several multi-agency operations, identifying cases of exploitation and taken necessary measures to ensure that those responsible are brought to justice.

They have undertaken joint safeguarding visits with Police Scotland to various large businesses across Scotland and carried out inspections looking at working conditions, terms of employment and accommodation to ensure that workers are afforded statutory entitlements and are made aware of how to challenge discrepancies.

Alongside UK Visas & Immigration, GLAA have carried out visits to various farms, undertaken site inspections and interviewed workers who were employed under the Seasonal Agricultural Workers Scheme (SAWS). The GLAA have taken steps to ensure not only that workers are protected during the period of their employment in Scotland, but also that they were not exploited during the recruitment process by, for example, paying work finding fees. Where issues have been found GLAA have taken enforcement action on those responsible, utilising the full range of their powers, such as issuing Warning Notices and Labour Market Enforcement Undertakings, through to revoking the licences and undertaking prosecution action as appropriate.

The GLAA have worked with Local Authorities, Safer Communities Teams, Police, Fire and Rescue and others to identify and address exploitation. They have inspected accommodation and taken active steps to ensure that landlords are held accountable for ensuring the houses they provide are of a safe and habitable standard and have challenged those who have fallen short of this.

Key outcome: Police, Prosecutors and courts use all powers and take robust action as appropriate

Data for 2023-2024 reflects the highest number of incidents of human trafficking and exploitation reported via the National Referral Mechanism (NRM) to Police Scotland since its inception in 2013. All other trafficking and exploitation recording mechanisms used by Police Scotland, including Modern Slavery and Exploitation Helpline Referrals, voluntary Duty to Notify Referrals and recorded calls have also shown increases.

Calls to Police Scotland relating to immigration matters are similarly at their highest recorded levels. Complex global geopolitical and socioeconomic conditions have added significantly to the number of migrants encountered by, or presenting to, Police Scotland. Police Scotland work locally and nationally with partners including Home Office, Local Authorities and third sector partners to safeguard those deemed to be vulnerable to exploitation.

Within the data, there has been a significant increase in victims reporting exploitation which has taken place out with the UK, mostly in relation to labour exploitation. There has also been an increase in the number of people found in situations of forced criminality within the UK; however, 2023/2024 saw a reduction in identified exploitation within service industries, such as nail bars.

Vietnamese nationals continue to be the largest nationality group entering the NRM in Scotland, with 2023-2024 seeing a significant increase on previous reporting periods. Police Scotland are working closely with partners to better understand the reasons behind this in order to develop a strategic, multi-agency approach to target the issue. Partners include representatives from Migrant Help, TARA, SOHTIS, Scottish Government, Guardianship Scotland and others. In addition, an intelligence group has been set up to discuss better ways of sharing information between partners in relation to the experiences of Vietnamese victims of trafficking.

In order to better mitigate the threat, risk and harm posed to victims of human trafficking, Police Scotland’s response included:

• roll-out of the Partner’s Intelligence Portal to relevant partners for the purpose of gathering intelligence relating to human trafficking and exploitation. The portal is a secure and confidential means of passing information and intelligence to Police Scotland
• quarterly distribution of AA2 partners’ briefing to share information with relevant AA2 partners
• quarterly distribution of Human Trafficking Champions Briefing to improve information sharing, highlight best practice and emerging threats
• regular liaison with support services including TARA, Migrant Help, SOHTIS, International Justice Mission and Justice and Care, to utilise their expertise and involvement with victims of trafficking within the NRM and Criminal Justice process
• foundation-level and specialist training to Police Officers and external agencies to raise awareness of human trafficking and improve the conduct and progression of investigations
• Operation ENCOUNTER – daily assessment by dedicated Intelligence Officers of intelligence submitted via the Scottish Intelligence Database and Partner’s Intelligence Portal
• two Victim Navigators, employed by Justice and Care and funded by the Scottish Government until 2025, are embedded in the National Human Trafficking Unit to provide additional support nationally to victims involved in the criminal justice process
• Operation MARRON – formed to improve the national intelligence picture and assessment of the impact of “County Lines” in Scotland. County Line gangs groom and exploit the most vulnerable people in our communities, including children and young people, to store and sell drugs
• working closely with the Convention of Scottish Local Authorities (COSLA) to encourage their members to consider licensing arrangements in respect of nail bars
• building and strengthening our engagement and relationships with the international law enforcement community and international statutory and third sector partners
• continuing to participate in existing and new Joint Investigation Teams (JITs) with international law enforcement officers, currently including Hungary and Romania.

Police Scotland continue to embed the European Court of Human Rights VCL and AN 202118 Ruling into their daily business. The ruling has seen increased understanding and recognition of the circumstances whereby those who have committed a criminal act may have done so as a result of being a victim of trafficking and has placed an onus on police to carry out early and thorough investigations into such circumstances.

Where vulnerable children and adults are encountered in Scotland and are considered to have been trafficked or subject to exploitation, regardless of nationality or country where the trafficking has taken place, an Interagency Referral Discussion (IRD) will be initiated, where safeguarding and their individual needs are prioritised. This includes due diligence enquiries with other relevant agencies including health and education and other professionals where appropriate, to assess their needs and ensure that those needs are at the heart of the decision-making process. These processes are embedded in the Child and Vulnerable Adult Support and Protection Frameworks in Scotland.

Police Scotland are committed to the early identification of those trafficked for sexual exploitation in prostitution. Guidance is issued to Contact, Command and Control call-takers, who regularly receive calls from members of the public reporting suspected human trafficking activity including brothel keeping. These types of calls are treated as a priority, requiring a prompt policing response and investigation where required. In addition, a programme of in-person training is being delivered by NHTU Officers to Border Policing Command Officers at air and seaports, which includes indicators of trafficking, investigative tools, reporting and available support mechanisms.

NHTU take ownership of investigations involving the highest-harm Organised Crime Groups who seek to exploit vulnerable female victims of trafficking into prostitution. In line with the Scottish Government’s strategic approach to challenging demand for prostitution, and Police Scotland’s commitment to eradicating Violence Against Women and Girls, these investigations seek to target the facilitators of this type of human trafficking, and overall challenge men’s demand for purchasing sex.

Work is ongoing with the Scottish Government to devise an appropriate process to reach female victims of trafficking with precarious immigration status and prevent this from acting as a barrier to seeking help and support.

Police Scotland continue to pro-actively target County Lines. There has been a significant increase in awareness raising around the exploitation of children and vulnerable adults by serious and organised crime groups across the UK in furtherance of their drug-dealing activity. This awareness raising has taken the form of briefings and training inputs to front line officers, as well as the monthly publication of intelligence snapshot summaries, which are circulated to Divisional County Lines Champions. In addition, the NHTU provide updates to the County Lines (Operation MARRON) meetings held across Police Scotland and the County Lines Coordinators and Analysts assess and manage all intelligence related to County Lines to ensure a proactive and appropriate policing response.

Police Scotland developed and carried out investigations into a number of complex human trafficking cases throughout the reporting period. The nature of these investigations has necessitated multi-agency partnership working with national enforcement bodies, including the Department of Work and Pensions (DWP), GLAA, Home Office Criminal Financial Investigations, the Maritime and Coastguard Agency and the Scottish Minimum Wage Team.

Police Scotland have made use of Trafficking and Exploitation Prevention Orders (TEPO) and Trafficking and Exploitation Risk Orders (TERO) to mitigate the risk of offending and reoffending. The first TERO was granted on 28 July 2022 at Dumfries Sheriff Court. The TERO was granted in relation to a UK national suspected of labour exploitation of foreign nationals in the fishing industry.

Between 1 April 2021 and 31 October 2024, 68 cases were reported to COPFS which included charges in terms of the 2015 Act.

In 31 of those 68 cases, prosecutors have taken action in relation to charges in terms of the 2015 Act. (Action has been taken in respect of other charges in 13 cases. In addition, 10 cases contained charges that were marked as No Action and 16 are still awaiting a marking decision.)

• in 6 cases, the accused person(s) were not convicted of a charge in terms of the 2015 Act
• in 4 cases, the accused person(s) were convicted of a charge in terms of the 2015 Act
• 14 cases contain charges where no decision has yet been made in respect of a charge in terms of the 2015 Act
• 22 cases contain charges which have been marked for prosecution and are currently ongoing in respect of a charge in terms of the 2015 Act.