Trafficking and exploitation strategy: second annual progress report

Report setting out progress implementing the trafficking and exploitation strategy in 2018 to 2019.

Section 3
Action Area 3 – Address The Conditions That Foster Trafficking And Exploitation

Implementation Structures

Action Area 3 focuses 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 meets on a quarterly basis. The group is chaired by the Scottish Government.

Membership of the group includes:

  • Scottish Government (human trafficking policy, procurement policy, homelessness policy, organised crime policy, equality policy)
  • Police Scotland
  • Gangmasters and Labour Abuse Authority
  • Independent Anti-Slavery Commissioner’s office
  • Renfrewshire Council
  • Stirling University Centre for Child Wellbeing and Protection
  • Brightwork Recruitment
  • Hope for Justice
  • International Justice Mission (IJM)

Looking Back

The first annual progress report identified four different strands of work that Action Area 3 would continue to deliver and take forward during 2018/19, further detail of which can be found in this chapter. These include:

  • 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.

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 traffickers to justice and get support to those who have been exploited.

The Scottish Government commissioned a further public survey in 2019 asking 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. The first survey was carried out in 2017 just before the Strategy was published. In 2018 additional questions were added to the survey about media and marketing and in 2019 there were further questions about consumer attitudes. The 2018 survey 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 which ran between August and October 2017. 

The 2019 survey showed that respondents see human trafficking as less of an issue closer to home. There was a decline from 16% in 2018 to 13% in 2019 in those who felt human trafficking was an issue in Scotland. However the significant increases between 2017 and 2018 in the proportion who state that human trafficking is an issue ‘to a great extent’ in Europe and the rest of the world have been sustained in 2019 suggesting that people believe it is a significant issue, albeit at a distance. As in previous years those in the West of Scotland are significantly more likely to think human trafficking is an issue ‘to a great extent’ in Scotland. When asked what respondents would do if they suspected someone had been trafficked or exploited, 83% said they would report it to the police. 

Of the new questions on consumer attitudes, the first was to gain a better understanding of consumer attitudes and awareness of trafficking and exploitation in supply chains. Whilst 4% of respondents claimed high levels of awareness, 58% admitted low levels of awareness. Just over a quarter (26%) claimed moderate or varied awareness levels. Those under 25 were least likely to claim high awareness (1%), whilst moderate awareness was highest amongst those aged 35-54 (31%). A further question on whether awareness of human trafficking and exploitation influenced respondents choices when purchasing goods and services in Scotland saw a split of opinion; 44% said it did while 44% claimed it never influenced their choices. 

"I feel comfortable and relaxed coming here and knowing someone is helping me with my mental health following my bad experiences. They give me good advice and I feel listened to, and safe. The Anchor feels different to other services that I go to, I am always welcomed here.”

The following are high-level numbers recorded by the Modern Slavery Helpline for 2018 regarding cases of exploitation reported to be occurring within Scotland.

In 2018, 183 contacts were received (calls, webforms, app submissions). This is an increase of 41% compared to the contacts reported in the Helpline’s 2017 Annual Assessment.

In 2018, the Helpline received reports of 58 exploitation cases, indicating 254 potential victims reported to have been exploited in Scotland, which is a 10% increase in potential victims indicated as compared to the Helpline’s 2017 Annual Assessment.

In response to information received, the Helpline made 61 referrals in 2018 to local authorities and Police Scotland on all case types. Of the referrals passed to police, 45 regarded cases of reported exploitation.

Joining up research activity was one of the areas that the Action Area 3 Group identified as a priority for 2018. The Scottish Government convened a meeting of academics, government officials and analysts, NGOs and post-graduate students for initial conversations to identify gaps and what any research carried out should focus on.

The Consortium of Anti-Trafficking Research in Scotland (CATRiS) was officially created at the University of St Andrews in November 2018. CATRiS sits under the umbrella of the Third Generation Project, a University of St Andrews think tank dedicated to community-oriented collaboration, research, and advocacy within the field of human rights. The newly established steering group has brought together senior academics from St Andrews, Edinburgh, Dundee and Stirling universities. CATRiS hopes to contribute to addressing a perceived research-policy-practice gap in Scotland. Its main aims include:

  • Bringing together key research stakeholders in anti-trafficking to identify opportunities for collaboration and knowledge transfer, exploring shared pathways and experience, and 
  • Focusing on survivor-led, survivor-informed and practitioner experience research, foregrounding the voices and knowledge of those with first-hand experience of trafficking and its long-term implications. 

Initial boundaries of scope direct that membership will include:

  • Where research is being conducted in Scotland; and 
  • Where research is being conducted elsewhere but where there is a potential application or learning outcome for Scotland.

In May 2019 the Scottish Government hosted the first national CATRiS workshop bringing together around 70 researchers. With such a broad scope, the focus of the day was to explore the parameters and collaborative possibilities of all those contributing to research in Scotland. 

Over the past year the Scottish Government and partners have met with a wide variety of stakeholders, organisations and other interested parties to raise awareness about the extent of trafficking in Scotland. The Scottish Government has delivered presentations and participated in events arranged by the following:

  • The Royal College of Midwifery 
  • Criminal Justice Social Work 
  • Scottish Community Safety Network
  • Moray Chamber of Commerce
  • KOM and MIGMA (Norwegian bodies involved in tackling human trafficking) and the University of Oslo
  • Police Scotland 
  • Holyrood Magazine 

Other activity to raise public awareness in Scotland has included a joint event with COSLA on Anti-Slavery Day (18 October) as mentioned in the chapter relating to Action Area 1. The programme included presentations on an Anti-Slavery Partnership Toolkit by Alison Gardner, Nottingham University and Vicky Brotherton, IASC Office; regional partnerships by Hannah Flint, Stop the Traffick/Modern Slavery Co-ordination Unit, Greater Manchester Police; and Research by Dr Paul Rigby, University of Stirling and Dr Chris Lusk, University of St Andrews.

A bespoke newsletter was published on Anti-Slavery Day highlighting good practice across Scotland from a business perspective. The newsletter focused on work that Brightwork Recruitment, Multiplex and Edinburgh Airport are doing to raise awareness amongst front line workers of human trafficking and exploitation and what signs and indicators to look out for. 

The Rah Rah Community Theatre Company brought its production of ‘My Mind Is Free’ by Sam Hall to Scotland to mark Anti-Slavery Day, through funding from the Scottish Government in partnership with Migrant Help, The Salvation Army, Hope for Justice, Action of Churches Together in Scotland and Justice and Peace Scotland. This powerful depiction of the impact of human trafficking on victims toured Scotland in October 2018. Venues included a number of Universities, Churches, Dundee Rep, Aberdeen Arts Centre and Carnegie Hall. 

A key aim for the Scottish Government is to increase awareness that human trafficking and exploitation occurs in local communities across the whole of Scotland. The Scottish Government recognises that it cannot achieve this aim working in isolation and welcomes the work of others such as Hope for Justice[7] and IJM[8] to raise awareness of the issue amongst a wide range of audiences, groups and organisations. 

Hope for Justice, through its Training and Development Officer, has delivered training sessions to Housing Associations, community-based charities such as the Cyrenians, Glasgow City Mission and the Trussell Trust Foodbanks. The support of Third Sector Interface organisations such as Kilmarnock Voluntary Action, Dundee Voluntary Action, Lanarkshire, South Lanarkshire and Clackmannanshire Alliance has enabled face to face training to be cascaded out in a multi-agency approach, with further training scheduled in other areas. 

Since 2015, The Tumbling Lassie Committee[9] has raised over £60,000 for TARA and IJM. The 2018 Seminar was titled Disrupting trafficking networks and included contributions from the Solicitor General, COPFS, Police Scotland, TARA and IJM.

A seminar in April 2019 looked at identifying and pursuing perpetrators in labour exploitation situations: the event brought together COPFS prosecutors from recent trials and appeals alongside Senior defence counsel and a representative from JustRight Scotland.

Key outcome: people and businesses are aware of how what they do and buy can contribute to this crime

Businesses have a key role to play in building a society where trafficking is not tolerated. The Scottish Government established a Corporate Group to involve and empower businesses to play their part in implementing the Strategy and to raise awareness of trafficking and exploitation. 

On Anti-Slavery Day the Cabinet Secretary for Justice launched Guidance for Businesses[10] in Scotland. This guidance is designed to complement UK Government guidance, and other relevant resources, to provide tailored advice for both larger and smaller businesses operating in Scotland. Following its launch the Cabinet Secretary for Justice wrote to 8 notable Scottish companies that did not have a Slavery and Human Trafficking Statement clearly visible on their website to encourage them to use this new guidance to meet their ethical and legal obligations to tackle and prevent human trafficking and exploitation. All these organisations have confirmed their compliance with the Modern Slavery Act.

The Scottish Government has continued working to raise awareness of human trafficking risks in public procurement. The national sustainable procurement tools[11] and supporting guidance were revised to ensure they take account of human trafficking considerations, including checking whether existing contractors have published a Slavery and Human Trafficking Statement. Since these updated tools and guidance were published in September 2018 they have been used to undertake an assurance review of Scottish Government contracts to establish ethical risk and identify mitigating action. The Scottish Government has also checked that all contracted suppliers with an annual turnover of £36m or more, have a Slavery and Human Trafficking Statement. Statements are reviewed on an ongoing basis to ensure relevant Scottish Government suppliers are compliant with section 54 of the Modern Slavery Act 2015. More recently the guidance[12] that supports the sustainable procurement tools has been updated to include a link to the Slavery and Human Trafficking Guidance for Businesses published in October 2018.

"I like coming to The Anchor as I can start to talk about my past truths and feel safe here, I am beginning to trust.”

The Scottish Government will consider how any amendments to the Modern Slavery Act 2015 in respect of section 54 and Transparency and Supply Chains following the independent review will extend to and impact Scotland. 

In March 2019 the Cabinet Secretary for Justice met with John McNally MP, Chair of the All Party Parliamentary Group on Hair and Beauty and Lesley Blair, Chair of the British Association of Beauty Therapy and Cosmetology, to hear about the work being taken forward to combat human trafficking and exploitation within the hair and beauty industry, particularly nail bars. 

The Civic Government (Scotland) Act 1982 provides for a range of licensing regimes, including public entertainment licensing, to be operated by local licensing authorities comprising locally elected councillors. Local authorities have some discretion over the scope of the regime and what it covers within the overall limits of the legislation. 

When something is licensed, local authorities can specify what activities and premises the public are admitted to for the purposes of entertainment or recreation.

In March 2018, a draft resolution was discussed at Dundee City Council Licensing Committee to extend the scope of the public entertainment licensing regime to include nail bars. This was subsequently advertised and a public consultation opened. The resolution called again at the Licensing Committee in June 2018, with no representations received on the consultation and the Committee agreed to the resolution with a commencement date of 1 April 2019.

As a result of these changes, only nail bars with a Public Entertainment Licence will be able to operate in the Dundee City Council area. East Lothian Council have also amended public entertainment licensing to cover nail bars.

On 26 April 2019 a new non-mandatory civic licensing regime for sexual entertainment venues (SEV) came into force. The key aims of civic licensing are the preservation of public safety and order and the prevention of crime. This discretionary licensing regime for SEV allows local authorities to consider local circumstances when granting licenses, including in setting the number of such venues able to operate within their area, and to exercise appropriate control and regulation of these venues. A local authority can decide to set a nil limit.

Where a local authority decides to licence SEV, licensing conditions along with enforcement will help reduce the risk of criminality such as prostitution and human trafficking; and help protect the safety and wellbeing of performers, customers and the wider public. The community should, in turn, benefit from a safer, regulated environment. Guidance to support local authorities in taking forward work in relation to licensing sexual entertainment venues has also been published[13].

In addition to work being taken forward by the Scottish Government, other partners are raising awareness of what the public, suppliers, businesses and employers can do to tackle human trafficking and exploitation in supply chains and to change consumer attitudes.

Brightwork Recruitment hosted two conferences, in Glasgow and Elgin, to raise awareness of human trafficking and exploitation, and transparency in supply chains, within the food and drink industry. The aim of the events was to inform attendees about the ethical and reputational risks which some of Scotland’s global brands may be running due to workforce vulnerabilities to exploitation.

In 2018 IJM launched make #slavefreenormal. The campaign highlights some of the everyday products that may have trafficking and exploitation in their supply chains: clothing, jewellery, mobile phones, rice, coffee, chocolate, make-up and flowers. The aim of the campaign is to encourage consumers to buy ethically, stop slavery at source and to raise consumer awareness and response.

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.

Refugees, asylum seekers and migrants

The second New Scots[14] 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.

COSLA, jointly with the Scottish Government, have produced guidance[15] to assist Scottish local authorities in meeting their statutory duties to support migrants and asylum seekers who have no recourse to public funds and are vulnerable to exploitation and trafficking. It provides information for people working in all sectors, who need to establish support options and entitlement to services, and highlights specific considerations for working with children and young people, adults with disabilities, and survivors of trafficking or domestic abuse that may require a targeted response. 


The homelessness and rough sleeping action group met over 9 months and developed 70 recommendations a number of which relate to people who sleep rough and may be vulnerable to exploitation. An Ending Homelessness Together[16] high level action plan was published in November 2018. Local authorities submitted five year Rapid Rehousing Transition Plans by the end of December and all received written feedback on their plan from the Scottish Government by the end of March 2019. Meetings have been arranged with 30 local authorities to discuss this feedback and these will be completed by July 2019. Local authorities have continued to develop their Rapid Rehousing Transition Plans in line with the feedback received. Some local authorities have now started implementation of their plans and funding from the Scottish Government will be distributed in summer 2019. 

Child Poverty

The Scottish Government is taking strong action to tackle and eradicate child poverty in Scotland, in line with the ambition outlined in the Child Poverty (Scotland) Act 2017.

Following publication of our first Tackling Child Poverty Delivery Plan, ‘Every Child, Every Chance’[17] in March 2018, recent progress includes:

  • Introducing a new minimum level for the School Clothing Grant of £100 for every eligible child; benefiting around 120,000 children each year;
  • Establishing the Innovation Fund, in partnership with the Hunter Foundation, investing £7.5 million by 2022 in innovative action to tackle child poverty;
  • Launching a new Financial Health Check service, delivered by the Citizen’s Advice network, which supports families to maximise their income and avoid paying the poverty premium for essential goods and services; and
  • Awarding over £2.7 million by the end of January 2019 through new Best Start Grant Pregnancy and Baby payments; helping over 7,000 low income families meet the costs of essentials such as a pram or cot.

The Scottish Government will publish the first annual progress report by the end of June, setting out the progress made on all of the actions committed.

Violence against women and girls

Violence against women and gender inequality make women vulnerable to trafficking and exploitation. The Scottish Government is committed to tackling violence against women and girls and is implementing Equally Safe, Scotland’s strategy to prevent and ultimately eradicate this violence. In November 2017, the Scottish Government and COSLA published a delivery plan containing 118 commitments across four priority areas. There is a focus on commercial sexual exploitation within the delivery plan, including a commitment to establish a multi-agency working group to develop steps designed to reduce harms associated with this type of violence, support women to exit, challenge demand and tackle in a holistic way issues that can lead to someone being exploited in this manner.

Sustainable development goals (SDGs)

Scotland was one of the first countries in 2015 to sign up to the UN SDGs and the National Performance Framework (NPF)[18] is Scotland’s localisation of the SDG agenda. The UN expects all member states to review progress towards the SDGs through a “Voluntary National Review” (VNR). The UK will be submitting its VNR to the UN ahead of the UN High Level Political Forum taking place in July 2019. The Scottish approach to the VNR has been for SG and COSLA to work with the SDG Network Scotland[19] to collaboratively develop contributions to the UK VNR and to publish our own specific Scottish review. As part of this process, we have published a discussion paper on Scotland’s performance against the SDGs and conducted a Scotland-wide survey to seek input on Scotland’s approach, performance, challenges and opportunities in delivering the goals. These reports will be published in summer 2019 and will help us to better understand where we are now and what next steps we need to take to fulfil our commitments for 2030.

International action

Action Area 3 of the Strategy is focused on addressing the conditions that foster trafficking and exploitation both locally and globally. 

As mentioned in the Action Area 2 chapter Vietnamese nationals continue to be the largest group referred to the NRM in Scotland. On 21 November 2018 the UK and Vietnamese Governments signed a Memorandum of Understanding (MOU) on anti-human trafficking cooperation. The MOU was signed in London by the Vietnamese Minister of Public Security and UK Home Secretary. 

As a result of funding received from the UK Government, via the Police Transformation Fund, Every Child Protected Against Trafficking (ECPAT) and the Pacific Links Foundation have been carrying out research in the UK and in Vietnam to gain a better understanding of why Vietnamese children are trafficked to the UK

At the start of 2018, IJM announced support from the Walmart Foundation to address human trafficking in the Thai fishing industry. With public-private investment from the U.S. Department of State’s Trafficking In Persons Office and Walmart Foundation, IJM’s office in Bangkok is positioned to support the Thai Government’s efforts to combat human trafficking in the fishing industry – a key supplier to global supermarkets. The Scottish Government will take into consideration any findings from this work and how that may apply in Scotland. 

Freedom Sunday› is an invitation for the Global Church to learn about human trafficking and exploitation and partner with the IJM to end it. In 2018, IJM had more than 18,000 churches in 52 countries experience Freedom Sunday.

Looking Forward

Public awareness raising activity will continue, including work with partners to co-ordinate opportunities and approaches. A key focus will be on Anti-Slavery Day, 18 October 2019. 

The Scottish Government will give further consideration to the latest TNS Survey results and use the findings to shape our messaging in the coming year.

The Action Area 3 Implementation Group will develop existing links with CATRiS to ensure that research can benefit policy and practice in Scotland.

The Corporate Group will consider next steps on business engagement in order to mitigate the risks of trafficking and exploitation within operations.

The Scottish Government will consider the publication of a Slavery and Human Trafficking Statement.



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