The NRM is the UK’s framework for identifying and supporting victims of modern slavery. An adult or child can be referred into the NRM by organisations known as First Responders.
Home Office guidance states that, following a referral, a decision on whether the individual is a victim of modern slavery will be determined by a relevant competent authority – either the Single Competent Authority (‘SCA’) or Immigration Enforcement Competent Authority (‘IECA’). There are two stages to this determination. The first is a Reasonable Grounds (‘RG’) decision, which should be made within 5 working days of the referral. The relevant competent authority will then make a Conclusive Grounds (‘CG’) decision at least 30 days following the RG decision being made.
Recently, however, wait times for CG determinations have greatly exceeded the timescales given in Home Office guidance. In recent years, the average number of days to wait for an RG decision has risen from 13 days at the beginning of 2020, to 56 days in the second half of 2023, leaving many at risk. Positive RG decisions for adults also fell to record lows in 2023. Where 89% of cases were granted positive decisions in Q2 of 2022, the same period in 2023 saw only 27% given the same result.
The extensive delays in making CG decisions have significant ramifications for potential victims of modern slavery. Philippa Southwell, speaking to i News on Home Office delays, reported that several Southwell & Partners clients had been made to wait years for a decision. In some instances, clients have been deported while waiting for the Home Office to make a determination. Delays cause further unnecessary and adverse impact to victims.
Southwell & Partners specialise in representing victims of human trafficking and forced criminality exploitation.