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Modern Slavery Policy


Indicators of trafficking

The following questions can help indicate if an individual is a victim of human trafficking:

  • Is the person in possession of their own passport, identification or travel documents or are these documents in possession of someone else?
  • Does the person act if they were instructed or coached by someone else? Do they allow others to speak for them when spoken to directly?
  • Was the person recruited for one purpose and forced to engage in some other job? Have transport costs been paid for by facilitators, whom they must pay back through working or providing services?
  • Does the person receive little or no payment for their work? Is someone else in control of their earnings?
  • Does the victim have freedom of movement? Are they dropped off and collected from work?
  • Is the person withdrawn or do they appear frightened?
  • Has the person or their family been threatened with harm if they attempt to escape?
  • Is the person under the impression they are bonded by debt, or in a situation of dependence?
  • Has the person been physically or emotionally harmed or deprived of food, water, sleep, medical care or other life necessities?
  • Can the person freely contact friends or family? Do they have limited social interaction or contact with people outside their immediate environment?

Procedure if someone is suspected of being trafficked/enslaved

Being a ‘First Responder’, WMCA has a Duty to Notify (DtN) the Home Office if anyone working within the CA identifies an individual with indicators that suggest they may be trafficked/enslaved. If someone suspects that this is occurring, they are to inform either their manager, HR, a Safeguarding Officer or by following the procedure outlined in the Whistleblowing policy.