Report on Hestia’s super-complaint on the police response to victims of modern slavery
On 31 May 2019 Hestia made a super-complaint to Her Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS).
This super-complaint is about the policies and practices of all police forces in England and Wales with respect to the standard of support that victims of modern slavery receive.
This super-complaint raises several concerns about the police response to victims of modern slavery. These are:
- non-specialist police officers fail to recognise the signs of exploitation and fail in their duty to report modern slavery to the Home Office;
- police officers aren’t taking immediate steps to make a victim feel safe;
- victims of modern slavery are treated as immigration offenders;
- victims of modern slavery are treated as criminals when they have been forced to commit criminal activities by their exploiters, despite the existence of the section 45 defence in the Modern Slavery Act 2015;
- police forces don’t adequately investigate cases that come to their attention; and
- the adequacy of training provided to frontline officers.
A recurring theme in Hestia’s super-complaint is the lack of effective support for victims. It says this lack of support, along with experiences of poor treatment, deters victims from engaging with investigations.
What is a super-complaint?
A super-complaint is a complaint that “a feature, or combination of features, of policing in England and Wales by one or more than one police force is, or appears to be, harming the interests of the public” (section 29A, Police Reform Act 2002).
The system aims to examine problems of local, regional or national significance that may not be addressed by existing complaints systems. The process for making and considering a super-complaint is outlined in the Police Super-complaints Regulations 2018.
Super-complaints provide a voice for designated bodies to raise concerns on behalf of the public. They can include patterns or trends in policing that are, or appear to be, harming the interests of the public.
College of Policing and the Independent Office for Police Conduct (IOPC) are responsible for assessing, investigating and reporting on police super-complaints. We have collaborated on the investigation and on drawing conclusions.