1 April 2022 - 31 March 2023

1. Introduction

Migrant Help exists to protect people affected by displacement and exploitation and is thus well positioned to take a comprehensive approach to address the issue of modern slavery. We work with survivors, and we are first responders in identifying potential victims among our clients. We also have a firm commitment to understanding the risks within our own operations and supply chains.

This statement sets out the steps that Migrant Help and its subsidiary Clear Voice Interpreting Services have taken and are continuing to take to ensure that modern slavery, human trafficking and forced labour do not occur within our operations or supply chain for the financial year ended 31 March 2023.

2. Organisation’s Structure & Supply Chains

“Migrant Help is a UK wide charity delivering a range of support and advice services to vulnerable migrants. In the last financial year, more than 96,000 people accessed the asylum services we provide, we supported 2,515 potential victims of modern slavery, we helped 154 refugees to resettle in Kent and we advised over 4,000 EU citizens on settlement status.”

We operate from 15 offices across the UK, providing advice, guidance and support to asylum seekers, refugees, EU migrants and victims of modern slavery and human trafficking. We also operate a small number of accommodation units to support survivors of trafficking as part of our work for the National Referral Mechanism under the Modern Slavery Victim Care Contract. 

Migrant Help is governed by a Board of Trustees who volunteer their time to help direct our work. They oversee our directors who manage our 450+ staff across the charity. We have one wholly owned trading subsidiary, Clear Voice Interpreting Services, that operates a pool of over 1500 self-employed interpreters. We purchase IT services, stationery, small quantities of branded merchandise, furniture for accommodation and other office equipment, together with cleaning, maintenance and professional services. We also subcontract some work to other organisations and charities, such as some call centre services and projects to support our clients.

Support for Potential Victims and Survivors of Modern Slavery

Migrant Help is one of the leading providers of specialist support and accommodation services for adult victims and their dependants in the UK. We have dedicated casework teams assisting victims in Scotland, Northern Ireland and England. In England, we provide this service as a subcontractor to The Salvation Army under the Modern Slavery Victim Care contract.

Our approach centres on each client's individual needs. Ultimately, our main priorities are reducing the risk of re-trafficking and empowering our clients to gain in confidence and move forward to a new and positive chapter in their lives. We are committed to helping victims feel safe, informed, supported and able to gain control over their lives again.

Our work includes:

  • providing safe accommodation
  • facilitating access to health services and counselling
  • emotional wellbeing
  • providing financial and practical assistance
  • assistance with accessing compensation
  • liaising with law enforcement
  • re-connecting with family
  • assistance with acquiring new identification documents
  • integration into the community or a safe and supported repatriation if requested

3. Governance & Policies

Migrant Help plays a vital role in supporting survivors of modern slavery through our core activities. We also promote ethical practices, due diligence, and engagement within our supply chain. We expect our suppliers to share our high standards towards ethical behaviour which includes, but is not limited to, adhering to modern slavery laws, and creating an environment that does not punish whistle- blowers.

Our approach is supported by the following policies, which set out the standards of behaviour expected of all Migrant Help staff, establish requirements of our suppliers, and provide guidance for staff to report any concerns or suspicions of modern slavery.

  • Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships. The Chief Executive and the Senior Management Team are responsible for ensuring that the policy is implemented throughout Migrant Help and reviewed annually. 
  • Our Procurement Policy sets out Migrant Help’s requirements for purchasing goods and services, including but not limited to ethical considerations and factoring in Migrant Help’s commitment to the Living Wage.
  • Our Code of Conduct for Third Parties establishes the standards we expect of our suppliers, including those who may encounter our vulnerable Clients. It also sets out our commitment to support suppliers in developing their approach to compliance with the Modern Slavery Act (2015), to promote Human Rights in accordance with the Human Rights Act (1998) and to reduce the risk of child labour and other labour exploitation.
  • Our Whistleblowing Policy encourages staff to report any concerns confidentially and without any fear of victimisation or retaliation.
  • Our Safeguarding Policy ensures that the safeguarding of adults and children, including victims of modern slavery, is well understood by all staff and, importantly, is acted on in an appropriate and timely manner to ensure the protection of our clients and our staff. 
  • Our Anti-Corruption and Bribery Policy aims to protect individuals, including our clients, from being exploited in return for favours from our organisation.

4. Identification & mitigation of risks

Due to the nature of our work, some of our clients are at high risk and some are identified as potential or actual victims of modern slavery. These continue to remain our priority focus.

We are also working to improve our process of mapping and assessing our supply chain for modern slavery risk to enable us to prioritise suppliers for reviews, on-site visits and enhanced due diligence. We have identified several higher risk categories and are prioritising engagement with suppliers providing these goods and services to our organisation. We publish internal blogs and articles to inform and educate all Migrant Help staff on the importance of an ethical supply chain, enabling them to act as eyes and ears across the business.

5. Due diligence processes

To address the risks to clients, we ensure that there are robust risk management and safeguarding procedures in place for their protection and to protect staff working with them.

Safeguarding Our Clients and Staff

All staff receive safeguarding training and managers who hold the responsibility of Designated Safeguarding Leads (DSL), Deputy DSL or Designated Safeguarding Officers (DSO) have had additional training suitable for this role and responsibility. The Director of Asylum has the overall responsibility as DSL and is supported by six Deputies. DSOs are in place in each Migrant Help site, and this is usually a manager.

The DSLs have a safeguarding group meeting monthly which also includes the Lead Trustee for Safeguarding by invitation and the CEO. There are robust data monitoring systems for safeguarding which are reviewed by the Safeguarding Team, from which improvements in safeguarding practice are implemented. In 2022/2023, we grew the central safeguarding team to maintain the oversight and strategic development of safeguarding within the organisation.

Vetting Our People

All staff are required to complete a Baseline Personnel Security Standard (BPSS) check as a condition of employment and we undertake identity and right to work checks, including employment references. Furthermore, staff in certain roles must undergo a Counter Terrorism Check (CTC).

Supplier Due Diligence

Slavery can exist at every stage of the supply chain, from extracting raw materials such as the timber used in paper production to cleaning services and the hospitality sector. Migrant Help has put measures in place to scrutinise our suppliers’ operations and business practices, including questionnaires and supplier visits. In addition, the requirements in our Supplier Code of Conduct form part of the contractual terms signed by all subcontractors and suppliers, requiring alignment to our values and principles.

Our Procurement Department has centralised the purchasing and supplier onboarding framework giving better control and oversight of our procurement practices, management of potential risks whilst ensuring our core values are met. We have also expanded our due diligence process focusing on criteria in line with our core values of Protection, Diversity, Equality, Partnership, Innovation and Excellence for suppliers of goods and services.

We conduct checks on all prospective and existing partners, suppliers and subcontractors of Migrant Help to ensure that their organisation shares our commitment to prevent workplace practices which enable, or are defined as, modern slavery. New suppliers who come on board must meet set criteria including evidence of a good quality modern slavery statement where they meet the size threshold, completion of a modern slavery questionnaire and evidence of appropriate policies, ethical workplace practices and oversight of their supply chain. We review adherence to ethical work practices for highrisk suppliers on an annual basis.

Our approach aims to promote continuous improvement, acknowledging that new risks may arise as we continue operations with third parties and committing to act swiftly to mitigate those risks. We hold regular review meetings and willingly offer and provide our expertise on modern slavery matters as needed to our suppliers.

To ensure our suppliers are following their processes and implementing their business operations to the expected level, on-site visits are routinely carried out. These visits play an important part in developing effective and transparent relationships and provide the opportunity to see firsthand how they deliver our product or service on a practical level. Supply chain mapping and ethical sourcing is a key topic covered, with a requirement in place for providing evidence of how our suppliers carry out their due diligence in these areas. For suppliers in higher risk categories, we aim to carry our annual site audits.

We also provide specific advice and guidance to staff who have procurement responsibilities within their area.

Case Study: During a recent visit to a supplier of printing services, we had the opportunity to meet the team and everybody involved in delivering our product and the environment they work in. This visit covered all aspects of their business from approved supplier selection for raw materials as well as effective methods of standards and oversight, including their Modern Slavery Policy, ISO9001 compliance, Environmental Policy and Information Security measures. They evidenced all paper products that they source come from Forest Stewardship Council (FSC) accredited paper mills, providing environmental, social and economic benefits, with the Operations Director visiting these paper mills routinely as part of due diligence. Seeing our product being produced from raw material to awaiting despatch provided a great insight into the culture and work ethos of the company, from director and senior management level to factory operators.

Raising concerns

We respond swiftly and professionally to any concerns raised by clients, staff or suppliers, which would include any concerns about the potential for modern slavery within our supply chains and service areas. None were received in the last financial year.

6. Measuring effectiveness

Our Senior Management Team annually reviews the effectiveness of our measures for ensuring that risks of slavery and human trafficking within our operations and supply chains are addressed and reports to the Board of Trustees accordingly.

We measure our effectiveness in relation to clients through a combination of internal audits, third party audits, client feedback and KPIs required under our contracts.

Safeguarding Across the Organisation

All our staff complete mandatory safeguarding training which is reviewed annually and we to continue to work closely with strategic partners sharing best practice to ensure our clients are safeguarded from harm whenever possible and mitigate further risks.

Support for Potential Victims and Survivors of Modern Slavery

The effectiveness of Migrant Help’s performance under the Modern Slavery Victim Care Contract is measured through a robust performance management framework including contractual key performance indicators and mandatory inspections assessing different aspects of compliance and quality. Our work also receives regular audits from the Care Quality Commission (CQC).

In the year 2022-23 we received four external inspections by CQC (three for our outreach services and one for the safehouse), The inspector reviewed core policies, case management, governance and organisational process such as recruitment and training, they also interviewed staff and service users as part of this process. The CQC inspection provided positive feedback and recommendations for areas of further improvement but identified no concerns with the services inspected. We have now implemented internal Quality Management Frameworks for all of our modern slavery services to ensure regular monitoring of compliance and quality but also to drive service improvements and work towards best practice in all areas of service delivery.

 Internally, we monitor the performance of our modern slavery teams by using Scorebuddy, an online platform that monitors an advisor’s client caseload. One case per advisor is selected at random to assess on a monthly basis, with results given as ‘under-performing,’ ‘developing,’ ‘successfully performing,’ and ‘exceeding.’ In each feedback session, advisors are taken through the scorecard results and receive commendation on best practice, something to be aware of, and a recommendation. The platform also produces reports for managers to review quarterly. This also allows us to be responsive to trends that are emerging and focus on different matters as they arise. Over the course of 2022-23 we updated and improved the Scorebuddy system to target areas of improvement and to support with implementation of new process.

Clients can provide feedback directly through forms, which are available in different formats and translated into 14 different languages. We track the responses each quarter and follow up on issues identified, enabling us to improve our services to clients. In 2022-23 following a review and consultation with our clients we updated the scoring information on the form to make this easier to understand. We also created a task and finish group to make the process more engaging for clients and to ensure that we are capturing information that is more effective in identifying gaps in services.

In July 2022 we established two lived experience advisory panels (LEAPs) for our modern slavery services, one for the MSVC contract and joint panel between our services in NI and Scotland. Both panels have been involved in a number of projects and initiatives both internally and externally. This continues to be an exciting area of work for the organisation as we develop our knowledge and experience in effective coproduction work. LEAP members have been involved in consultation, conferences, research, and much more, they are also involved in a number of Task and Finish groups across different areas of work in the organisation to drive improvements based on lived experience. The Scotland/NI group has been nominated for an award at the Human Trafficking Foundation Anti-Slavery Day Awards in the Empowering Survivor Voices category for the work they undertook as part of the Scottish Government Exploitation Strategy review.

Addressing Supply Chain Risks

We are in the process of developing measures to track the effectiveness of our mitigations to address supply chain risks.

In 2022/2023, we made significant improvements to the monitoring of our suppliers and measuring the effectiveness of our risk mitigations as per the Supplier Due Diligence section of this statement. In 2023/24 we intend to further improve this process through increased supplier audits and further training and education of staff members who are business owners of specific supplier relationships.

7. Communication and Training

All employees and new joiners receive training on all modern slavery related policies and have direct access to all policies via the organisation’s Intranet. We provide annual eLearning on modern slavery and human trafficking for all staff at Migrant Help and a quiz to assess their understanding. Our training includes knowing what modern slavery is, how to identify potential cases and how to report issues.

Our staff responsible for delivering services directly to survivors receive additional specialised training, including Modern Slavery Guidance to aid in recognising potential cases. Our regional staff offices each have a member of staff who leads on matters regarding modern slavery and who can provide guidance and information on issues and referrals within their team.

Our training programme is supplemented by ongoing internal communications through a variety of media including blogs, videos and faceto-face engagement, which brings the topic of modern slavery to life and reinforces staff responsibilities in relation to addressing it.

We continue to offer training and information sessions to external organisations on request to raise awareness on modern slavery in the workplace.

This Modern Slavery Statement has been approved by the Board of Trustees and is signed by Caroline O’Connor, the charity’s Chief Executive.