Does a suspected victim of modern slavery need to self-identify before an officer can refer them?

No. A victim does not need to self-identify — officers can and should refer where indicators of modern slavery are present even if the person denies being a victim.

What is the section 45 defence?

Section 45 of the Modern Slavery Act 2015 provides a statutory defence for adults who were compelled to commit an offence as a direct consequence of being a victim of slavery or trafficking, and a broader defence (with no reasonableness test) for children under 18. Schedule 4 excludes certain offences, including murder, rape, and terrorism offences, from the defence.

What are the two decisions made in the National Referral Mechanism?

The Single Competent Authority first makes a Reasonable Grounds decision, normally within 5 working days, and then — after the recovery and reflection period — a Conclusive Grounds decision on the balance of probabilities as to whether the person is a confirmed victim.

Modern Slavery & Human Trafficking

A guide for police officers on identifying modern slavery, understanding the National Referral Mechanism, and fulfilling First Responder duties under the Modern Slavery Act 2015.

Unofficial independent resource — always verify with official sources (College of Policing, your force, PFEW).

Reviewed by the BlueLineHub Editorial Team

Last reviewed: 26 August 2026 · Next review due: 26 February 2027

Reviewed by BlueLineHub Editorial

What is modern slavery and what must a police officer do if they identify a victim?

Modern slavery covers human trafficking, forced labour, domestic servitude, sexual exploitation, criminal exploitation and (rarely in the UK) organ harvesting — all involving control, coercion and the removal of personal freedom under the Modern Slavery Act 2015. No single indicator confirms modern slavery, but physical, behavioural and environmental signs across categories should raise significant concern.

Every police officer is a designated First Responder under the Act. Where indicators are present the officer should refer the person into the National Referral Mechanism — with a duty to notify the Home Office of adult victims who do not consent to a referral — and the Single Competent Authority then makes a Reasonable Grounds decision followed by a Conclusive Grounds decision.

All operational references

A reference to identifying modern slavery, making a National Referral Mechanism referral as a First Responder, and the section 45 statutory defence under the Modern Slavery Act 2015. It is educational reference, not tactical guidance — follow your force policy, training and current law.

What is Modern Slavery?

Modern slavery encompasses several distinct but overlapping forms of exploitation, all involving control, coercion, and the removal of personal freedom.

Human trafficking

Recruiting, transporting, transferring, harbouring, or receiving persons by threat, force, fraud, or abuse of power for exploitation. Movement across borders is not required — internal trafficking is equally illegal.

Forced labour

Work or services extracted under threat, menace, or penalty. Common in agriculture, construction, food processing, car washes, and domestic work. Victims often controlled via debt bondage.

Domestic servitude

Victims (often women) are forced to carry out domestic tasks in private households, controlled by the employer/household. Isolation is a key feature — victims rarely leave the property.

Sexual exploitation

Controlling, arranging, or facilitating sexual activity for financial gain. Victims may appear to be acting voluntarily — coercion is often hidden. Look for signs of control by a third party.

Criminal exploitation

Forcing victims to commit crimes, including drug supply (county lines), shoplifting, cannabis cultivation, benefit fraud, and pickpocketing. Often involves children — child criminal exploitation (CCE).

Organ harvesting

Rare in the UK but recognised internationally. Victims are transported and coerced into providing organs for transplant. A specialist referral pathway exists.

Indicators of Modern Slavery

No single indicator confirms modern slavery. Multiple indicators across categories should raise significant concern. Officers should record specific observations, not conclusions.

Physical Signs

Unexplained injuries or signs of physical abuse
Malnourishment or dehydration
Branding marks or tattoos indicating ownership
Wearing inappropriate clothing for the weather or season
Dental decay, untreated medical conditions
Exhaustion, appearing heavily sedated
Signs of sexual exploitation (STIs, pregnancy)

Behavioural Signs

Fearful, anxious, submissive, or avoidant
Scripted or rehearsed answers to questions
Unwilling to discuss personal circumstances
Third party speaks for them, controls documents
Does not know their own address or location
Apparent lack of freedom to come and go
Does not appear to be in control of their own money
Uses language suggesting they owe a debt

Environmental Signs

Overcrowded or unsuitable accommodation
Appears to live at place of work
Multiple people sharing a single address (cuckooing indicator)
Locked in premises or unable to leave freely
Few personal possessions, no ID documents
Transported in controlled groups
Poor sanitation, inadequate food

First Responder Duty & NRM Referral Process

All police officers are designated First Responders under the Modern Slavery Act 2015. You have a legal duty to refer suspected victims into the NRM. This is not optional.

1. Identify

Officer identifies indicators of modern slavery. Victim does not need to self-identify — officers can and should refer where indicators are present even if the person denies being a victim.

2. Duty to Notify (s.52)

For adults who do not consent to an NRM referral, police have a duty to notify the Home Office (via the UKVI referral route) of the suspected victim. This does not require victim consent. Applies only to adults.

3. NRM Referral Form

First Responders (including all police officers) complete the online NRM referral via the Modern Slavery Victim Care referral system. Include all indicators observed, victim account (if obtained), and supporting evidence. A victim must consent to NRM referral (adults) or referral is made automatically (children under 18).

4. Single Competent Authority

The referral is assessed by the Single Competent Authority (SCA — part of the Home Office). They decide whether to accept it to the NRM process. The SCA makes two decisions: Reasonable Grounds and then Conclusive Grounds.

5. Reasonable Grounds decision

Within 5 working days: SCA decides whether there are reasonable grounds to believe the person is a victim of modern slavery. If positive: the victim enters the National Referral Mechanism and receives support (accommodation, financial support, legal advice) via the Salvation Army 'Victim Care Contract'.

6. Conclusive Grounds decision

After the 'recovery and reflection period' (minimum 45 days for adults): SCA makes a Conclusive Grounds decision — whether on the balance of probabilities the person is a confirmed victim. A positive conclusive grounds decision provides longer-term support and can assist immigration applications.

Section 45 Statutory Defence — Victims Who Commit Offences

Section 45 of the Modern Slavery Act 2015 provides a statutory defence for adults (and a full defence for children under 18) who commit offences as a direct consequence of their exploitation as a victim of slavery or trafficking.

Adult defence (s.45(1))

Applies where the person was compelled to commit the offence, the compulsion was attributable to slavery or trafficking, and a reasonable person in their situation and sharing their characteristics would have done the same.

Child defence (s.45(4))

Broader than the adult defence — a child is not guilty of an offence if they committed it as a direct consequence of being, or having been, a victim of trafficking. No reasonableness test for children.

Excluded offences

Schedule 4 of the Act lists offences that cannot attract the s.45 defence, including murder, rape, and terrorism offences. For all other offences, consider the defence before charging.

Practical application

If you suspect a person you are dealing with is a victim of modern slavery who has committed an offence (e.g., cannabis cultivation, shoplifting), consult your supervisor and force Modern Slavery lead before making a charging decision. An NRM referral should be considered alongside any investigation.

County Lines & Child Criminal Exploitation

County lines describes drug supply networks where gangs use a dedicated mobile phone line (the "line") to market drugs across county boundaries. Children and vulnerable adults are exploited to transport and supply drugs.

Cuckooing

Gangs take over the home of a vulnerable person to use as a drug supply base. The occupant is exploited and may be a victim of modern slavery. Indicators: multiple visitors at unusual hours, unfamiliar people in the property, occupant appearing fearful or controlled.

CCE indicators

Child seen with older males or groups, unexplained cash or gifts, missing from home/school for periods, found in unfamiliar locations with drugs or cash, using language associated with drug supply ('trapping', 'OT'), multiple phones.

Criminal exploitation vs. offending

Children and young people found in possession of drugs or county lines paraphernalia should be treated as potential victims before suspects. Consider s.45 defence. Consult force Modern Slavery / CCE leads.

Safeguarding response

Children: automatic NRM referral and s.47 enquiry. Adults: NRM referral (with consent) plus duty to notify. Coordinate with social care, schools, and specialist Modern Slavery units.

Victim Care — Immediate Safety, Accommodation, and Immigration

Immediate safety

Remove the victim from the immediate situation — away from the suspected controller or trafficker. Do not conduct interviews in the presence of anyone who may be involved in their exploitation. Be aware of the risk that the victim may not trust police.

Trauma-informed approach

Victims of trafficking have often been subjected to prolonged trauma and may be distrustful, inconsistent, or appear uncooperative. Do not treat inconsistency as dishonesty. Build rapport before formal questioning.

Salvation Army contract

The UK Government contracts with the Salvation Army (through their subcontractors) to provide support to confirmed NRM referrals: safe accommodation, financial support, and access to legal advice and health services.

Immigration status

Immigration status is not a barrier to an NRM referral. Victims may be in the UK illegally — this does not mean they are not victims, and enforcement action should not be the primary response. Engage Border Force and immigration specialists separately.

Evidence gathering

Where possible, gather evidence contemporaneously: photographs of injuries, accommodation, phones, documents. Obtain consent where possible but note that evidence gathering can proceed without consent in serious cases. Preserve all digital evidence.

Key Legislation

Provision	Description
MSA 2015 s.1	Slavery, servitude, and forced or compulsory labour — maximum life sentence.
MSA 2015 s.2	Human trafficking — arranging or facilitating travel with a view to exploitation. Maximum life sentence.
MSA 2015 s.45	Statutory defence for victims who commit an offence as a direct consequence of being a victim of slavery or trafficking.
MSA 2015 s.52	Duty to Notify — police and specified public authorities must notify the Secretary of State of suspected adult victims who do not consent to NRM.
MSA 2015 s.54	Transparency in supply chains — commercial organisations over a certain turnover must publish an annual slavery and trafficking statement.
Children Act 1989	Child safeguarding duties engaged where victim is under 18 — NRM referral is automatic; s.47 enquiries must be considered.

Frequently asked

Does a suspected victim of modern slavery need to self-identify before an officer can refer them?: No. A victim does not need to self-identify — officers can and should refer where indicators of modern slavery are present even if the person denies being a victim.
What is the section 45 defence?: Section 45 of the Modern Slavery Act 2015 provides a statutory defence for adults who were compelled to commit an offence as a direct consequence of being a victim of slavery or trafficking, and a broader defence (with no reasonableness test) for children under 18. Schedule 4 excludes certain offences, including murder, rape, and terrorism offences, from the defence.
What are the two decisions made in the National Referral Mechanism?: The Single Competent Authority first makes a Reasonable Grounds decision, normally within 5 working days, and then — after the recovery and reflection period — a Conclusive Grounds decision on the balance of probabilities as to whether the person is a confirmed victim.