Masters Dissertation Final v1.0

ANGLIA RUSKIN UNIVERSITY
Degree
Transnational Crime
Title of Award
Master of Arts
Date
12/08/2016
SID Number
0909274
Title of Dissertation
Exploring the Practicalities of
Enforcing the Modern Slavery Act
Applying a policing lens to a case
study of tackling forced labour
Word Count
15,236
DECLARATION: I declare that the above work is my own and that the material contained herein
has not been substantially used in any other submission for an academic award.
Signed: Date: 12/08/2016
All dissertations, projects etc, submitted as part of an assessment process for a degree become
University property once handed in, and are not normally available to be returned. It is therefore
recommended that candidates retain a personal copy. The submitted copy may be retained by the
University for reference by others.
Author: Tom Martlew Email: tom.martlew@cambs.pnn.police.uk

Exploring the Practicalities of Enforcing the Modern Slavery Act August 12, 2016
i
Abstract
Currently, it is estimated by the Home Office that there are between 10,000 and 13,000
victims of Modern Slavery in the UK. Traditionally, the focus of governments has been on the
trafficking of women and children for the purpose of sexual exploitation. However, since the
death of 23 undocumented Chinese migrant workers at Morecombe Bay in 2004 there has
been a growth in literature that has evidenced severe labour exploitation, (with some
practices amounting to forced labour), existing in the lower echelons of the UK labour market.
With growing pressure of the government by groups and a demand by enforcement agencies
for more coherent and fit for purpose legislation, the government in 2015 introduced the
Modern Slavery Act. A landmark piece of legislation that brought together existing laws on
trafficking and forced labour into one and set out strategy to reduce the prevalence of
contemporary forms of slavery in the UK.
This study aims to explore the practical realities of enforcing this new act by capturing
practitioners’ experiences of tackling a serious case of exploitation in the agricultural sector
– a sector that has been characterised by insecurity, exploitation and a high proportion of
migrant workers. In 2016, four members of Latvian Organised Crime Group were charged with
offences associated with the exploitation of migrant workers in the small market town of
Wisbech. By exploring the two multi-agency operations that led to their conviction within a
problem-oriented policing framework, this research brings a policing lens to the growing body
of literature on modern slavery in the UK.
By interviewing a small group of practitioners from Cambridgeshire police and Fenland
District Council, what the study found was that despite overcoming technical, practical and
cultural challenges in identifying and investigating this complex crime, the fundamental
obstacle facing enforcement of the act and obtaining convictions is defining and evidencing
where labour exploitation ends and forced labour begins.

ii
Acknowledgements
First and foremost, I would like to thank my tutor and advisor Dr Anna Markovska for her
guidance and support. Her passion for criminology is truly infectious and I have been
fortunate to share many discussion with her on all things criminal.
I would like to thank Cambridgeshire Constabulary for giving me permission to undertake
the research. Without it I couldn’t have achieved what I set out to do. I am truly indebted
and thankful to the participants who gave up their time to be interviewed. Their dedication
to protect some of the most vulnerable people in our society and tackle those who wish to
exploit them was spoken with such passion, knowledge and commitment - it was a privilege
to have met and gained valuable insights from them all.
I would like to thank my friends and family for their support during the highs and lows of
undertaking a major project.
Finally, I would especially like to thank my partner Steph for her patience, willingness to give
up weekends and overall; sharing the burden of balancing work, life and study. Without her
love and support I couldn’t have done this – thank you!

iii
Table of Contents
Abstract ...............................................................................................i
Acknowledgements ............................................................................ii
List of Tables .......................................................................................v
List of Figures......................................................................................v
List of Acronyms..................................................................................v
Introduction........................................................................................1
Chapter One: Literature Review..........................................................6
Problem-oriented policing..............................................................................7
Modern Slavery and Forced Labour in the UK ..............................................10
Conceptual challenges to the Modern Slavery Act 2015...............................14
Chapter Two: Methodology and Results...........................................23
Results..........................................................................................................31
Chapter Three: Findings and Analysis ...............................................34
Establishing Trends through Data.................................................................34
Engagement with Victims.............................................................................36
Victims to Court............................................................................................38
Intelligence...................................................................................................39
Control, resistance, loyalty and debt ............................................................40
Challenges in securing Modern Slavery related convictions .........................42
Educating the Victims, the Public and the Police ..........................................43
Chapter Four: Discussion ..................................................................46

iv
Identifying Modern Slavery in Wisbech ........................................................46
Analysing Modern Slavery: A Problem-Oriented and Intelligence-Led
Approach......................................................................................................51
Responding to Modern Slavery: A Victim-Led Approach...............................53
Chapter Five: Conclusion ..................................................................55
Bibliography......................................................................................57
Appendix A – Interview Guide ..........................................................63
Appendix B – Participant Consent Form ...........................................64
Appendix C – Practitioner A Interview Transcription ........................65
Appendix D – Practitioner B Interview Transcription........................77
Appendix E – Practitioner C Interview Transcription ........................89
Appendix F – Practitioner D Interview Transcription ......................102

v
List of Tables
Table 1: ILO Indicators of Forced Labour.................................................................................19
List of Figures
Figure 1: Skrivankova's Continuum of Exploitation.................................................................20
List of Acronyms
COP Community-oriented Policing
EU European Union
FDC Fenland District Council
GLA Gangmasters Licensing Authority
ILO International Labour Organisation
JRF Joseph Rowntree Foundation
MSA Modern Slavery Act 2015
OCG Organised Crime Group
POP Problem-oriented Policing
SARA Scanning; Analysis; Response; Assessment
UK United Kingdom

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Introduction
“…sometimes it’s forced labour… forced doesn’t mean in a sense that literally they are
frogmarched everywhere, but actually forced because they’ve got no other option”.
(Practitioner C)
In 2016 four members of a Latvian Organised Crime Group (OCG) were convicted for a total
of 23 years for a range of offences including fraud, money laundering and operating as
unlicensed gangmasters. The gang provided labour for the agricultural sector by sending
workers to farms and factories across the Fens (The Guardian, 2016) and housed them in
squalid conditions while profiting from their rent (Migrant Advisory Committee, 2014). What
this case presents is an opportunity to explore the phenomenon of modern slavery and forced
labour that has become a growing focus for both policy makers, researchers and police
agencies across the UK. Three years before Cambridgeshire Constabulary and Fenland District
Council formed a partnership, dubbed ‘Operation Pheasant’, to tackle a number of problems
that had manifested in Wisbech (a small market town in the United Kingdom). In the years
leading up to the prosecution not only were they successful in reducing demand for resources,
they uncovered a strong link between the issues they were tackling and the severe
exploitation of migrant workers. Intelligence gathered from their work identified a serious
case of what has been conceptualised as ‘modern slavery’ facilitated by unlicensed
gangmasters and rogue letting agents.
Within the UK this form of exploitation became a salient topic following the tragedy in 2004
involving 23 irregular (undocumented) Chinese migrants who drowned on the beach of
Morecombe Bay picking cockles for just £5 a bag under the supervision of their gangmaster.
The response was the passing of the Gangmasters Licencing Act in 2004 and the establishment

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of the Gangmasters Licencing Authority (GLA) whose continuing mission is to protect workers
and “curb the exploitative activities of agricultural gangmasters” (GLA, n.d) and regulate one
of the least regulated markets in the world (Craig, 2010). The scale of the problem can be
reflected in their 2014-2017 strategy;
“During 2013-14, the UK has seen a marked increase in labour exploitation ranging
from unlawful travel and subsistence schemes and withholding holiday pay up to and
including examples of human trafficking, forced labour, benefit fraud and other
heinous crimes committed by organised and determined criminals who have sought
to infiltrate the legitimate human supply chain”. (GLA, n.d, p.1)
Gangmasters, with their “Dickensian overtones” (Strauss, 2009, p. 2) are labour
providers/intermediaries for highly flexible and precarious markets particularly in agriculture
where workers are available when required yet are not being paid when there is insufficient
work (Rogaly, 2008). Evidence has suggested that these labour intermediaries have played a
crucial role when “exploitation of vulnerable workers can be identified as forced labour”
(Strauss, 2012, p.143). The framework that explains the re-emergence of gang labour,
gangmasters and the environment that has enabled exploitation to flourish can be found in
the growing body of literature. Scholars on the topic highlight the impacts of neoliberal
market policies and globalisation, intensification of workplace regimes, the growth in labour
intermediaries, and the unexpected large-scale economic migration from the A8 and A21
1
Countries that make up the A8 are Czech Republic, Estonia, Hungary, Latvia, Lithuania, Poland, Slovakia and
Slovenia who joined the European Union in 2004. Romania and Bulgaria formed the A2 accession countries that
joined three years later in 2007.

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countries. This structure has provided an inexhaustible pool of potential labour which, all
factors combined, create an environment where exploitation can flourish.
Prohibition of slavery, forced labour and human trafficking are already enshrined in
international and domestic law, however in 2015 The Modern Slavery Act (MSA) was passed
into UK law. Publicised as a landmark piece of legislation and an international first, the act
amalgamated a number of existing laws relating to human trafficking and forced labour to
make it much more efficacious for agencies to pursue convictions under a single, more
coherent piece of legislation (HM Government, 2014).
Despite this, many scholars have been increasingly dissatisfied with how modern slavery,
forced labour and human trafficking are conceptualised and defined in law. They are often
portrayed in rigid binaries such as free/unfree and forced/voluntary labour and are often used
interchangeably or inconsistently (O'Connell Davidson, 2010. Lewis, et al., 2015). Not only
does this provide confusion when exploring the phenomenon, it conveys the image that there
is a distinct and defined line been what constitutes modern slavery and what does not. This
makes it challenging for practitioners and law enforcement to know where labour law ends
and criminal justice proceeding begin. By moving away from definitions writers have been
able to move beyond these unhelpful binaries and highlight the importance of “complexities,
variations, processes, relations, contexts, and above all “continuums” in understanding forced
labour” (Lewis, et al., 2014, p. 588). It is through these lenses that the practicalities of
enforcing the MSA can be better understood and enable better responses to reduce the
prevalence of modern slavery in the UK.
So far studies on modern slavery have either focused on conceptual issues that have plagued
definitions, or on obtaining insight from victims, industries, labour providers and

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professionals through a number of small ‘qualitative’ studies (Strauss, 2012. Plant, 2014.
O’Connell Davidson, 2015). There has been little research on the impact of modern slavery on
enforcement agencies and the practicalities of day to day policing. Hence, this study aims to
provide a policing lens to the topic by capturing the experiences of practitioners involved in
the two related operations in Wisbech to help expand the practical knowledge base of this
phenomenon. It will use the popular modern policing method of ‘problem-oriented policing’
(POP) to provide the framework in which to structure the study by identifying and understand
the problem, how the police responded, what were the challenges faced and what were the
lessons learned (Bullock & Tilley, 2003). To achieve this the research will conduct a case study
of the events in Wisbech and capture empirical evidence from practitioners through semi-
structured interviews.
The research will take an exploratory approach by firstly conducting secondary research to
explore and review the current body of literature to understand the problem further.
Secondly it will conduct primary research to capture empirical data from practitioners who
were involved in either or both the two operations that are the focus of this study. To achieve
the aims of the research there are a number of objectives to complete.
1. Drawing on secondary sources to provide a brief overview of problem-oriented
policing to inform the structure of the research drawing on secondary sources.
2. Explore and review the current academic body of literature to analyse the problem of
labour exploitation in the agricultural sector and why migrants have been widely
acknowledged as most vulnerable to exploitation.
3. Use the MSA as the analytical framework to outline the conceptual challenges found
in the literature that introduces some of the complexities of its practical application.

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4. Conduct primary research and gather experiences from practitioners using a case
study methodology.
5. Use the literature and data collected by the study to explore the realities and practical
challenges of enforcing the MSA.
Chapter One will explore the current literature on POP and modern slavery in the UK. Chapter
Two will outline the approach and methodology that was adopted for the research. Chapter
Three will outline the findings and analysis from the interviews followed by Chapter Four
which will discuss them within the body of literature. The research will then conclude with
key findings and highlight any further research opportunities that may have arisen given the
exploratory nature of the work.
There are significant limitations to this research giving its size, resources and the complexities
of the topic. Fundamentally what this study hopes to achieve is to promote the greater need
for further investigation and, where possible, the evaluation of policing methods to support
those on the frontline who are responsible for protecting victims, pursuing and prosecuting
offenders, and preventing modern slavery from occurring in their communities.

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Chapter One: Literature Review
The purpose of this chapter is to critically review the current body of literature to evaluate
and identify methodological approaches as well as gaps in knowledge that can inform the
research question of this study (Hart, 2005. Matthew and Ross, 2010). A literature review is
an essential part of all research as it will help to shape the rationale for the study, inform the
methodology and the discussion of the findings. The latter, according to Hart (2005, p. 183),
is where this study can relate back to previous research to “show how [the] research makes
a contribution to the knowledge of the topic or problem”.
However, identifying consistent and appropriate literature to inform the discussion of
modern slavery amongst migrant workers proved to be no easy task. The initial challenge was
finding a “lack of conceptual clarity in some discussions of forced labour, unfree labour,
trafficking and slavery” as they are often used “interchangeably or inconsistently” (Strauss,
2012, p. 138). Furthermore as Strauss (2012) points out, so far there have been only a “small
amount of studies (qualitative) on one hand and the need for greater conceptual clarity on
the other” which has distilled the literature down to a small number of studies, articles and
reports. Despite this, over the last decade this topic has seen significant grounds made in
understanding both conceptually and evidentially labour exploitation and modern slavery in
the UK.
Before drawing on these studies this chapter will provide a brief outline of ‘problem-oriented
policing’ (POP) to provide the background and structure of the concept including the ‘SARA’
(Scanning; Analysis; Response; Assessment) (Goldstein, 1990) structure that this research
aims to adopt. With this understood the chapter will then explore the literature to provide an

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analysis to why modern slavery (forced labour and human trafficking) is found among migrant
workers in the UK with the objective that it will help to outline the problem facing
practitioners.
Finally, it will then explore the conceptual challenges in defining modern slavery and forced
labour and steps that have been taken by academics to address them. To keep the study up
to date it will use the Modern Slavery Act (MSA) as the analytical framework rather than the
International Labour Organisation’s (ILO) definition of forced labour which much of the (older)
literature uses as the basis for exploring the topic.
This chapter will conclude by outlining where this study can add to the current body of
research by formulating a suitable research question to take into Chapter Four (methodology)
that will shape how this research will be conducted.
Problem-oriented policing
Problem-oriented policing (POP) is a concept that has been widely accepted by police
agencies and scholars as an effective way of tackling policing problems. In the UK it has been
adopted by almost all police forces to varying degrees and has become increasingly important
as a methodology in crime reduction practice and policy (Bullock, et al., 2006. Tilley, 2011.
Karn, 2013). The origins of POP are found in the works of Herman Goldstein (1979, 1990) who
developed the concept after criticising the Chicago Police Department’s reactive approach
and their focus on efficiency and procedure rather than better outcomes for community
problems. He argued it was proving detrimental to the resolution of local concerns. Instead
he believed that the police should concentrate on improving the effectiveness of reducing the
impact of, or eliminating, problems in the communities they serve. The result was POP.

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POP also challenges the ‘widely held belief that dealing with crime is the sole function of the
police’ (Goldstein, 1977, p. 33). He argued that some problems do not warrant a criminal
justice response and enforcement, however any community concern that leads to demand
for the police should be dealt with using the most effective response. Whether this be the
police or not. Therefore a crucial component in effective POP is the role and engagement of
partners in delivering a variety of initiatives. As Karn (2013 p.20) points out ‘the police do not
possess all the information needed to assess all the problems and their causes, nor all the
means to coordinate and deliver solutions’. This has seen the term ‘problem-oriented
partnerships’ emerge in the UK which saw a statutory footing put on it by the 1998 Crime and
Disorder Act. Therefore the terms ‘problem-oriented policing’ and ‘problem-oriented
partnership’ are often used interchangeably (Bullock, et al., 2006).
Language is somewhat important when discussing POP and not without significance Bullock
et al. (2006) is quick to point out it is not ‘problem solving’ as some scholars have come to
understand the term. Problem solving refers to smaller scale issues such as violence
associated with a particular bar, or the actions of one offender. POP requires a more
systematic analysis and research to finding the ‘root causes’ of a problem in order to develop
effective interventions (Bullock et al., 2006; Weisburd, et al., 2010; Tilly, 2011; Karn, 2013).
This systematic approach is reflected in the ‘SARA’ model of ‘Scanning, Analysis, Response
and Assessment’. The model is a process designed to guide, design and implement crime
reduction strategies and initiatives. It is an iterative approach as outlined by Karn (2013, p.
20);
 Identify community and organisation concerns (Scanning).
 Investigate priority problems, such as what, where, when, who, how and why the
problem is happening (Analysis).

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 Developing tailored, evidenced-based interventions to address the problems
identified and their causes (Response).
 Evaluate the implementation and outcomes achieved (Assessment) and then
redefining and refining those problems and strategies in response to attempts to
addresses them.
Although this approach has received criticism as being too over-simplistic (Bullock, et al.,
2006) it does provide a logical structure and approach to tackling complex problems
encountered by the police. In practice there is evidence to suggest that it is an effective
approach to crime reduction. A systematic review in 2010 of ten rigorous studies identified
an overall “modest but statistically significant impact of POP on crime and disorder” and an
overwhelming positive response by 45 “pre/post comparison studies” (Wiesburd, et al., 2010,
p. 139). However what is also documented in the text is that often the police and their
partners fail to conduct the systematic, in-depth analysis of problems and effectively evaluate
initiatives to document and share lessons learned (Bullock et al., 2006; Karn, 2013).
POP is also linked with other modern policing methods which are worthy of noting as they are
likely to be evident in the case study giving the nature of the topic. These include ‘community-
oriented’ (COP)2 and ‘intelligence-led’ policing (Tilley, 2008). Briefly, intelligence-led policing
is a more traditional approach to policing that focuses the key functions of the police as
identifying, targeting and apprehending serious offenders. In other words catching ‘bad guys’.
2
Often referred to as ‘neighbourhood’ policing in the UK.

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However there has been little involvement by the research community in the “development,
implementation, observation and evaluation” of this method compared to POP and COP
(Tilley, 2008). On the other hand COP is a philosophy that emphasises community
involvement in crime prevention and encompasses a range of styles and models; one being
POP (Karn, 2013; Gill, et al., 2014).
Given the root cause of police demand in Wisbech was the exploitation of migrant workers
by organised crime groups, the role of POP within this chapter is to investigate this problem.
The rest of this chapter will use the literature that has emerged on this phenomenon over the
last decade to answer some of the questions to why.
Modern Slavery and Forced Labour in the UK
This section aims to analyse the body of literature on modern slavery and the exploitation of
migrant workers by gangmasters/labour intermediaries in line with the POP step of
understanding what, where, when, who, how and why the problem is happening (Karn, 2013).
It is widely acknowledge that Anderson & Rogaly’s (2005) ‘landmark’ study in 2005 formed
the foundations for this field of work into forced labour in UK labour markets (Lewis, et al.,
2015, p. 6). Their study focused on four economic sectors where significant numbers of
migrant workers are found. These are; construction, agriculture/horticulture, contract
cleaning and residential care. They are often referred to as the “3 D’s” of Dirty, Dangerous,
and Dull (Craig, 2010). What Anderson and Rogaly (2005) uncovered during their investigation
were forms of coercive recruitment and employment practices that many regard now as
severe forms of exploitation, amounting to forced labour. This study has since sparked a
growth in research - predominately driven by the Joseph Rowntree Foundation (JRF). In 2010
JRF commissioned a number of studies to understand the nature, scale and scope of forced

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labour in the UK. This stream of work, along with others, has helped to advance both the
conceptual understanding of forced labour and how it can be explored within the analytical
framework of the MSA. (Rogaly, 2008; Craig, 2010; Skrivankova, 2010; 2014; Strauss, 2012;
Lewis, et al., 2015; McCollum & Findlay, 2015).
Before analysing and discussing how the literature defines and conceptualises modern slavery
it is worth outlining the explanatory framework for why such illiberal practices occur in the
UK labour market. It has been strongly argued that neoliberal market polices and a globalized
competitive market economy have led to contemporary forms of slavery existing in modern
UK labour markets. These policies have seen significant shifts in power from employee to
employer with ‘managers right to manage’ restored and the erosion of collective power
through obstructing unionisation (Lewis, et al., 2015). This framework is neatly summarized
by Watts (cited in Strauss, 2012, p.144);
“An exemplar of neoliberal policy environment in which labour markets are
characterised by short-term employment, low levels of unionisation, individualised
and competitive employment relations, high levels of labour market inequality, and
strong private sector involvement in placing workers in employment”. (Watts, 2009)
Although opinions differ (e.g. Skrivankova, 2014), much of the literature highlights the
emergence of complex supply chains and labour intermediaries which have resulted in the
view that modern slavery is a hidden crime (HM Government, 2014). Plant (2014, p. 2)
describes how “temporary or contract workers with perfectly lawful contracts” are at risk of
exploitation due to offenders taking advantages of loopholes in the system. Skrivankova
(2014, p. 10) explains that within complex and lengthy supply chains the “forced labour
dimension of the chain tends to be several levels removed from the core labour force” making
it challenging to identify who is responsible for the exploitation. Often it ‘makes business

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sense’ with both the labour provider and labour consumer benefiting from revenue
generation and cost reduction (Skrivankova, 2014). This is particularly evident in the
agricultural sector which has seen intensified market and workplace regimes and the return
of the gang labour system to provide a flexible and compliant workforce come harvest time.
The tragedy at Morecombe Bay not only highlighted the existence of modern slavery in the
UK but also the exploitative nature of the gangmaster system. In the response to this event
the UK introduced the Gangmasters Licensing Act in 2004 followed by the establishment of
the Gangmasters Licensing Authority (GLA) in 2006 to tackle exploitation in the agricultural
sector. The GLA currently protects approximately 500,000 workers through their licensing
scheme with a small number of enforcement officers (GLA, n.d.).
The reemergence of the gangmaster system is rooted not only in neoliberal policies,
globalisation and agency work but also the ‘intensification’ of agriculture workplace regimes.
Intensification in this sector is defined by Rogaly (2008, p. 498) as “efforts to speed up,
enhance or reduce the risks of biological processes”. However this is not confined to technical
innovations but also “innovations in labour control”. These “just in time strategies” (Lever &
Milbourne, 2015, p. 3) include methods to exploit workers’ vulnerabilities to ensure a
productive and compliant workforce to enable suppliers to meet the ever increasing pressure
and demands of the powerful UK supermarkets (Anderson & Rogaly, 2005; Rogaly, 2008;
Craig, 2010). Lever & Milbourne’s (2015) recent study into the workplace regimes in the meat-
processing industry found evidence of the practices that resulted in what they argued as
‘compartmentalisation’ and ‘self-exploitation’;
“Self-exploitation among the migrant workforce is linked to the strategies of
employers and the organization of work, and that hyper-flexible work patterns have

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reinforced the special and social invisibilities of migrant workers in this sector”. (Lever
& Milbourne, 2015, p. 1)
Jobs in these sectors are often time and place bound thus the demand for labour that is highly
flexible and willing to move. This emphasizes why migrant workers are often more desirable
as they are often more willing than local ‘fixed workers’ (Rogaly, 2008; Lever & Milbourne,
2015; Lewis, et al., 2015). This view is reflected in a number of studies that engaged with
labour providers who evidence the desire to employ migrant workers over British nationals
due to their perceived work ethic (McCollum & Findlay, 2015). It is also well documented that
the role of employment agencies have been pivotal in facilitating exploitation in UK labour
markets. This is predominately because they have been able to exploit the vulnerabilities that
comes with agency working and zero hour contracts;
“Agency workers have significantly fewer rights than those that are directly employed;
they can be hired on lower hourly rates and on worse terms and conditions and they
do not have any rights to benefits such as overtime and sickness pay. They are also
less likely to be member of a trade union”. (Lever & Milbourne, 2015, p. 2)
Therefore another key element of the explanatory framework is the ‘inexhaustible potential
pool of labour’ which has emerged from the expansion of the EU A8 and A2 accession
countries in 2004 and 2007 (Lewis, et al., 2015). Although the native population are also
vulnerable to modern slavery due to the structures and regimes that have been discussed,
migrant workers are consistently found to be a group that have become implicit in cases
ranging from minor forms of labour exploitation to more extreme forms - some amounting to
forced labour. To understand why, Lewis et al. (2014; 2015), took the approach of viewing
exploitation and forced labour through the lens of ‘precarity’ and introduced the concept of
‘hyper-precarity’. This concept argues that precarity is not just a place in the jobs market and
needs to be viewed both in the ‘economic and social context’ to understand why individuals

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find themselves trapped in situations of forced labour (Lewis, et al., 2015, p. 149). They
highlight there is a two tier labour market with those who are able to embrace and enjoy this
new flexible working market while there are others, characterised by migrant workers who
experience high job insecurity and are unable to negotiate their terms of work with
employers. Precarity provides a useful lens when discussing what makes victims not only
vulnerable to severe forms of exploitation, but why they also may be complicit in their own
exploitation (see both Lever & Milbourne, 2015 and Lewis, et al., 2015 studies).
This section has briefly outlined the problem facing law enforcement and why it occurs in UK
labour markets. It has highlighted challenges such as the current labour market structure and
regimes enabling modern slavery and exploitation to occur - in some cases promoting it as it
makes ‘business sense’ to (Skrivankova, 2014). However the fundamental challenge for law
enforcement is when the ‘criminalised act’ of forced labour has occurred as appose to severe
exploitation and breaches of labour law which fall out of the scope of policing and into the
scope of regulation. The next section will explore the new MSA and attempt to deconstruct
the core offences using the literature to highlight potential challenges facing successful
prosecution.
Conceptual challenges to the Modern Slavery Act 2015
There was an obvious need by law enforcement agencies for much simpler and effective
legislation to tackle this complex crime and protect vulnerable members of society against
slavery and its contemporary forms. So, after years of campaigning, the MSA was brought into
law in 2015. It is “An Act to make provision about slavery, servitude and forced or compulsory
labour and about human trafficking” and contains two core offences (Modern Slavery Act,
2015);

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1) Slavery, servitude and forced or compulsory labour
(1) A person Commits an offence if-
a. The person holds a person in slavery or servitude and circumstances are
such that the person knows or ought to know that the person is held in
slavery or servitude, or
b. The person requires another person to perform forced or compulsory
labour and the circumstances are such that the person knows or ought to
know that the person is being required to perform forced or compulsory
labour
2) Human trafficking
(1) A person commits an offence if the person facilitates the travel of another
person (“V”) with a view to V being exploited
The prohibition of these two offences have both been established in international law for
decades, however they have been seen as separate acts both in national and international
legislation. Despite them both being recognised as forms of modern slavery, it is vital to
distinguish between the two as they are not the same - but they sometimes overlap
(Skrivankova, 2010). Human trafficking is a process in which the purpose is to bring someone
into a situation of exploitation (Chandran, 2011). On the other hand forced labour is at the
most extreme end of labour exploitation and is described as ‘a distorted employment
relationship where a worker is subjected to severe exploitation either by their direct employer
or by an intermediary’ (Skrivankova, 2014, p. 5). Due to this overlap, there is often confusion
between the two;
“While forced labour is often conflated or confused with human trafficking – the
coercive transit of people for the purposes of exploitation – not all forced labour
results from trafficking, and those responsible for deceptive border crossings may or
may not be linked to subsequent exploitation”. (Lewis, et al., 2015, p. 1)
By bringing these two offences together the MSA has help to it resolve longstanding debates
and challenges for researchers, analysts, policy makers and lawyers on the relationship

0909274 16
between these two concepts (Strauss, 2012; Plant 2014). One key issue being the “elision3 of
forced labour other than as an outcome of trafficking” (Strauss, 2012, p.142) which has often
put victims of forced labour who were not trafficked at a disadvantage. This is particularly
important when discussing migrants from EU accession countries who as a group have
experienced high levels of exploitation despite the right to free movement in the UK (Craig,
2010; Skrivankova, 2010; Strauss, 2012; Plant, 2014).
The ILO definition of forced labour which underpins the offence in the MSA and is routinely
used by scholars as the analytical framework for research (Lewis, et al., 2015). It is defined it
as;
“All work or service which is enacted from any person under the menace of any
penalty, and for which the worker has not offered himself voluntary” (ILO, 1930)
There are two features to this definition; “the exercise of coercion and the denial of freedom”
(Skrivankova, 2010). Coercion (or menace) is defined as “any situation in which the person
has no real acceptable alternative but to submit to the abuse involved” (ILO 2005, p.21). This
also includes subtle forms of menace and coercion, including of a psychological nature.
Coercion is a seen by the ILO as a key factor in separating forced labour from general forms
of labour exploitation. Denial of freedom, otherwise described as ‘involuntariness’ is the
inability for the victim to withdraw their labour and so absent of ‘freedom of choice’.
3
The process of joining together or merging things, especially abstract ideas:

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However, it is widely argued that the binary framing of forced labour and what constitutes
coercion (opposed to consent) and involuntariness (as oppose to freedom) are unhelpful in
defining the realities and experiences of victims. Critics point out that constructing a distinct
category for forced labour separately from other forms of labour relations only serves to
enable the criminalisation of perpetrators rather than challenging the whole system and
structures discussed in the previous section. Moreover it ‘narrows down, simplifies and
reduces the concept to such an extent it becomes disconnected from the actual complexities
of exploitation’ (Lewis, et al., 2015, p. 149) and is therefore only applicable in the worst of
cases avoiding the more mundane forms of forced labour. Some writers have argued that
statutory protections for workers are inadequate with Gallagher (cited in Plant, 2014, p.11)
going further and arguing that they only give the ‘illusion’ of legal protection. Most notably
because the definition excludes the economic necessity of an individual as a form of coercion.
For example, the need to pay debts to someone other than an employer, often to a web of
debtors.
Overcoming this issues, scholars have found a theoretical way out of this impasse by using
the concept of ‘unfree labour’. This concept situates ‘unfreedoms’ in opposition to ‘free
labour’ that is characterised by decent work and free contractual relationships (Strauss,
2012). Unfree labour is based on Marx’s idea that workers are able to commodify and sell
their labour through entering a contract with a purchaser of labour for an agreed wage. On
the other hand unfree labour is described by Morgan and Olson (cited in Lewis et al., 2015,
p.587) as;
“That labour is not free to enter into alternative employment relations; that labour is
not free to exit current employment relations; and that the terms and conditions of

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current employment contribute to the first and second criteria and themselves
onerous”.
What this does is reflect the real life, highly constrained choices of individuals and lack of
alternatives that makes them vulnerable to exploitation and in many cases likely to be
complicit in the abuse due to ‘no real or acceptable alternative’ (Lewis, et al, 2015). This is
because victims are often find themselves ‘bound’ to their exploiters not by chains, but by
accommodation, transport, work, and debt. These dependencies significantly reduce freedom
of choice to pursue other employment opportunities as well as acting as an abstract form of
coercion resulting in, for some, a compulsion to engage willingly with forced labour practices
(Lewis, et al., 2015).
These complexities therefore lead authors like Lewis et al. (2015, p. 152) to conclude that it
is impossible to define forced labour “against other form of exploitation”. However, to better
understand what constitutes forced labour in practice the ILO in 2004 developed six indicators
of forced labour which it later expanded into eleven in 2012. These were recommended to be
included in the MSA during the evidence hearings (Modern Slavery Bill Evidence Review,
2013). These indicators provide a useful framework to identify whether a person can
legitimately be classed as having experienced forced labour. Lewis, et al. (2015) uses these
indicators described in table 1 to access whether the particpants of their research had
experienced situations of forced labour.

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Table 1: ILO Indicators of Forced Labour
ILO (2005) 6 Indicators ILO (2012) 11 Indicators
Threats of actual physical harm to the worker Physical and sexual violence
Restriction of the movement or confinement to
the workplace
Restriction of movement
Debt bondages Debt bondage
Withholding of wages or excessive wage
reductions
Withholding of wages
Retention of identity documents Retention of identity documents
Threat of denunciation to the authorities Intimidation and threats
Isolation
Abuse of vulnerability
Abusive working and living conditions
Excessive overtime
Deception
Despite these indicators providing a useful tool, they still do not help to resolve the much
debated issue of what definitively separates forced labour, an act that requires a criminal
intervention, and situations of exploitation that are covered by labour laws. Chandran (2011,
p. 53) neatly describes this issue as a ‘definition vacuum’. However like others she points to
the work by Skrivankova (2010, p.5) whose research attempted to answer the question;
“Where does decent work end and labour exploitation begin, and where does labour
exploitation end and forced labour begin?”.
Out of this work she developed the concept of a ‘continuum of exploitation’ to address the
complex reality of forced labour, labour exploitation and human trafficking (Skrivankova,
2010). This concept was developed to ‘address both the symptoms and the causes and brings
in labour law and enforcement of labour rights alongside criminal justice interventions’
(Skrivankova, 2014, p.5). It also recognises that at the time human trafficking is a process and
the diagram below (Figure 1) indicates where trafficking is present, where it is not, and where
forced labour is one of its outcomes.

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Figure 1: Skrivankova's Continuum of Exploitation
However, it is made clear by Skrivankova (2010) that it doesn’t replace the missing definition
of exploitation. As Chandran (2011) points out it may provide a useful tool for practitioners
to identify remedies when they uncover cases of exploitation. Therefore it may be useful as a
tool within the POP framework when analysing and formulating a response to potential cases
of modern slavery, or lesser forms which fill the space between the “desirable (non-
exploitative work) and the unacceptable (forced labour)” (Chandran, 2011, p. 58).
Nonetheless, this concept has been regarded as a major step in understanding the topic and
more reflected of the realities of those that not only experience exploitation but how they
enter situations and at times are willing to participate. According to Lewis, et al. (2015) the
continuum also provides an additional and important conceptual way forward from the binary
world of the ILO definition. They provide a helpful critique of the concept that also
summarizes a lot of what has been discussed in this chapter;

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“It recognises that some enter labour situations from the outset feature highly adverse
conditions of little or no pay, debt or threats. Others enter work on the expectation or
promise of decent pay and conditions, but find themselves constrained and
deteriorating circumstances that close down avenues of exit. It is thus difficult to draw
a line between exploitation in the form of substandard working conditions or the
abuse of workers’ rights and forced labour. The continuum approach additionally
highlights the relationship between the more general exploitation in the labour
market and the existence of forced labour”. (Lewis, et al., 2015, pp. 152-153)
Lewis, et al. (2015) provides the most recent addition to this conceptual approach of forced
labour. Although their work focuses on victims with the particular vulnerability of ‘irregular
status’ such as refugees and asylum seekers, their critique (informed by interviews with
victims of forced labour) has led them to combine the concepts of unfreedom and the
‘continuum of exploitation’ to put forward the idea of a ‘continuum of unfreedom’. This
concept consists of four dimensions supported by their empirical evidence (Lewis, et al., 2015,
p. 156);
1. No real acceptable alternative to entering and continuing in exploitative labour.
2. Withholding of a minimum, living or social wage.
3. Existence of a web or chain of fixers, agents and beneficiaries.
4. Wider existential feelings of coercion, menace and involuntariness in relation to social
reproduction and social life.
These elements also bring together all that has been discussed so far within this chapter and
provide a good up to date framework in which to understand the realities of forced labour
and modern slavery in the UK. What it hopes to have identified is the significant challenges
facing the implementation of the MSA and securing prosecutions due to the vast complexities
and realties of modern slavery. It has evidenced that within the UK, labour markets regimes
have created an environment where exploitation and forced labour are able to flourish and
in some cases make ‘business sense’ (Skrivankova, 2014). Furthermore to define and evidence

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when forced labour has occurred instead of general unsavoury working practices adds to this
challenge.
One of the key objectives of this chapter was to develop a suitable research question to take
into the next chapter, drawing on what has been discussed. Therefore to add to this growing
body of literature this research aims to answer the question;
‘What are the realities and practicalities of enforcing the Modern Slavery Act?’
With the question set, the next step of this dissertation is to determine a suitable
methodology in which to approach and answer it.

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Chapter Two: Methodology and Results
This chapter will outline the rationale for the philosophical stance and approach of the study
which informed the methods that were implemented during the course of the research. In
order to achieve the aims and objectives of this research and answer the research question,
both primary and secondary research methods were adopted to understand the practical
realities facing practitioners in tackling modern slavery.
As this dissertation has based itself on the framework of problem-oriented policing and, with
the current emphasis in UK policing to understand ‘what works’, it was initially attractive to
attempt to conduct an evaluation of the events in Wisbech (as described in the introduction).
However, given there is still limited research on what the practical challenges facing police
practitioners are in tackling modern slavery, it was challenging to define measures in which
to evaluate success or failure against. Furthermore, there are practical challenges to this
approach given the size and scope of this study relative to the size of the events and
complexities involved. This includes the ability to access confidential data and systems and
securing resources to conduct a successful evaluation to a high standard that would perhaps
meet the criteria of Wiesburd, et al. (2010) systematic review.
Instead of an evaluative methodology, this research made the decision to take an exploratory
approach to meet its aims and objectives. Explanatory research is, according to Matthew and
Ross (2010, p. 57) usually research of personal interest and concerned with taking the initial
steps to;
“Understand or explore some social process or phenomenon when you (maybe as an
individual, but possibly the social research community to which you belong) have
limited prior understanding of the area or issues.”

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Given the complexities and the size of the phenomenon the research has framed the events
of Wisbech within a ‘case study’. A case study is an analysis of a person, event, policy,
institution or any system which is studied holistically by one or more methods. The case (or
cases) is a specific enquiry of a phenomenon, usually in considerable depth and within
boundaries, to illuminate, explain and draw some conclusions (Gomm, et al., 2000; Matthew
and Ross, 2010. By adopting this approach therefore it has allowed the research to narrow
down its scope and boundaries to the events in Wisbech from 2012 to 2016 when the court
case was concluded.
Although there is an argument that a case study is a distinct research paradigm in itself
(Gomm, et al., 2000), this dissertation will follow the standard research process (Hart, 2005)
to establish its methodological assumptions and beliefs of the study. This is known as the
paradigm consisting of the ontological and epistemological standpoints that outline how the
world is viewed (ontology) and how we know that world (epistemology) and the nature of
knowledge (Hart, 2005. Matthew and Ross, 2010. Becker, et al., 2012).
Ontology is the study of reality and within the social sciences it is described by Mathew and
Ross (2010, p.23) as the ‘way in which the social world can be seen to be and what can be
assumed about the nature and reality of the social phenomena that make up the social world’.
The first step is to establish whether the social phenomenon that is being observed can be
measured in the same way as the natural sciences since they have an existance of their own.
Social scientists who believe this take an ‘objectivist’ stance to their research (Hart, 2005).
Arguably this approach is aligned with the concepts of ‘problem-oriented’ and ‘evidence-
based’ policing which promote the use of quantative methods and statistics to evaluate

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whether an inititive has been a success. For example, crime is recordable and therefore an
inititive can be measured on where there is a reduction or increase in crime.
However, when analysing the current body of literature on modern slavery in the form of
forced labour amongst migrant workers in the UK it is evident that a social phenomenon is
more often than not viewed within a ‘constructivist’ research paradigm. This paradigm takes
a different view in that social phenomenon are a construct that are constantly being reviewed
by those involved in them (Matthews & Ross, 2010). Within the literature this is evidenced by
the work to conceptualise the topic rather than attempt to measure it. This is understandable
as despite modern slavery being framed within rigid binaries (O'Connell Davidson, 2015), in
reality it is often void of the ‘true or false’ (Hart, 2005) answer. This not only presents a
challenge to practitioners but also researchers who require this for an objectivist study to
take place. This issue is presented throughout the last chapter as modern slavery is open to
different interpretations and difficult to define. For example, where does labour exploitation
end and forced labour begin?
Consequently, modern slavery is a concept that has been continually constructed through the
interpretation of ‘social actors’; researchers, policy makers and practitioners. Through their
social interaction and reflection they bring their own meanings and understanding to what,
how and why modern slavery and its many forms occur in their constructed reality. As a social
phenomenon it deviates from the norms of society reflected by the laws and institutions put
in place to reduce its prevalence e.g. in the police and their partner agencies. Focusing on the
social actors to be engaged within this study, ontologically practitioners exist in a society
constructed by their own experiences (Lawson, 2014, p. 270) and as social actors are
constantly reviewing and reworking structures based on interactions and reflections that will

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enable them to successfully understand and tackle this crime. By its nature, the police force
have been constructed to enforce the norms of society as social actors therefore reinforcing
the rational for a constructivist methodological approach to this research (Lawson, 2014). In
contrast, an objectivist stance would not enable this study to meet its objectives as the
interpretations of practitioners cannot be measured. With this established, the next part of
the process is to form the epistemological view of reality.
As the focus of this case study is to explore the experiences of practitioners, it is these social
actors (practitioners) that are appropriate for this study and will enable the research to bring
its own meanings and understandings to the concept of modern slavery through a policing
lens. The epistemological position it asserts is of an interpretivist view since the role of the
researcher in this study is to collect and interpret knowledge from the social actors and their
interpretation of tackling the social phenomenon that is modern slavery. What is interesting
is that Lawson (2014, p.270) highlights there is a need for more interpretivist research into
policing.
“Policing research will benefit from a sociological worldview, particularly critical
research using an interpretivist ontology”.
A typical interpretivist approach is to collect qualitative data as opposed to quantitative data
since it is rich in detail and description (Matthews & Ross, 2010, p. 142). Qualitative methods
of research are, according to Mathews and Ross (2010, p.142), predominantly concerned with
“stories and accounts including subject understandings, feelings, opinions and beliefs” and
therefore are consistent with the ontological (constructivist) and epistemological
(interpretivist) stance of this research. Again reflecting the body of literature, they
predominately adopt qualitative over quantitative methods of data capture and analysis.

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There is a stand out exception - the work conducted by Silverman (2014) used complex
statistical methods to produce the figure for the Home Office of 10,000 to 13,000 victims of
modern slavery in the UK. However, given the researcher does not have the capability to
conduct such sophisticated and advanced methods, this reinforces the decision to adopt a
qualitative approach.
With the rationale and philosophical standpoint established, the next step is to select and
confirm the primary and secondary research methods selected by the researcher and outline
the strategy to put them into practice. As outlined in the introduction, the research aims to
develop an understanding of what the challenges facing the police are when tackling modern
slavery and what can be learned from practitioner experiences. In addition, the research will
adopt an exploratory approach to its design which lends itself well to a qualitative approach.
Before discussing the primary research that was carried out to inform the case study,
secondary data was gathered to help inform the understanding of the phenomenon as
outlined in the literature review and reflected in the discussion. There are a number of
different types of secondary data, but predominately they can be summarised as “data that
a researcher uses which has already been produced by others” (Matthews & Ross, 2010, p.
51). The secondary research element of this dissertation consisted of a literature review
which identified and analysed publications from a range of academic journals, books,
government and non-governmental organisations, websites and news articles. The majority
of academic literature was accessed through Anglia Ruskin University’s library either obtained
as a physical or online source.
Online searches were conducted using for example terms such as ‘modern slavery’, ‘modern-
day slavery’, ‘modern slavery in the UK’, ‘forced labour’, and ‘human trafficking’. An attempt

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was made to select the most recent sources and literature ranges from 2004 - 2016.
Unfortunately not all desired documents were obtainable within the level of access and
timeframes of the study as well as within its budget. Nonetheless, secondary sources were
able to provide valuable insight into the topic as well as offer the framework for the study and
inform the method and structure of the primary research that was conducted with
practitioners.
Within the social sciences there are varying types of qualitative methods that can be adopted
by the researcher. As this research looks to capture the experiences of practitioners, primary
research needs to be undertaken by the researcher. The purpose of primary research is to
capture data specifically for the research usually to find out something new about the topic.
The method of primary research that was used in this study was in the form of face to face
‘semi-structured interviews’ with participants. Semi-structured interviews are considered to
be one of the main research methods adopted when conducting qualitative research (Becker,
et al., 2012). This can been seen in the body of literature where it has been widely used to
capture views ranging from victims of modern slavery, labour providers to experts (Anderson
& Rogaly, 2005; Lever & Milbourne, 2015; Lewis, et al., 2015).
The rationale behind choosing semi-structured interviews was to acquire in-depth responses
to questions. In contrast, structured interviews not only restricts answers, but are more suited
to a quantitative methodology and analysis (Matthews and Ross, 2004; Becker, et al., 2012).
Semi-structured interviews allow the interviewees to ‘speak for themselves’ in their own
words rather than be restricted to binary answers. Interviews, like Skrivankova’s (2010)
concept of exploitation, can be viewed as a “continuum” ranging in structure and flexibility to
change and adapt through the course of the interview (Becker, et al., 2012, p. 291).

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When conducting interviews it is important to consider a number of things as outlined
through the literature on this method. There is an emphasis on the importance of establishing
a rapport with the interviewee and creating a good atmosphere where their views and
opinions are valuable. Becker, et al. (2012, p. 292) highlight that the time to start building
rapport “is as soon as the relationship begins, which may be over the telephone when
negotiating and arranging access”. Before each interview a brief meeting was held with each
participant to outline the purpose of the study. This meeting not only provided this
introduction, but also gave some insight into how the questions for each participant could be
structured based on their role within the case study.
Another challenge is to ensure that the interview stays on track. To maintain control,
questions for the participants were designed around the SARA (Scanning; Analysis; Response;
Analysis) structure. This informed the development of an interview guide that was referred
to throughout the interviews (appendix A). It outlined a number of core and supplementary
questions in case the conversation ran dry (Matthews & Ross, 2010). This enabled the
interview to explore the case with the participant through a structured process that ensured
all the desired topics were covered. Furthermore by adopting this approach the interviews
were able to provide the assessment element of the SARA model as participants were able to
reflect on the challenges they faced, whether they were able to overcome them or not and
what they would do differently in future.
The recording of the interviews was an important element of this method as it was “essential
to have a comprehensive record” for further analysis (Becker, et al., 2012, p. 292). Each
participant was asked for their permission for the interview to be recorded and stored, which
was facilitated using a mobile phone application. There were risks in only using one device,

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however, it was rigorously tested to ensure reliability. Afterwards, the interview was
transcribed as this allowed the opportunity to turn the unstructured ‘raw data’ obtained into
structured data to enable methods of analysis to take place. For this research a ‘thematic
analysis’ was conducted to interpret the data and identify key issues and themes in regards
to the topic (Matthews & Ross, 2010, p. 373).
Participants for the interviews were selected using a ‘snowball’ method of sampling. Snowball
sampling is a ‘non-probability’ method where the process of choosing respondents based on
previous respondents’ recommendation (Matthews & Ross, 2010; Becker, et al., 2012). This
method is particularly useful when the population is hard to find. In this case, practitioners
from Cambridgeshire Constabulary involved in the two Wisbech operations were part of a
‘hidden population’. Fortunately, the first interviewee was able to identify other potential
participants which in turn enabled the research to conduct a small number of in depth
interviews covering a range of experiences and insights into the events of Wisbech.
Throughout the research there were a number of ethical implications to consider given the
nature of the topic and the method adopted. The first and most important was to obtain
permission from the organisation to conduct the study and to ensure that any risks were
assessed and the study was practically viable. Permission was sought and given by the Head
of Local Policing to obtain informed consent (Matthews & Ross, 2010, p. 73). An ethics form
was then sent to the faculty of Arts, Law and Social Sciences Ethics Committee to ensure that
the research adhered to Anglia Ruskin’s University’s (2011) Research Ethics Policy.
However, as Banks (cited in Becker, et al., 2012, p.58) points out there is a “tendancy to
associate ethics in research with procedures for gaining institutional approval before
commencing emperical studies invoving humans”. There also needs to be respect and

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protection for each research particpant, public and professional responsibility of researchers
themselves and finally honesty in communication. As a consequence of this, before each
interview each participant was issued with a consent form and notified that they could
withdraw at any point from the study if they wished (appendix B). Furthermore each
participant was anonymised and only identified by their organisation. After each interview
the transcription was submitted to the participant to ensure they had a copy of what was
recorded. The recording was then subsequently deleted. Once this dissertation has been
completed it will then be submitted to each participant to obtain their permission to
disseminate it further.
Results
Unfortunately, not all those contacted were able to take part in the research given the
timescales and availability. In total four practitioners were interviewed, three from
Cambridgeshire Constabulary and one from Fenland District Council (FDC). Each participant
was allocated a letter to keep them anonymous in line with the established ethics of the study
and to identify them through the text they will be referred to ‘practitioner’ ‘A/B/C/D’ rather
than their job title or rank. There are a number of core themes shared by the participants,
however there are also some that are unique to each interview.
 Practitioner A provided a broad overview of both the partnership and the operation.
They provided a narrative that outlined how the situation developed in Wisbech from
identifying crime trends and links to exploitation, to methods of engagement with
victims and the challenges in securing a prosecution (appendix C).
 Practitioner B’s interview was more focused and discussed their experiences of
involvement in the operation. They provided insight into what methods, strategies

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and approaches took place once offenders were identified and the realities of
conducting an investigation and taking it to court (appendix D).
 Practitioner C was able to give a board overview of the operation as well as a strategic
view of how Wisbech had influenced the Constabulary’s understanding of modern
slavery and how this leaning has prepared them for the introduction of the MSA
(appendix E).
Although the focus of the interviews was to collect experiences from Cambridgeshire
Constabulary practitioners, through the snowball methodology, the opportunity to interview
a member of FDC (who was pivotal in the partnership working) was presented.
 Practitioner D provided a similar narrative to practitioner A by outlining the problems,
approaches and outcomes of the partnership. However they also provided valuable
insight from a non-police perspective that emphasised that importance of a multi-
agency approach to tackling this phenomenon (appendix F).
Upon reflection, it would have been ideal to have conducted more interviews of practitioners
from other agencies such as the GLA, the fire service and housing officers inside the council.
However the interviews that were conducted provided a broad and insightful overview of
what occurred in Wisbech and the two operations.
In conclusion, what this chapter has outlined is the rationale for the philosophical standpoint
of this research and the chosen methods as well as providing a brief overview of the results.
It also considered other approaches, however, by both recognising the objectives of the study
and taking into account the approaches of the wider literature it is confident that it has
outlined the most suitable approach.

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Although only four interviews were completed, they provided a rich source of empirical data
in which to meet the objectives of the study. The next chapter will outline the findings from
the interviews and the thematic analysis that captured the practical realities facing
practitioners when tackling a potential case of modern slavery amongst a vulnerable migrant
workforce.

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Chapter Three: Findings and Analysis
This chapter outlines the findings of the interviews that were conducted with the four
participants and the thematic analysis that took place to categorise the data given the volume
obtained4. The case study consists of two operations that are linked. The first, ‘Operation
Pheasant’, was an operation that began in 2012 to tackle rogue landlords and the outcomes
from the exploitation of migrant workers in the town. The second operation, ‘Operation
Endeavour’, was established from intelligence generated from Operation Pheasant through
engagement with occupants living at a number of unlicensed ‘Houses of Multiple Occupancy’
(HMOs). This led to prosecution of a gang of four offenders of Lithuanian nationality in 2016
for charges relating to Human Trafficking, fraud and unlicensed gangmaster offences (The
Guardian, 2016). To assist in the language of both the findings and the discussion, Operation
Pheasant will be referred to as the ‘partnership’ whereas Operation Endeavour will be
referred to as the ‘operation’. When both are considered the term ‘investigation’ will be used.
Establishing Trends through Data
It was clear throughout the interviews that the full picture of modern slavery did not emerge
straight away and it was only through taking a holistic view did they recognise that the
problems were linked to the exploitation of migrant workers. The partnership started by
4
There were a number of common themes identified however it wasn’t possible to cover all within this
dissertation. For example, as practitioner B highlights; “The victim issues could go on to be a dissertation in itself”.
However, the benefit of the interviews being transcribed is that they allow others to conduct their own analysis
of the interviews and draw further conclusions. Therefore they have been included in the appendix of this paper.

0909274 35
looking at two events that had spiked in the town; homelessness amongst migrant workers
and theft.
“The police identified that there was a rise in shoplifting and is wasn’t just alcohol
being stolen it was food as well. So that’s quite a clear indicator of poverty. At the
same time the council was aware of an increase in rough sleeping…the idea was to get
together and think what’s the link between these two? Why are we seeing an increase
in people stealing food and why are we seeing an increase in rough sleeping, is there
any correlation?”. (Practitioner D)
Addresses given for those stealing food were the same as those gathered by the council at a
homeless shelter. Further intelligence indicated that many Lithuanian and Latvian workers
had been illegally evicted from these addresses. They turned out be Houses of Multiple
Occupancy (HMOs) and became the focal point for the investigation as it was concluded they
were a source of high demand for the police and other agencies including fire, council and
local charities.
“We identified that there was a link between the number of incidents we were
attending and the locations being over crowded houses. When we started exploring it
with them [FDC] and the fire brigade we were going to the same over crowded housing
locations”. (Practitioner A)
Establishing the link required analysing the available data to the partnership. This presented
the first major practical challenge for the partnership as sources of information were held on
different systems within different organisations. However they were able to overcome this
through information agreements, willingness to share, and the computers system ‘ECINS’ – a
information sharing platform for communities and partnerships (Empowering Communities,
2015).
“We have information sharing agreements, so we can share that within that circle of
trust quite freely”. (Practitioner D)

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“Most of the data on overcrowded housing is all dealt with by the council [so we] went
to the Peterborough city council housing officers and said where are your
overcrowded houses? They gave us a list of top ten. When we then transferred this
onto our crime system. That’s where all our crimes were happening”. (Practitioner A)
By overcoming these issues and transferring the data onto the crime system from the council
database the police were able to correlate a range of crimes that were occurring at the
addresses including two murders, incidents of domestic violence, burglary and theft of
passports, as well as incidents of noise complaints and anti-social behaviour. The partnership
concluded that these were overt signs that exploitation was taking place. This directing the
partnerships resources on investigating these properties and engaging with the occupants
was important. What was uncovered through the process was that the houses and the
occupants were under the control of organised crime groups.
Engagement with Victims
Engagement initially started by a number of informal visits by officers but soon became
organised with multiple agencies continuously visiting the properties. A number of key
themes were identified from the interviews that centred on building trust and confidence
with the occupants while attempting to overcome a number of barriers including mistrust of
authorities, language, and the tactics employed by the offenders to disrupt the investigation.
“We quickly realised that vulnerable people won’t, especially if their first language
isn’t English aren’t going to come running to your door with a list of issues…these
issues were very hidden”. (Practitioner D)
There was a belief that early on victims were mistrusting of authorities and were unlikely to
engage with the authorities unless it was for something serious.
“They [victims] aren’t coming forward. It’s only when they get beaten up or their
passport is used for fraud etc. do they start becoming vocal”. (Practitioner A)

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At the beginning of the investigation, there was a lack of understanding that occupants were
potential victims of modern slavery by attending practitioners.
“The casual attendees such as the house enforcement officer and that would just say
they are all roughs…and would treat the person like they had something to hide rather
than them being a victim. So all the previous times we treated them as hostile
offenders…they were actually victims who were scarred of repercussions”.
(Practitioner A)
What was clear from all the interviews was that to overcome this the investigation took a
‘victim led’ approach that recognise the vulnerabilities and realities of the migrants’ lives. This
approach focused on establishing trust and confidence with the occupants to obtain
intelligence and cooperation. To achieve this they conducted multiple visits to the property
and gain entry to the houses by making gradual improvements to the properties.
“We thought let’s take a victim type approach…let’s look at the properties and make
sure they’re safe, let’s strike up a conversation with those people in the property to
say look, we’re here to help”. (Practitioner D)
“We would keep going to the same address and we would progressively make
improvements to the house. So first of we went and there would be some rubbish out
the front so the [Detective Constable] would get that cleared up. There would be
dodgy boilers so the fire brigade would use their powers to ensure it was safe, they
put smoke alarms in and you know there would be mould on the wall so we would get
hold of the landlord”. (Practitioner A)
A tactic was to go in plain clothes rather than uniform to not be intimidating and create an
environment of informality. It was within these visits that they engaged in conversation and
started to build a picture that underlined the early links between the occupants and their
exploiters. This process enabled the partnership to gain trust, confidence and build a rapport
with the occupants who began to open up about their experiences. This gave the partnerships
understanding, not only of the root causes of problems in the town, but also who was
facilitating the exploitation.

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Victims to Court
For the operation it was vital to get victims to court. Given the length of the trial it was
important that the team stayed engaged with the victims and provided support - despite it
being costly to the organisation. For the operation they introduced a new specialised role of
a ‘victim contact officer’ who was responsible for maintaining the welfare and relationship
with victims. This is something Practitioner B states as something Cambridgeshire
Constabulary has been successful with compared to other forces as they invested in
continued support for victims to build up a relationship.
“You just can’t pick up language and talk to people via an interpreter over the phone.
It doesn’t work, they don’t buy into it, you don’t get any emotional connection. You
have to use a human being. And if that means I’m spending an arm and a leg with an
interpreter for two days and it’s the same interpreter so the victim knows who they
are dealing with, well that’s what I’ll do…so we’ve got 100% success rate in getting all
our victims to court…all from 2013 and given the fact we’re now 2016 and everyone
has moved on with their lives”. (Practitioner B)
However there are some considerations with the type of relationship the police built with
victims that they had to be aware of come prosecution. Practitioner B highlighted the
challenges they received from the defence and the importance of documenting all interaction
that occurred to mitigate this challenge.
“The defence will be saying you conversed the victims into making a statements…they
were saying before you even went through the door you were calling them victims,
my client was helping them out, yes he was taking a cut but that’s good business”.
(Practitioner A)
“You’ve got to use a script because…we need to show that if it ended up in court that
we didn’t say come with us. That there was no enticement or anything like that…We
had to document everything”. (Practitioner A)

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Intelligence
A major theme throughout the interviews was the importance of gathering intelligence to
build the picture of how the exploitation was organised. Questions asked through the
engagement at the HMOs became more focused on employment as well as who was
collecting the rent. The operation also took the same approach, however they also engaged
with workers as they were being transported to the workplace. They did this under the guise
of another operation to not rouse suspicion.
“If you go there at 5 o’clock…you would find all the gangmasters and they’d have mini
busses and all the workers and they’d be pilling all the workers on…under the guise of
a traffic check and while traffic were checking all cars and mini busses, we’d have our
investigators speak to some of the people [migrants]…Where are you working, who is
it you are paying rent to”. (Practitioner B)
“After interviewing 20-30 people they all had similar but slightly different stories we
got the big picture of what the whole exploitation chain was happening…We started
seeing links to certain rent collector names or a certain car or an index. Things like that
started linking”. (Practitioner A)
The exploiters responded to the investigation and the visits. Therefore, it was important that
the partnership built relations quickly as there was often a quick turnaround of occupants in
the houses initiated by the exploiters.
“The exploiters have a portfolio of addresses and what they do on purpose is that they
move the occupants from house to house quickly around if there is any sort of whiff
of any authorities at the address”. (Practitioner A)
This intelligence was fed into the Central Intelligence Bureau (CIB) who were able to build a
picture of the organised crime network by identifying who was controlling the houses, what
agencies were managing them as well as who was controlling the work. However initially
there were challenges getting their intelligence bureau to except intelligence that wasn’t
related to a crime.

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“We had a lot of issues with the intelligence bureau because they were saying this isn’t
intelligence…we don’t care about a rent collector, this isn’t a crime. So there’s a big
issue there with…trying to educate your intelligence bureaus that actually insignificant
information will build a bigger picture…yes it’s nothing about a crime at the moment,
but the rent collector is an important bit of community intelligence”. (Practitioner A)
As the investigation developed and other agencies became involved such as the GLA, HMRC
and NCA, the constabulary’s intelligence system was the only system capable of processing
the volume and mixed types of data. Again the practical implications were that it required
additional resources to ‘double key’ information onto the intelligence system.
“The intelligence picture started to develop. Very much needed then lots of double
keying in regards to intelligence held by the GLA…council…HMRC had all of this
information that wasn’t on our system…our intelligence system is the only one that
could cope and is designed to cope with lots of different intel and then make sense of
it”. (Practitioner A)
Once they were able to overcome these issues identifying the offenders was, according to
Practitioner B, rather straight forward due to the questions being asked of workers such as
who collects rent and who pays the wages. This intelligence uncovered how the exploiters
were operating and how they were controlling victims.
Control, resistance, loyalty and debt
Those who appeared to control the properties and facilitate the exploitation were the ‘alpha
males’. This is a term that has been allocated by the investigation to occupants in the house
who were very dominant. This is because they are given privileges and responsibilities such
as collecting rent in return for money, freedom and loyalty to the exploiters. These people
were seen as sometimes both victims and offenders and appeared to be responsible for
disrupting the efforts of the investigation as well as enforcing discipline and control in the
houses.

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“We realised that properties were being controlled by gangmasters largely or people
further down the line who’d perhaps been victims themselves being promoted and
then suddenly become a rent collector. So of these rent collectors are very
intimidating, very powerful characters and you don’t ask questions because you know
that something awful might happen if you step out of line. You’ll be kicked out, you
will lose your job and home and end up homeless”. (Practitioner D)
What this shows is that victims were at constant threat of being placed into destitution. What
they also found was that offenders were able to manipulate victims effectively to gain their
loyalty.
“There’s some loyalty to the person who has been sorting them out…when they first
arrive here the exploiter would use all these psycho…[psychological]… kind of
relationship so they will basically say first of all don’t trust the authorities because they
will send you back home, they don’t like you here, they are all very mistrusting and
they are very similar to our ones back home…then they will start saying I will look after
you, I will find work…any problems contact me”. (Practitioner A)
An interesting comment was this behaviour was relatable to domestic violence and the
coercive practices of abusers with the person being unable to walk away.
“I always use the analogy of domestic violence. Well a victim of domestic violence can
leave their partner, but they don’t because actually there is an element of fear and
control”. (Practitioner C)
Debt was also identified as an enabler to exploitative practices taking place. What they
uncovered was the methods employed by the exploiters to push people further into debt by
withholding work and taking control of bank accounts. What this showed was that a complex
form of debt bondage was taking place in Wisbech.
“Some of them under the greatest amount of control were in the greatest amount of
debt”. Practitioner B.
“A lot of the time there will be bank accounts taken out in victims’ names, but actually
the use of the bank accounts is by another individual because they…will actually take
charge of their cards and credit cards and withdrawals”. (Practitioner C)

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Challenges in securing Modern Slavery related convictions
A significant challenge facing the prosecution was that many victims were willing to be
complicit in their exploitation. This raised the issue of consent which was experienced during
the judicial court process and engagement with the Crown Prosecution Service (CPS). When
it came to trying to achieve a conviction for human trafficking the most challenging part of
the prosecution according to Practitioner B was the current legislation. This was despite them
being confident that trafficking had occurred through the deception of victims into travelling
to the UK to undertake work in exploitative conditions. However, when it came to taking the
case to the CPS they had issues.
“As investigators we very much said this was human trafficking because...in some
cases they were organising travel, facilitating the movement of these people from
poor areas of Latvia…mainly Latvia…and bringing them into the country on the
promise of a better life and they were exploiting them. You know, they were doing
this for the purpose of exploitation. The CPS had a very different view”. (Practitioner
B)
Despite victims being held in terrible living conditions and being under constant threat of
menace, they were according to CPS, consenting to work and were free to exercise freedom
of choice.
“Where the CPS struggled was around the issue of consent. The CPS very much felt
that because people had willingly come in, even if they had been coerced or mislead
or even lied to, they felt that because these people consented and were consensually
going to work and did not have chains on the doors and you know, weren’t being
forced”. (Practitioner B)
What the investigation found was a cultural acceptance of these conditions and a willingness
to be complicit in their exploitation. As well as this there was the contrast between life in the
UK verses back in their home country. This again caused issues for the prosecution and

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enforced the CPS view that victims were willing and therefore that it didn’t constitute modern
slavery.
“They will have put themselves in debt to get to this country and actually even though
they are living in overcrowded housing in the UK it’s better position than they were
back in their home countries. So actually when you go to them and say you’ve worked
60 hours this week and you’ve only been payed £40 that’s wrong. They will say well
actually you know I’m better off”. (Practitioner A)
“The first three or four victims we had in the box could have been there as defence
witnesses, you know they were saying [suspect] helped me. I was sleeping in a field
and the [suspect] gave me a job and a roof over my head. I may have been earning
only £10 a week, but I wasn’t sleeping in a field”. (Practitioner B)
This raised questions on whether the legislation at the time was fit for purpose, or that a
lesser crime was occurring in Wisbech that is not captured in law. Practitioner B made a very
interesting assessment of the case that captures this point and questions whether the
Modern Slavery Act will cover the events in Wisbech.
“Across Wisbech as a whole, you have this real interesting phenomenon of where you
have activity which more than often than not does not meet the threshold of modern
slavery. So back then it probably wouldn’t have met the threshold for human
trafficking or slavery…it’s exploitation, we’re saying it’s not right, but it is at a level
which isn’t severe enough that it would captured by the Modern Slavery Act”.
(Practitioner B)
Educating the Victims, the Public and the Police
A key theme throughout was education. Not only the victims and raising the awareness of
modern slavery but also the officers in the constabulary and member of the public. It was
highlighted early on that due to lack of knowledge officers often missed the signs of modern
slavery. This was recognised not only as an issue for Wisbech but also a force wide problem
due to the number of referrals but lack of cases and convictions.

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“We’ve got lots of victims being identified through the NRM, but not the same amount
of crimes and prosecutions, but that one might come back to education about how we
as police…as police staff need to respond to it”. (Practitioner C)
Therefore the constabulary has taken steps to increase the awareness and knowledge in the
force by installing a modern slavery management team, developing a training package and
practitioners guide as well as appointing ‘Single Points of Contact’ (SPoCS) across the six
policing districts to provide guidance, support and raise the profile of the impeding Modern
Slavery Act (MSA).
“The training guide…talks from a national perspective to a local perspective. Talks
about the signs and indicators, expectations, reflects a bit on the practitioner’s guide,
brings some live case studies and is fairly interactive and specifically talks about the
new Modern Slavery Act and the different powers and procedures [that] have been
brought in…then it is the full responsibility of the SPoCS to then go deliver that across
the force”. Practitioner C.
What the partnership also did during and after the operation is educate the public. This was
vital in gaining the support due to the perception of migrants in the town and the impact on
community cohesion. The partnership also worked with the local MP who was able to
champion and raise the issue nationally which also helped to gain funding.
“The local population resent how migrants will walk around in gangs drinking. So what
we’re very keen to do is to try and put some publicity out that showed that actually,
some of these people…that there’s a story behind this. They go around in gangs
because they don’t speak the language, they don’t perhaps know where they are
even…so we try to sort of paint an alternative picture”. (Practitioner D)
The success of the investigation is reflected in its 2015 LGC Partnership and Communities
award (Local Government Chronicle , 2015), the successful prosecution of the gang, and the
continued safeguarding of victims. However, what this analysis has hoped to show is there
was a significant amount of learning took place over the course of the investigation in
identifying and tackling a relatively new and complex crime absence of previous experience,

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national understanding and an inadequate legal framework suable for the case. Therefore
what this case study has provided is insight into the practical realties of tackling modern
slavery as well as challenges that may face similar investigations in the future and the
implementation and enforcement of the Modern Slavery Act.

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Chapter Four: Discussion
This chapter will explore and discuss both the events in Wisbech and the literature to provide
insights into the practical realities facing practitioners responsible for enforcing the new
Modern Slavery Act (MSA) – in particular the offence of forced labour.
Identifying Modern Slavery in Wisbech
This section will focus on the exploitation that took place and how Organised Crime Groups
(OCG) in Wisbech were able to operate and profit from vulnerable migrants while remaining
relatively hidden from authorities. The characteristics of the case, including its composition
and the sector in which the exploitation took place, mirrors the literature, making it a
‘representative case’ of modern slavery in the UK (Gomm, et al., 2000). The gang, as labour
intermediaries, provided a compliant and timely workforce for the factories and fields in and
around Wisbech and were able to profit by controlling wages through rent and unlawful
labour practices. Consequently, victims were kept in a constant state of economic and social
precarity due to the vast imbalance of power exercised by the OCG (Lewis, et al., 2014).
By applying the International Labour Organisation’s (ILO) eleven indicators to the findings, it
is clear that victims were experiencing coercive situations that, within this framework,
constituted forced labour. This was evidenced in the case by the use of violence, withholding
of wages and identity documents, exploitative living conditions and debt bondage.
Nonetheless, although the gang were successfully prosecuted for related offences, during the
court case victims were viewed as having the ability to exercise freedom of choice by ‘walking
away’ and therefore didn’t constitute what the literature would regard as a contemporary
form of slavery.

0909274 47
As a result, instead of applying the ILO framework, a more appropriate tool to critique the
events in Wisbech is to apply Lewis, et al. (2015) “continuum of unfreedom”. What was clear
from the findings was that victims were experiencing a number of ‘unfreedoms’ imposed by
offenders who were able to exploit vulnerabilities by employing a number of strategies and
methods of coercion, control and dependency. This framework can also be found in the
‘victim led’ approach adopted by the investigation to understanding the complexities of the
exploitation and why victims were complicit and somewhat compelled to live and work in
such conditions. By adopting its four elements (no real acceptable alternative to entering and
continuing in exploitative labour; withholding of a minimum, living or social wage; existence
of a web or chain of fixers, agents and beneficiaries; wider existential feelings of coercion,
menace and involuntariness in relation to social reproduction and social life) as a framework,
this can be better understood.
No real acceptable alternative to entering and continuing in
exploitative labour;
Through deception, workers were brought into Wisbech on the premise of work before being
submitted to a process by the exploiters that eroded the life choices and freedoms of the
victims (Migrant Advisory Committee, 2014). This predominately involved a strategy of
bonding victims’ accommodation, transport and access to work leaving them highly
dependent on the gang. This ‘strategy of dependence’ can be found within the literature as a
common way to exploit and aggregate the additional vulnerabilities of migrant workers (Lever
& Milbourne, 2015). In Wisbech, occupants of houses needed to access work to pay for rent
to avoid being placed into destitution by illegal evictions. By controlling this access, it severely
limited the choice and ability of workers to negotiate conditions of pay. This social and

0909274 48
economic dependency provided a powerful method of control that gave victims no other
option but to submit and work under the exploitative conditions imposed by the OCGs.
The MSA offence of forced labour is currently viewed as a distorted and significant imbalance
of power between worker and employer. However, in this case it is also an imbalance of
power between tenant and landlord - expanding the concept of forced labour beyond work
place regimes. Therefore, in order to overcome the view that victims are able to physically
‘walk away’ or not turn up the next day for work, prosecutions need to evidence that
economic and social dependency is a subtle form of coercive control. Without being able to
evidence the limited ability and choice of victims to seek out and negotiate both new labour
relations and accommodation, there is an argument that it may prevent similar cases to
Wisbech from obtaining a conviction under the new MSA. This poses a significant challenge
to its enforcement.
Withholding of a minimum, living or social wage;
Continuing on from the previous section, controlling the finances of victims severely limited
their ability to reduce their dependency on the gang - hence increasing their vulnerability to
severe exploitation. The gang were able to hijack victims’ bank accounts and wages to
maintain dependence and restrict freedom. As evidenced by the interviews, many of the
victims were left with little ability to pay back debts and obtain financial freedom. Victims’
cultural perceptions of their own obligations to honour debt were further exploited by the
gang on top of additional vulnerabilities - such as the lack of knowledge of financial and
employment systems. This enabled the OCG to control the flow of money as well as force
people, especially women, into further debt and dependence that made them vulnerable to
other exploitative practices such as forced marriages and sexual exploitation.

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Lewis, et al., (2015, p. 10) suggests that “the glue that holds this web together is frequently
indebtedness” and that this is a key element to successfully maintaining exploitative practices
with little resistance. Given the impoverished backgrounds of the victims, their willingness to
accept exploitation and debt as a pathway to a better life further adds to the hidden nature
of the crime and lack of reporting (see O’Connell Davidson, 2013). Moreover, with some of
these practices considered breaches of labour law and not within the powers of the police,
victims may not have the capability, knowledge and financial support to take these offences
to an employment tribunal. This highlights the need for prosecutors to recognise that these
are subtle methods and are part of a much wider strategy to control victims and limit their
ability to exercise agency and freedom (Lever & Milbourne, 2015. Lewis, et al., 2015).
Existence of a web or chain of fixers, agents and beneficiaries;
Unfortunately, the interviews did not capture the full picture of this element. Nonetheless,
the role of the ‘alpha male’ in the exploitation provided two valuable insights; the first into
how the victims were controlled not by one person, but by a network that “orchestrates the
unfreedoms of workers” (Lewis, et al., 2015, p. 158); the second was how victims can become
not only complicit in their own exploitation, but facilitate the exploitation of others in receipt
of benefits and greater freedom. Alpha males became pivotal in maintaining control and the
dependency of the victims on the OCG for housing, wages and transport. Victims becoming
offenders is a phenomenon that can be found in other cases of modern slavery. For example,
the trafficking of Nigerian women for sexual exploitation who progress from a prostitute, to
working as supervisor of a madam, before becoming a madam themselves (O'Connell
Davidson, 2013. 2015).

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In regards to the MSA, this web poses a significant challenge on who is responsible for
committing the offence if forced labour is viewed as a bilateral affair between an offender
and a victim. Once again, victims may not have been forcibly made to work, but the
environment generated by the OCG and facilitated by alpha males left victims no acceptable
alternative but to either comply in the exploitation, or offend themselves. This clearly makes
it challenging for agencies to distinguish who is victim, who is facilitating, and who is
orchestrating the whole chain.
Wider existential feelings of coercion, menace and involuntariness in
relation to social reproduction and social life.
Threats of eviction, access to work and control enforced by alpha males all helped to create
an environment of menace and placed restrictions on the lives of victims. Similar to debt, it
provides a constant strategy of maintaining compliance and control. However, Practitioner
C’s comment on domestic abuse and how the experiences in Wisbech echoed methods and
signs of coercive control found in abusive relationships provides an interesting lens to view
the exploiter/victim relationship. This is particularly the case when violence may not always
be present. Or, regular, but psychological, forms of coercion and control exist and are a
constant.
In line with this idea, some of the literature strongly argues that dependency and lack of
alternatives is a form of coercion in itself (Strauss, 2012). However, briefly exploring the
concept of coercive control in domestic violence shows that it is still within its infancy – for
example, it was only incorporated as a domestic violence offence in 2014 (Home Office, 2014).
This is certainly a concept to explore further outside the boundaries of this research to; firstly,
understand coercive control, secondly, how it can be applied to the concept of modern

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slavery, and thirdly, how best to evidence it to achieve stronger prosecutions in cases of
modern slavery.
By applying Lewis et al. (2015) framework and drawing on the evidence captured by the case
study, it supports the view that modern slavery is not a single act that can be neatly defined
and evidenced through a bilateral affair between victim and offender (Lewis, et al., 2015).
Instead modern slavery is a situation that also needs to consider if victims have “no real or
acceptable alternative” to housing, education, health, food, social life and so on, not just their
employment. This is due to the environment exploiters are able to build on - the vulnerable
situations migrant workers find themselves in as a result of a flexible market, often finding
themselves compelled to engage with exploitative practices amounting to forced labour to
survive (Lewis, et al., 2015, p. 159). Therefore, with no apparent changes to workplace
regimes in sight, it is the responsibility for the police and partner agencies to manage this
environment, protect those who work within in it, and prosecute those who exploit it.
Analysing Modern Slavery: A Problem-Oriented and Intelligence-Led
Approach
Despite participants not being asked if they had adopted a POP approach, it was clear that
‘Operational Pheasant’ (and to an extent Operation Endeavour) undertook a process that
mirrored the SARA (Scanning; Analysis; Response; Assessment) model. By identifying and
analysing a number of problems in Wisbech, they were able to formulate appropriate
responses that unearthed modern slavery as the ‘root cause’. Key to identifying links and
building the picture of exploitation was the successful use and analysis of multiple data sets
from multiple systems and agencies. However, there were practical, technical and cultural
challenges to this process. These challenges are shared by Bullock, et al. (2006) and Tilley

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(2008) who highlight that data and databases are not always available to police forces,
systems are often incompatible, can contain poor data and there are often “cultural obstacles
to sharing data between agencies” (Bullock, et al., 2006, p. 24). The same technical and
practical challenges were found in ‘Operation Endeavour’ that required vast amounts of
intelligence to be processed and shared amongst multiple agencies. This, combined with
different approaches, knowledge, experience and training required careful planning,
continuous communication and coordination of the overall response.
Nonetheless, what could be established from the interviews was it was clear that both the
partnership and operation were able to overcome and work through these technical, practical
and cultural obstacles by developing close working relationships, exploiting established
information sharing agreements, using a single system approach and creating clear roles and
responsibilities that recognised each agencies powers, capability and limitations.
Once it had been recognised that the problems in Wisbech were, in fact, symptoms of a much
larger problem, gathering intelligence was key to continuing the analysis that built the picture
of exploitation and uncovered OCGs operating in the town. The approach of this analysis can
be framed within an ‘intelligence-led’ policing methodology. What was challenging for this
approach was the recognition that some intelligence may not (on the face of it) appear to be
crime related. However, this ‘community’ intelligence was vital in uncovering and building the
picture of exploitation. Despite initial resistance by the Constabulary’s intelligence
department, recognising the importance of this type of intelligence uncovered how the OCG
was operating in Wisbech. What was key to obtaining this intelligence were the strategies and
methods adopted by the police and their partners in their response; this strategy can be
defined as a ‘victim-led’ approach.

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Responding to Modern Slavery: A Victim-Led Approach
To combat modern slavery within this challenging environment, police forces and their
partners need to develop their own strategies and methods. Within Wisbech, the decision to
adopt a victim-led approach was significant in recognising the vulnerabilities of migrant
workers. This strategy of engagement and support provided victims with greater freedom of
choice (even if this was to go back home) and enabled the investigation to gather intelligence
and evidence to pursue a prosecution.
The first challenge of this approach was to educate themselves, other agencies and the public
to look beyond stereotypes and negative views of migrant workers in the town. Due to
reasons discussed, victims through necessity turned to committing petty crime to obtain food
and pay debts during periods when there was little or no work, or work was withheld by the
exploiters. Furthermore, males from poorer nations who seek to improve their life-chances
through migration were more likely to be labelled as the new ‘folk-devil’, the economic
migrant rather than a victim of modern slavery (O’Connell Davidson, 2015; Lewis, et al 2015).
This resulted in a failure to look beyond this view with police officers dealing with problems
as offences, rather than signs of exploitation and economic necessity. They were responding
to the symptoms of modern slavery, not the causes which, in turn, hides the problem and
results in a continued demand for reactive resources. By moving beyond basic perceptions
and narrow assumptions, the partnership was placing the victims at the centre of the
investigation and engaging with migrants directly to build the picture of exploitation in
Wisbech.

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Building up trust and confidence was essential in obtaining support in pursuing and securing
a successful prosecution. However, this was not without its challenges. As already discussed,
alpha males disrupted visits and prevented engagement with occupants meaning the
investigation had to adapt its methods and approaches. Another key challenge was language
and ensuring that relationships with victims could be harnessed to maintain support
throughout a lengthy trial – the success was evidenced by one hundred percent attendance
at court. By introducing a special role (victim contact officer) highlighted the commitment by
the investigation to obtain justice for those who had been exploited for profit and kept in
appalling and inhumane conditions.
What this chapter has achieved is to discuss the events of Wisbech to understand what the
practical realities are of identifying, analysing and responding to a case of modern slavery. By
drawing on Lewis et al. (2015) continuum of exploitation, it is clear that the strategies and
methods employed by OGCs enabled them to remain hidden from authorities. However, by
analysing multiple data sets and linking problems, close partnership working and engagement
with victims, the two operations brought to surface the exploitation which led to the
successful prosecution of a gang of four offenders and exited vulnerable victims from
exploitation. What this case has provided is an exploration into the realities of tackling
modern slavery and an insight into the practicalities and challenges of enforcing the MSA.

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Chapter Five: Conclusion
By adopting an exploratory approach to this research, it has been able to explore the concept
of modern slavery in a practical sense rather than just conceptual. By framing the exploration
within a case study, it has gathered valuable insights from practitioners involved in identifying
and responding to a case of modern slavery – most notably the challenges and obstacles they
had to overcome. What this provides is an early indication of the potential impact of the new
Modern Slavery Act (MSA) on a police force. What was key throughout this exploration was
the importance of education and a greater requirement to understand the phenomenon.
Throughout this study, a number of frameworks have been used to try to structure this
complex topic. The primary structure adopted has been the SARA model found in problem-
oriented policing. Without being prescriptive, it provides an effective approach simply
because it requires police forces to focus on finding the root causes for demand – as opposed
to just reacting to symptoms. Although there are practical, technical and cultural challenges
to partnership working, what this case showed was that when these challenges are overcome,
vulnerable victims can be assisted out of exploitation, offenders brought to justice and local
communities benefit from the resolution of visible problems.
However, a major challenge still to be resolved is defining what constitutes ‘no acceptable
alternative’ but to submit to the abuse when victims are complicit in the exploitation. Without
this clarity, the defence team in court are able to present a mirage of freedom that obscures
the lack of choice and economic dependency of victims on their exploiters - voiding any
chance of securing a conviction under the MSA for similar cases like Wisbech. Thus, by using
Lewis et al. (2015) continuum of unfreedom, what is vital is that evidence in cases of modern

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slavery captures both the economic and social ‘unfreedoms’ imposed by the strategies and
methods of offenders to show that exploiters know, or ought to know they are requiring
someone to perform forced or compulsory labour. Furthermore, by looking closely at recent
developments in cases of domestic abuse, the concept of coercive control could provide a
new conceptual lens to view situations where a victim’s dependence is orchestrated as such
that they cannot simply ‘walk away’ from their exploiters.
Fundamentally what this small study hopes to achieve is to stimulate further research around
some of the topics it was able to uncover during the course of the exploration. Growing the
knowledge and evidence base of policing methods effective in identifying, responding and
prosecuting cases of exploitation will enable law enforcement to successfully meet the
challenge of reducing the prevalence of modern slavery in the UK.

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Appendix A – Interview Guide
Introduction
Purpose of interview is to understand modern-day slavery in Cambridgeshire and the ongoing
operation in the Wisbech/fenland area. Also to identify further people to interview.
Main question 1) Identifying the issue: How did Cambridgeshire constabulary police realise
there was an issue with modern-day slavery in the area?
- What were the signs?
- Who are the victims?
- How were they being exploited?
- When did you decide to take action?
- Was it during a particular time of year?
- Who reported it?
Main question 2) Investigating: When did you start the investigation and how did you go about
it?
- Who did you engage with?
- What tactics did you use?
- How many officers were involved?
- What partners did you engage with?
- How did you collect evidence?
- How did you identify offenders?
Main Question 3) Prosecution: How did you manage to arrest and prosecute the offenders?
- How many people have you prosecuted since modern-day slavery was identified as an issue?
- Under what laws/offences have you prosecuted?
- If any, what issues did you face in securing a prosecution?
Main Question 4) Prevention: What action can Cambridgeshire police do to prevent modern-
day slavery in its area?

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Appendix B – Participant Consent Form
CONSENT FORM FOR QUALITATIVE RESEARCH PROJECT IN THE U.K.
Statement of Informed Consent
Transnational Crime, 21/08/2015
My name is XXXX, and I am a Masters student studying Transnational Crime at Anglia Ruskin University. As part
of my course I are required to submit a dissertation. This is a piece of original research that I have worked on
with a department supervisor.
Purpose of the study
The purpose of my research is to capture practitioners’ experience of responding to modern slavery in
Cambridgeshire Constabulary. This study will focus on Op Endeavour and Op Pheasant to understand how
modern slavery was identified and investigated. Providing valuable insight into this new and complex crime.
Permission to conduct the study has been granted by Chief Superintendent XXXXX of Cambridgeshire
Constabulary.
Why you have been selected
Participants of this study were identified through a ‘snowball’ sampling method. You were identified as potential
participant by either Chief Superintendent XXXXX, Chief inspector XXXXX, or a colleague as having worked, or
currently working in this area for the constabulary.
What is being asked of you
For my research, I would like to conduct a short 30-40 minute recorded interview with you in order to understand
your personal experiences of dealing with Modern Slavery and any good practices, lessons learned and general
knowledge you have gained over the course of your time working in this area.
Ethical considerations
To insure confidentiality you will be anonymised and given a Unique Reference Number that only I will have
access to. This is to identify you if you wish to at any point remove yourself from the study.
In the dissertation you will only be referred to as Practitioner A/B/C etc. Recordings will be held on a password
protected devices and transferred to a password protected computer.
The interview will then be transcribed to make it easier to analyse and present findings, a copy of the
transcription will be returned to you and the recording deleted. Any addresses or names revealed in the
interview will also be changed/anonymised in the transcript.
Once completed I will disseminate a draft version to you before submitting to the university. Once marked it will
be published in the College of Policing’s library.
Do you have any questions you want to ask me?
Researcher: XXXXX Supervisor: XXXXXX
XXXX@university.ac.uk supervisor@university.ac.uk
I give my consent to a recorded interview and to participate in this study. Yes No
Your Name:
Your Signature:

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Appendix C – Practitioner A Interview Transcription
Practitioner A
S1 Researcher
S2 Practitioner A
Speaker Transcript
S1 Okay [Officer A] just some early questions. How long have you been a police
officer?
S2 Well probably coming up to close to 20 years. Since 1995
S1 And how long have you been involved in the policing of modern slavery in
Cambridgeshire police.
S2 Probably two years, two and a half years
S1 So to get straight into it with the main questions. The first one is in regards to
identifying modern slavery in Cambridgeshire and how did Cambridgeshire
police realise there was an issue with modern day slavery in the area?
S2 Well the way it really sort of manifested itself was that we always had little
small jobs where a victim would come to a police station and say I’ve been
trafficked and something like that and a lot of the time, rightly or wrongly the
investigation would stall because of the lack of knowledge of officers etc. and
the general lack of knowledge of the national referral system mechanism what
to do with a trafficked victim was not well known by our officers. Then what
happened was I took over at Fenland and one of the main towns in Fenland is
Wisbech. Now Wisbech is a small market town that has been dis-proportionally
affected by human trafficking. So I think that’s the reason why if the same issue
were happing in a big city then I don’t think we would have identified as such
but because it’s a small town it became more pronounced. And certainly in the
case of big new command coming into the area looking at all the crime trends,
ASB against the local things etc. What we identified was that there was a link
between the number of incidents we were attending and the locations being
overcrowded houses. Many of these overcrowded houses would have a certain
nationality of either Lithuanian or Latvian and that started asking questions.
When we then, we did have a strong partnership relationships with colleagues
in Fenland district council and when we started exploring that with them and
the fire brigade they were going to the same overcrowded housing locations.
So basically what we did we said okay lets go low key plain clothes into these
addresses just to see what was going on and for the first time where normally a
normal police officer would go deal with the incident in this case so there would
be either when I talk about this case I’m talking about the would be drunken
disputes, there would be noise complaints there will be you know overflowing
bins, disputes between occupants’, lots of burglaries in regards to a room being
broken into passports being taken, lots of crimes being raised being raised
through theft of passports and ID cards stuff like that. But most of the time the
officer would go deal with the incident and move on no one was actually was
looking at the strategic viewpoint. It was then we started to instead of going to
the address of the victim stroke offender, on that individual case it was when

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we started going to the occupants and just generally having no agenda, no set
agenda and just sit down and talk to them is that we started to build up a
rapport. In hindsight now is the first two, three visits we went to the occupants’
were very vague defensive and the reason for that is because they were victims
of human trafficking who we didn't know that at the time. We took that for a
cultural mistrust of the uniform etc. so there are these barriers straight away
and hence the casual attendees such as the house enforcement officer and that
would just say they are all roughs, you know what I mean and would treat the
person like they had something to hide rather than them being a victim. So all
the previous times we treated them as hostile offenders sort of thing. They
were actually victims who were scared of repercussions. The first 3 or 4 times
we would keep going to the same address and we would progressively make
improvements to the house so first of all we went and there would be some
rubbish out the front so the DC would get that cleared up. There would be
dodgy boilers so that the fire brigade would use their powers to insure that was
safe, they put smoke alarms in and you know there would be mould on the wall
so by that time we would have got hold of the landlord so each time we went
there had been progress at that address. This was fundamental because it built
up a rapport and trust and confidence. What you got to remember as well is
that a lot of these locations have a quick turnover of occupants so you would go
the first time and there would be 10 people and then you would go a month
later and actually there was a completely different household again. So what we
actually had to do was some of the visits had to be quite rapid, you know two to
three days so we actually had to time to keep the same occupants or we would
find out where the occupants had gone round town. The exploiters also they
have like a portfolio of addresses and what they do on purpose is that they
move the occupants from house to house quickly around if there any sort of
whiff of any authorities at the address or anything like that. So you've got all
these other issues. So basically we did lot lots of visits and eventually people
started to tell us their life stories and how they got here and like that and it was
very much you know sitting over a lemon tea and saying how did you get here
and all that. We then started to become experts in what questions to ask, not
investigative questions just general questions like just general questions of how
did you get in did you come through dover did you go through the terminal you
know these kind of question like I take it you got dropped at South Wields in a
coach. So you already by that conversation and the sort of questions we're
asking they knew we had some knowledge of the story they had been through
and that for therefore that gave subconscious of actually they know what I’m
doing what I tell them isn't anything new so therefore I feel a bit more
confident. So it's that sort of interview where you suggest things to them and so
you build up and again it’s building up trust for us. Literally after interviewing
about 20-30 people they all had similar but slightly different stories we got a big
picture of what the whole exploitation chain was happening and from there,
through all that intelligence that was going onto the system, that increase
intelligence, we then had an identified intelligence officer in our CIB to look at
all that and they then started seeing the links to certain rent collector names
and. or a certain car or an index things like that started linking and then they

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started doing the stuff they do mapping it in and make a picture. From there we
were able to identify two or three organised crime groups and then it starts
rolling from there that then once you know the people you are focusing on we
then did some background work on them people and identified some more
addresses they were in control of, we start looking into their financial bank
accounts etc. and we started seeing a pattern etc. and the whole case started to
build up so you can do something. But that all started from some small
community intelligence about a red car the rent collector picking up in the red
car. We had a lot of issues with intelligence bureau because they were saying
this isn't intelligence you know, that we don't care about a rent collector this
isn't a crime so there is a big issue there with regards to trying to educate your
intelligence bureaus that actually that insignificant information will build a
bigger picture eventually and yes it's nothing about crime at the moment but
actually the rent collector is an important bit of community intelligence so that’s
quite interesting... Sorry I forgot your original question?
S1 Oh no it’s answered a number of the questions. So the first question was in
regards to identifying the issue.
S2 Ah yes. So identifying the issue, basically what we also found is that once
started delving into these accommodations they were actually the ones that
were causing the most demand for our resources. Because you haven't got one
victim who's always calling and shouting the loudest you got lots of several
victims no one actually picks this up on searches on CrimeFile because it's a
different person each time and things like that, so your normal search and that.
So it was only and when we started talking to the local officers saying you know
where the overcrowded houses they would come out with a list so they knew
where they were going because they were always going to those addresses you
know when they come over across radio or at you know a house full of
Lithuanians. What and what we also found is the range of crimes, so two of our
murders were in overcrowded house because of the disputes often happened
because people were drunk a lot of our domestic violence was in overcrowded
housing right down to you know your shoplifter who was stealing food to keep
alive were giving these addresses. So the same addresses coming up each time
and it wasn't until we identified the overcrowded housing as the thing, the
common MO, that we then started investigating and exploring that and actually
we then started to realise that lots of crime and incidents were being created by
these houses. But you probably wouldn't of seen that in a big city and that's
probably they can now because now we know what the trigger are and what to
search for and to look for you probably could delve it out in Peterborough and
we have started doing that. What you got to remember is that is most of that
data on overcrowded housing is all dealt with by the council and it wasn't until
you went to the Peterborough city council housing officers and said where are
your overcrowded houses they gave us a list of their top ten when we then
transferred that onto our crime system that’s where all our crimes and all that
were happening. So again, but no one had ever made the link between
overcrowded housing and crime.
S1 That's really interesting because it's kind of using the data [inaudible]

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S2 Yeah the data that we don't hold but could do. The other thing is the HMRC
have got a massive big database and if you ask them on an address they were
saying this indicates an overcrowded house for us because the number of credit
checks. So when a new person comes into the country they ask for a credit
check on a certain address and we were told thousands and thousands of
certain addresses for them there are lots of turnover in that house and then
you've got victims’ names there and you try to tack them round the UK.
S1 Was it particularly during any time of year that you noticed a spike in crime or
overcrowding or all year round?
S2 So what happens is again where we first found out. Christmas time is you lull
time not much crop. Now this I should really explain. Wisbech is very much
agricultural so it was more obvious. Peterborough now we've been investigating
that now it is less obvious because there is a lot more factory work and stuff so
it's more steady labour. So there is more cleaning work stuff like that, so when
you starting to talk about London and places like that. Human trafficking it’s all
down in the construction industry so again it will be less obvious. Certainly with
Wisbech we found Christmas time was the lull period where most of our
overcrowded houses only held about five or six people in them. We then found
out from occupants that were left were either shipped down to Devon and
Cornwall who knew anyone who was arriving in the country would go down to
Devon and Cornwall. There are certain crops that are very labour intensive that
the exploiters tend to target, so for example the flower industry. So Devon and
Cornwall the first things are your daffs and all that. Basically what they've got
down there is a problem with holiday homes basically you are out of season so
who holiday home caravans are being filled up by with victims of exploitation
and they are ready for the flower season basically migrates from Devon and
Cornwall as the spring comes and comes up through East Anglia and it
eventually goes right up the way through the north to Scotland and actually the
organised crime groups are moving the labour as it follows
S1 So there is actually trafficking within the UK?
S2 Absolutely yeah. So that also means that each county doesn't keep track of it so
certainly round mother’s day and valentine’s day we suddenly see a massive
increase in our in our overcrowded housing population and it will stay and
obviously you've got the flower season but then you got the root crops the
pumpkins at Halloween all these kind of things so you can literally map out a
whole season and how to do it. A lot of time in a perfect world crops will
overlap so they'll move from flower to factory on one day and the pumpkin
factory on the next day but sometimes there are gaps in seasons and I
explained last time about two years ago we had a very late weather we had a
long hot summer and certainly all two crops were very late and very dry and we
had this period of about two and half months where there was absolutely no
labour at all but they knew the season was coming so all the occupants were
still staying and they weren't getting work. So they still were having to pay their
unofficial debts and to shell out their rent, electricity, and all that. But there's no
work for them and that’s when we started seeing spikes in like street robberies
for mobile phones and shoplifting for food etc. so that’s what we started seeing.

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So to combat that next season although didn't happen because we didn't have
to because the all crops came in early, but was to start thinking about crime
prevention initiatives which would be your food banks, your credit union,
community credit banks etc. loans etc. so that you can start tying people over in
those periods of time. Now if you said to a police officer right okay we want you
to find out all about the food bank etc. etc. places for they to go you’ll get you
know I’m a law enforcement officer why am I doing this. But for me that’s more
for crime prevention that should be given to occupants as you go to these
overcrowded houses because they won't know about food bank system because
they don't have it back in their countries so the whole idea is right lets [in
audible]. So yeah so it’s trying to think about you know when we talk about
crime prevention within the constabulary we think about burglary alarms, we
think about gravel on your driveway and stuff like that when actually, we should
also be talking about food banks and how you can tie people over. Its
understanding what the problem is and the right solution.
S1 So moving on, the next question is in regards to the investigation. When did you
start investigating and how did you go about it? Could you explain more around
what partners that you engaged with and also the sort of evidence you collected
and how you started to head towards prosecution?
S2 Well you got to remember not one size fits all. So Fenland was very much based
around agriculture there was a big operation in Kent which was very much
around the egg industry so there would have a completely different scenario. I
know that obviously the Peterborough issue at the moment with exploitation is
all around house slaves. So the idea of you sort of saying, being able to say right
okay this is what human exploitation is and this is the package you should use. It
needs to be quite fluid or have different themes so you can actually explain that
there are different things. For us how did it all start well basically like I said the
intelligence picture started to develop. Very much needed then lots of double
keying in regards to intelligence that was held by the GLA the gang masters
licencing authority the council had all this HMRC had all of this information that
wasn't on our system. Now our system Intrepid, which is our intelligence
system is the only one that could cope and is designed to cope with lots of
different intel to then make sense of it. So for example council, any council they
don't have an intelligence system because there is no function they don't need
it for if you know what I mean. They have their systems to manage their files
and things but they don't actually have an intelligence system. The GLA will then
have an intelligence system that is very much on their own business of working
and they won't obviously put general constabulary intelligence on them. So we
had to make a decision to make first of all which is going to be the best system
to use it was a bit of a no brainer. But then it obviously meant a lot of double
keying as we had to bring in all this information together so that then the crime
analyst people could make sense of it all. So that that’s how we had to do it. So
we used lightened duties officers etc. etc. but lots of double keying to get it
onto one system. So one suggestion we have put together is actually, do we
have a community intelligence kind of system that we can kind of go over
boundaries and organisations so that would be interesting to see if that sort of

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develops. So anyway we started gathering all the intelligence together. The next
problem we had was a human trafficking crime to prosecute isn't the same as a
normal shoplifting crime. Whilst you have an offender you will have numerous
victims but probably don't know they're victims and that’s a big issue we had
because a lot of the time the victims will be coming from very poor backgrounds
in their home countries. They will have put themselves in debt to get to this
country and actually even though they are living in overcrowded housing in the
UK it's a better position than they were back in their home countries. So actually
when you go to them and say do you know you've worked 60 hours this week
and you've only been paid forty quid that’s wrong. They will say well actually
you know I’m better off here I've got a roof over my head. Also there's some
loyalty to the person who has been sorting them out because you as I explained
before at the beginning when they first arrived here the exploiter would use all
these psycho.. kind of relationship so they will basically say first of all don't trust
the authorities because they will send you back home, they don't like you here,
they are very mistrusting and they are very similar to our ones back home. So
they will start to put that barrier up for us. But then they will start saying I will
look after you I will find you work tax system is very complicated to give me
thirty quid and I will sort it out for you the banking system is really hard so I will
take you to a bank and open an account in your name and I'll make sure all the
money goes through there so you know any issues you have any problem
contact me contact me, contact me sort of thing. So their whole existence in
this in this country because their English is very poor they don't the benefits
systems they don't know anything about the system they very much reliant this
one simple person and this person knows it. So therefore he is more able to
exploit them more. So the idea of you being able to go into a house of twenty
people arrest the offender and then say to the victims you are the victims and
they go yeah we know we're victims is completely out the window so already
you are having to start educating the victim. But what you also have got to
remember is the end goal with the prosecution is that the defence will be saying
you conversed the victims into making statements. We had a lot of issues with
the Operation Endeavour trial in the fact they were saying before you even
went through the door you were calling them victims you know my client was
only helping them out, yes he was taking a cut but that's good business. So this
is the kind of defence that's coming up so what you got to do is educate the
person that they are being exploited but at the same time they don’t know they
are and they aren't coming forward. It’s only when they get beaten up or their
passport is used for fraud etc. that they start becoming vocal. If otherwise the
fact they haven't got a passport because matey boy has taken it for them or the
fact they don't get regular work that the work is too hard that, that comes with
the territory for them and all the time they are thinking that actually if I can
improve my English improve my written English eventually I’ll be able to get a
permanent job and that's the light in the tunnel that's their main goal and
therefore they will tolerate exploitation a lot more. So it is a very complicated
prosecution sort of case to start. So very much victim focused in that the victim
is in there. So what we had to do is use lots of agencies that we won't probably
use so in operation endeavour there was three hundred officers from both the

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constabulary, NCA, GLA. They were the main three that provided the arrest
teams and then on the back of that all the victims were taken to a which there
were eighty one of them were taken to a reception centre that was run by FDC
salvation army red cross. That was sort of the main three. On the back of that
you've got the national referral mechanism which is again run by the Salvation
Army. So lots of agencies involved, tax man was obviously keeping an overview
of that and he was trying to take a long haul, the long sort of game. We also
because we on endeavour were also arrested two gang masters we had VOSA
there because basically we were told the fleet was unsafe and actually went and
closed the fleet down So that was a good result and GLA were able to be able to
use their powers in regarding to unlicensed gang mastering activity etc. so they
were the ones that led on the investigation for the two gang masters. It’s a
really complicated because you are using different legislations from different
organisations and seeing which one fits the best. But the GLA don't have
sophisticated investigators etc. so rely on us to do the interviews etc. whilst
they were there but we're using their powers, so you can see where this is all
going CPS we had a big discussion about which CPS lawyers would lead would
be GLA would it be HMRC would it be the constabulary so we had all those
issues as well. On the day we got lots of stuff and different agencies all trained
differently, we used to different briefings etc. so we had to bring them all
together. The briefing themselves were very complicated because we had to
get across that we actually not going to bash the door down and arrest
everyone that’s in the house because you got victims but they don't know they
are victims so actually got to talk to them. You’ve got to use a script because at
the end of the day we need to show that if ended in court that we didn't say
come with us the was not enticement or anything like that. There was no we'll
find you a job and a house, there were none of those sayings at all. We had to
document everything about the reception centre and the way that the people
were treated in the reception centre so when they arrived at the reception
centre the first primary care was medical because a lot of them were
malnourished. We had scabies, we had bed lice, and those kind of things were
quite common in all the victims. So we had to sort out the medical issues first
then there was food, so feed them. Then we started to talk to them about work
then accommodation. It was only after three days of them being at the
reception for three days thing because what you can't to either is be a conveyor
belt saying you got to be out in two and half hours. So this is like three to four
day reception centre and only on day three and four do we then start saying
okay, do you want to give a statement to the police if not you will go here do
that. So it’s very much a slowly slow approach and in the meantime there are
videos players and there’s interpreters there to help them to support them and
things like that. So you got the reception centre you got the investigation going
on and obviously you've got the strategic overview. The one next week within
Peterborough will be even more complicated because its seven counties are
involved.
S1 Seven counties?

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S2 So it’s going to be sort of you know coordinating that as well so. But that’s the
kind of issues we mean and that’s why you got the National Crime Agency to do
the regional stuff. Sorry I’ve forgotten the question again?
S1 How did you identify your actual offenders? There were two gang masters
involved, was there anybody else and how did you identify them?
S2 Oh right, okay very much this community intelligence started triggering things
off. So someone would say someone had my passport taken, that's a common
theme you know the minute you arrive in the UK the exploiter will take the
passport off the person. The reason for that is so they can't get work elsewhere
or with an alternative employer, they use that passport for ID fraud and
identification fraud. Then it's also a way of manipulating the victim so it’s the
insurability on any debts etc. so reason so they can't move out and stuff like
that. So a simple theft of a passport was quite easy. But obviously though you
want to try and persuade or explain to the jury that this is more than just a theft
of a passport it’s exploitation, you’ve trafficking and you know they talk about
insecurity and in the definition of human trafficking it’s all about you know
being imprisoned and that’s a really hard concept to get across. Because the
average joe public will say the door was open you know they're not actually
physically locked in anytime they could have left that house and gone to the
police station or at any time they could have gone council. What they don't
understand where you have to get across is English is their second language it’s
very poor they're very poorly educated, they don't know the systems, they don't
trust the authorities all these kind of things you have to try and draw out. So
that’s one of the real complications the prosecution is to try and build all that
up and all the time the defence lawyers will want to be trying to reduce that. So
all the time in the court case it was all this isn't relevant this isn't relevant and
there were lots of legal arguments about that. But how at the beginning of this
investigation are you going to have evidenced all this gathered the evidence you
know how do you tell people that they are being exploited etc. So basically
answer is lots and lots of long interviews, so VRI video recorded interviews so
that we could literally start at the beginning you know how did you first you
know when you were in Lithuania how did you first find out about coming to the
UK and literally going through that whole visit here. Lots of it will be irrelevant,
but then it becomes relevant when you start trying to explain the manipulation
bit. So what's your English like, how many lessons have you had, would you
know if someone’s talking to you now, would you understand them stuff like
that, kind of the just trying to explain the whole thing. So for us at the reception
centre that was very much you know one of our key goals was to was to
[inaudible] but what you got to remember is these victims are still in a state of
shock, and lots were worried - more worried where their next job is, where their
next food is coming from rather then tell the police their life story. So it is very
hard like that and then you mustn't be too manipulative in the questions you
ask because then the defence will say you led down this road you know you
you've manipulate the evidence. So again it's got to be very much clearly
documented. The UKHTC do give out some advice on what kind of things you do
what sort of questions you should ask so there is some national guidance. But

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again as I explained earlier on each case is different so the trouble is they can't
give any really detailed stuff out. Just trying to think what else was big issues in
the endeavour trial. So we had that we had lots of worries about how we were
going to get them alternative accommodation and work because then are we
treating these people more favourably than the general public. So there were
lots of concerns about you know, oh yeah come with us and we'll give you a nice
house and set a good place to work. Well why aren’t you doing that with
everyone? So it was very much having to give those options, general options
and they still had to do it themselves. You've always got to remember that
whilst they are vulnerable victims because the way they are being exploited
actually they are very intelligent people, very brave in fact they came to another
country and all they want to do is work hard. So if you lead them along the right
path then they are able to look after themselves and do it, but it’s just a case of
leading them down the right path. The ideal opportunity for us is to then to get
them settled within the UK so then they can come back to court. Because what
we did find was two or three victims went to the NRM system which you have
this month and half period cooling off and then they were released out the
reception centre. All they then did was to go back to the exploiter and start
being exploited again and that’s because they weren't given enough support
and guidance on how to set up a new life. So we had two who actually went
back into the cycle and we had to rescue them again because they literally came
out and didn't know what to do and thought I’ll go back to matey boy because
at least I had a roof and work so I’ll go back again. Also what happened was as
we were clearing one house out there were phone calls to the victims from the
exploiters coming in on phones saying alright, you know I’m taking over this
address now so the one of the offender that had been exploiting at a certain
location he’d been arrested and someone else had already taken command of
that house. Right I’ll be the person involved with that and then we'll ring around
didn't really know who had been taken to the reception centre and who hadn't
and they were ringing the victims saying oh there's a house here that I’ve got
control of.
S1 So how many people were you looking at during the investigation? In your
professional opinion how many offender would you would say was in that
network?
S2 Well the trouble is you have different tiers. I would say the organised crime
group we probably had about ten main offenders with lots of runners. Then you
got the alpha male scenario as well but I told you about before where certain
people were given little privileges like being the driver, or being the rent
collector for that house and therefore were given a discount and again they are
more loyal to the exploiter. So alpha males you could be talking fifty probably.
We're talking about a thousand over crowded houses in Wisbech so I mean that
gives you the sort of scale now not all of these people will be victims because
some of them will be living there but not being exploited, or being exploited a
little bit. You know I’ll give you a few quid because I haven't got a tenancy
agreement and I could sit on the sofa sort of thing. So there is a lot degrees of

0909274 74
that going on but we're only concentrating on the really bad ones. So quite large
numbers.
S1 That's interesting. So moving away from then main investigation and the issue
that is going on and looking forward. The final question is to understand
prevention. What of action is Cambridgeshire police do to prevent modern
slavery in its area going forward?
S2 Right so things we are doing. First of all we're educating partners to think
outside the box. So who would have thought that a bin collector would be the
main source of information about overcrowded housing which would lead us to
a house? So we're educating people about this crime that probably would of
never been involved in crime investigation before so like bin collectors, doctors,
dentists, teachers, social workers, mid-wives, literally anybody that goes into a
house or knocks on the door, postman anything like that. So we're basically
giving them a briefing on it and the whole purpose is to tell us if you see
something suspicious let us know. We then are giving them a list of like signal
crimes such as lots of mattresses out the front of an address or lots of rubbish in
the back which are peoples belongings, or industrials bins instead of normal
bins. Or you know the fact there is lots of beer bottles etc. etc. Anything that
indicates that that house is overcrowded and brings that intelligence into us and
we will go investigate it. Then that’s the general community and people that are
involved in investigations. We’re then talking to housing enforcement officers,
your surveyors, your estate agents, all those kind of people and again saying this
is the scenario, anything like that anything let us know and report it. We’re then
using partnership working. So you’ve always got to remember is crime isn't
always the answer. So what we’ve actually done is do a lot of work with the
housing officers where they've gone into a house and said no this is
overcrowded and they've then worked hard with the landlords. So a lot of the
time a lot of the landlords are completely unaware because what happens is the
landlord will rent it out to the exploiter thinking that the exploiter's going to put
his family himself and his family in there, and actually what happens is then 10
to 15 people move in. But if the landlord never goes to that address but the
payment is made regular and everything then they're completely unaware and
uncited by it all. So a lot of the time we're working with the housing officers,
working with the landlords saying did you know this did you know that, no I
didn't, okay so now we need to reduce the numbers in the house etc. you need
to be going to that house a lot more to visit etc. so we’re working with that.
General awareness. We’ve found actually that publicity isn't the answer
because it gets kyboshed by politics and stuff like that. So we try and stay away
from that but we can give simple messages out. So gain to try and highlight to
people that actually we need you to report it to us rather than turn a blind eye.
We've used councillors we've used all these different kind of avenues which we
would have never done before. So that’s sort of the crime prevention stuff that
be going on and we’ve certainly become more aware of crime trends and
keeping human trafficking in the background. So for example, and because that
really fits in to the Cambridgeshire constabulary priorities which is all about
vulnerability identifying risk and all that. So it fits perfectly if two three years

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ago when our main focus was on dwelling burglaries detection rates it probably
wouldn't have sat very well but now it perfectly into what we’re trying to
achieve. So you know officer briefings etc. etc. we're doing a lots more and it’s
the case of in custody, to the custody sergeant if this person comes in and
they’ve nicked a loaf of bread and some milk then you know let’s start thinking
right okay where you from. Rather than doing an interview around you know
the offence and proving the offence let’s have a sort of a community
intelligence interview; where do you live, how did you come into the country,
you know stuff outside of the investigation so that we can start building that
picture. I’m not completely confident that we're hundred percent there. But
that’s the kind of vision we need to have is like you know people start thinking.
And likewise you know if a PCSO goes an address because there is a complaint
about a car that’s always parked on double yellow lines and when you walk into
the address there are lots of people there don't just think oh the yellow lines
now let’s think okay, what’s behind this, let’s start asking questions how did you
come here and all that. It’s all good community engagement anyway for me. So
that’s the kind of mentality, changing officers’ mentality. I think we’ve got to get
smarter with our IT and with intelligence. Identify community intelligence more
and then have a way of co-ordinating it all. So you is there, are the certain
addresses, or are there certain locations where we always see the same people.
Are we looking at our crime trends and identifying peaks and troughs and trying
to explain that, rather than crime answer let’s talk a community answer. For
example violent assaults. Usually peak in the summer and we put that down to
the hot weather and the people drinking more, well actually it could because
there is no crops, or there is no work. Are we linking in the labour providers and
saying what’s the work like out there at the moment, is it all dried up things like
that. Are we talking to the community saying how are employment levels etc.
You know is there a big rush because what also happens is the exploiters just
want new victims in because the first month, month and a half they makes lots
more money out of them than they do predominately. So their whole focus
drive is to get more and more people in they don't care there's no work at the
end. So they just keep them coming keep them coming, keep them coming as if
they play up, they get thrown out. So do we see are we looking at our homeless
levels and then saying actually it’s peaking at the moment, why is that? Then are
we talking to the homeless people saying well where did you live, who was your
rent collector, why did you find yourself kicked out. Because normally that
would be done by the council, and the council would then think about telling
the police about this and traditionally the police will go ah well we don't want to
know about this why you telling us. So it's trying to link these intelligence paths
together is what we need to do. And we've got to get regional do you know
what I mean. The organised crime groups they’re following the crop trend.
They’re also are linking, there are very strong links with Boston, Spalding and
Kings Lynn with Peterborough and Wisbech and yet how much intelligence do
we know about these organised crime groups across the borders. They will
often have a house growing model at Wisbech which the house was there, but
they were working in Norfolk and Lincolnshire. But how many Lincolnshire
officers would go onto a field and start talking to people with the view of trying

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to identify if they are all victims of human trafficking it never happens. So
therefore you need to start getting other counties involved as well so you know
a regional kind of coordination is needed. And that’s another thing all our
intelligence system our Intrepid system doesn't talk to Lincolnshire Intrepid
system and you know it goes on doesn't it.
S1 Yeah... I’ve heard that
S2 I know there's a structure there for regional crime but the whole thing about
the system is ERSOU and NCA are only interested in the big jobs quite rightly
because they only have limited resources. So all this other cross border smaller
stuff, because it is small to begin with, its only when you got to Pheasant and
Endeavour when then suddenly NCA came, wow we never knew it was this
organised, it was this big, that they came and helped us. But before that it's all
just little bits of snippets of intelligence, and without someone driving it and
saying we need all this information, that’s when you start seeing the bigger
picture. But you need that drive and if there's no catalyst, that there’s no…you
know, don't get me wrong the only reason why we found out about Wisbech is
because it was hitting our crime figures etc. that’s why started going into it, we
from that we had community cohesion issues and that’s what my driver was,
but then obviously when we found out what was going on than it started to get
big, but yeah how many other places in the UK haven't looked at it yet. And this
is the other thing is that a lot of the time the victim aren’t in your face saying ah
ha I’m a victim. There's no visible injuries, they're not walking around big gashes
you know black eyes and stuff like that. They're not shouting for it, you can't see
it visibly on them and they don't think they're being exploited. So a lot of the
time in not unless you start looking for it that you find it. For me the benefit is
that already we've seen in Wisbech that when you start tackling it you then see
a general figures come down so our general incidents and general crime in the
Fenland area reduced because we're tackling that. But no one would have said
we need to get rid of our shoplifting figures I know lets tackle human trafficking,
or we need to reduce our number of murders lets go and tackle human
trafficking no one had made that link, and only when making them links in your
general crime. Because it’s general rather than one crime. And of course you've
got to have that driver you know you've got to have that person who’s sort of
saying actually this is wrong right how are going to get the people together. Its
extra work for people in the short term and medium term its lots and lots of
work it's only in the long term do you start to see the benefits but people need
to know that vision and I don’t think there is enough cases out there or case
studies to demonstrate actually the impact it’s had… Okay.
S1 Brilliant I think I'll stop the interview there. That's brilliant thank you
S2 No worries.

0909274 77
Appendix D – Practitioner B Interview Transcription
Practitioner B
S1 Researcher
S2 Practitioner B
Speaker Transcript
S1 Now, okay. Welcome. So I've got to jump straight into it. So when did you
become involved into the investigations model slavery in Wisbech and what
previous knowledge did you have on model slavery?
S2 Okay. So I joined Operation Endeavour in August 2013 as a detective sergeant.
I came from uniform policing in Peterborough [phonetic] so I've had no
previous experience or knowledge of Wisbech or modern slavery.
S1 Okay. So in regards to Wisbech came along, do you know how decision is
made or just acknowledgement modern slavery was taking place in Wisbech?
What was the sort of evidence and the size?
S2 Okay. So when I arrived, an investigation team had already been set up a
couple of months earlier by [officer name] who is now a DCI. She was the
investigating officer. When I landed the brief that I got was that they…the
force had been receiving overwhelming intelligence by and large created by
Operation Pheasant and the partnership work that they'd been doing. Which
had indicated that there were multiple groups operating in the Wisbech and
March area which had indicators of exploitation and what we now know to be
modern slavery. Obviously at the time it's human trafficking, that's how we
labelled it. It wasn't specific to this is one group doing it, I think at the time
when we started there were maybe five groups that we were looking at. The
difference to other investigations I've worked on is that we were looking at
individuals, so for example I have the [suspects] who were coming to court.
We were looking at them, we were looking at another couple of groups that
were similar to them, but we were also looking at labour companies.
So…which was different to any other kind of investigation I'd worked on. So
they were each set up as a different project so Operation Endeavour was the
overarching investigation and then there were a number of project groups
that sat underneath that. So I think, for example, Value had started off as
Project Idaho and then we had separate ones for each investigation that we
had underneath that. Each investigation interlinked due to the nature of
Wisbech and they were providers and gang masters. There were lots of links
between all of the groups, but we started off with the [inaudible 00:02:36]
categorised them in that way so we could approach it from that way.
S1 Okay. So it's quite interesting because how did you approach each type of
investigation then? There was multiple, it was a different approach in an
organisation or was it different just compared to a person or an individual?
S2 So it was [inaudible 00:02:55] that this strategy and we…I'm sure that her
approach was that she priorities risk. So, for example, we were focusing
initially on a particular guy called [suspect] which was one of the projects first
because we had the most intelligence related to victims. So it was a very

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victim led approach, where is the most amount of risk. And in regards to the
differences between investigating individuals and companies, the main
difference was us utilising the Gang masters licensing authority, the GLA. So
because these companies were licensed by the GLA that meant that we could
then, working in conjunction with the GLA and utilise their investigative
powers, there's a lot of behind the scenes research the GLA can do on these
companies before we turn it over to an investigation. So the initial steps of
those investigations were working with the GLA to find out what we could
about those companies.
S1 Okay. So when you say the first step I think you said was research and working
with GLA information gathering. Once you sort of went through that process,
do you then look at kind of tailoring the type of response to start conducting
investigations and to start with evidence gathering?
S2 Yeah, absolutely. So there was a little bit more information gathering that was
not desk based, if you like. So we did that, we did the desk based stuff, the
intelligence reviews. We also were then still sending Operation Pheasant out
with them. Got the point where we were tasking them, so in addition to their
day job, we may be particularly interested in a house where [the suspect] is
running or we've heard that [they] might be running. So under the guise of
their day to day working Operation Pheasant we would task them to go and do
some overt police work to say…and then they would report back. Right,
there's 10 people in that house, this is where they were working, funnily
enough that's one of the companies that you're now looking at and it would
link together. In addition, we did some further overt work where the centre of
the universe at that time in Wisbech and may still be is the BP garage opposite
the police station. Centre of the universe in Wisbech, it's where all crime
happens. And if you go there at 5 o'clock in the morning what you would find
would be all the gang masters and they'd have mini busses and all the workers
and they'd be piling all the workers onto the different mini busses and
directing them. So we set up…I want to get this right. Operation Pheasant had
previously set up an operation called Operation Darley. Now Operation Darley
in its infancy was a traffic based operation where they'd get traffic officers to
check the mini busses, check that they were all okay and that everything was
legitimate. So what we then saw as an opportunity was we could use under
the guise of Operation Darley we could run an Op Darley at 5 o'clock in the
morning, but put in some of our Operation Endeavour investigators. I think
the SIO went on that one as well…put them in on that operation under the
guise of what is a traffic check and while traffic were checking all the cars and
all the mini busses, we'd have our investigators speak to some of the people
on the busses. Where are you working, who is it you are paying your rent to
and that was a big intelligence gathering opportunity. And again, that helped
frame our responses to where the risk was.
S1 Okay. That's interesting. So in regards you sort of mentioned there was some
Op Endeavour officers. Was there any particular skills that was required to be
those officers? Was there any sort of challenges you had to overcome such as
language barriers?

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S2 Yeah, language throughout was barrier in Wisbech. And particularly
investigating in Operation Endeavour. So we were very lucky at that time
Operation Pheasant had a PCSO [name removed] who speaks off the top of my
head Lithuanian and Russian. And Russian is the common language if you like
in Wisbech. If you've got someone who speaks Russian, generally you can
communicate with most of the community there whether they're Latvian or
whatever, it's a common language. So [PCSO] was part of that operation and
he support Op Endeavour quite a lot even though he sat with Op Pheasant.
So, yeah, we had to make sure we had language skills.
S1 Obviously you've indicated the travel, but you also mentioned in regards to
houses. Was there a particular reason why you targeted these houses at all?
S2 Yes. That was all laid out by Operation Pheasant effectively. So, you know,
clearly at that point…the framework has changed now…but at that point Op
Pheasant was pretty much 100 percent based on, you know, these row of risk
houses, this is where we're going to do the visits. Our houses were defined by
that. The only slight difference is that once we started gauging a little bit more
and getting victims coming forward, sometimes their intelligence would lead
to new houses. So they'd say yeah, there's six people now living at this
address in Wisbech. And it would lead on from there, but yeah, that's how it
was done with the intelligence basis.
S1 Were you ever involved in visiting houses or doing any investigation work
around people in those houses?
S2 I definitely dealt with the victims from the houses. I never went to…I'm trying
to think. No, I never went to one of the houses myself as a supervisor. It
tended to be a uniform response so that it could all be under the guise of Op
Pheasant if that makes sense. We were trying…we weren't in covert, but we
weren't being overt about Operation Endeavour at that point. This was…there
was obviously a day of action which I can come on to, but in the run up to that,
we were trying to make it look like business as usual with uniform officers
from Op Pheasant.
S1 Okay, I see.
S2 So they didn't know we were looking at them.
S1 So in regards to then identifying potential offenders, how did you go about
there as in talking to or reading the literature or talking to other people? It's
common to not be able to distinguish between who were offenders and who
were victims?
S2 Yeah. It's…it was pretty straight forward in Endeavour. That was definitely the
case, you do have this alpha thing which I'll go onto in a sec, but it was pretty
straight forward because in this case, we were saying that by and large our
offenders were people that were organising the work and collecting the rent
and paying the wages. All you had to do was ask the person at the house very
straight forward questions. Who do you pay your rent to? Who comes and
collects that from you? Who gives you your wages? And certainly what had
value in the [suspect] case what you found is 100 percent of the time the
answer would be either [suspect names] which made it very straight forward.

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Because that matched the intelligence we were getting from Op Pheasant,
from Op Darley, you know, from local police officers in the area. And that all
matched. There were certainly other cases where it becomes more difficult
because yes, it does happen where the [suspect] would maybe delegate rent
collection, for example, to somebody who is lower down the chain, potentially
somebody that's come into the country they've helped to work, they've been a
good worker, they've been trustworthy and has moved up the ranks from, you
know, having all of their money taken off them to well, we'll actually give you
a little bit more money, a little bit more freedom if you go and collect our rent,
but we didn’t tend to have so much of a problem with that in Op Endeavour
because the intelligence was so clear about these people.
S1 Brilliant. That's interesting. So in terms of I suppose then making their money,
those exploiters, how did they operate and in terms of keeping some of that
money hidden or trying to keep it legitimate, did they have any methods in the
way of laundering it to keep it sort of a cash economy?
S2 It was a cash economy from what I can establish. We had some real problems
in regards to the money. I'll be straight in that prior to our big day of
action…executive day of action…on the…October the 13th, the word got out
that we were going to deal with our warrants because the BBC leaked the
story. We had major problems with press, major problems. So the BBC had
been doing an investigation into Wisbech, doing a documentary piece. They
had been working with Operation Pheasant going out and doing some visits.
What they'd also been doing was quite a lot of fact finding in the area
themselves and where actually quite blood thirsty and hungry for the
information. So much so that they would do things which were stepping on
the police investigation. And, yeah, the SIO and the BBC had a meeting, we
met regularly to try and share information and as much as could be done as
possible to ensure that the BBC were telling us things that they knew.
Because, you know, we were trying to stress to them that if you know where
victims are that are at risk, you know, and something happens to them and
you've not told us about those victims in those houses, then clearly you've got
a liability issue there. So they started to share more, but they had a real tight
deadline to release this inside out program that they wanted to do and we
kept pushing them back and back and back saying no, we want to do an
enforcement day and organise a day of action which is going to take us quite a
long time to set up, lots of staff. It was going to coincide with the launch of
the NCA, that's another reason we wanted lots of NCA resources. The NCA
were rebranding and launching on that date which is another reason why we
did it on that day. And in the end, the BBC said no, we're going ahead
regardless and they sent letters to our defendants…our now defendants…
because they legally have to send them notification letters that they're about
to do a program on them and give them their legal right to respond, right to
reply. So although it didn't tell them they were having…they were subject to a
police investigation, it basically said we know what you're doing, this is what
we're alleging you're doing and then funnily enough when we then went into
the houses a week later, almost no money was found. We did have

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intelligence that in the week running up to the day of action there was quite a
lot of movement, so for [the suspects] there was what we call a business
address. So they had their home addresses [one suspect] in Kings Lyn and
[other suspect] in Wisbech, they then had multiple rental properties which
they had victims in. They then also had what I would call a business address.
And that was in Wisbech and it was a house where [suspect] had previously
lived and he had all his mates living with him. This was at the point where he
probably couldn't afford to have his own property and live in it as single
occupancy. So he lived in this [road name removed] address. He had a few of
his mates there living with him, Alphas, I would describe them that he
surrounded himself with. And it was quite a big property and he used to
maintain lots of the cars and lots of the mini busses from there. We found…on
the day of action we actually found quite a lot of evidence there that was
damning to [suspect] in regards to paperwork, et cetera and ledgers, but that
premises, we started to hear after they'd had the right to reply from the BBC
and before we went in a week later…about a week later…there was a fair
amount of movement at that address. You know, bins being moved around
and cars coming and going and all the normal…this was like officers and
residents. So as far as the money goes, we've never found it, but everything
suggests they were running a heavily cashed based business. [Suspect] also
had links to a pub in Wisbech. I think it's called the [named removed]. This is
where it gets quite complicated. There was a business man, [removed]. Now
[business man] knew [suspect] were best mates, they’re like family. Every
time [suspect] gets arrested [Business man] visits him, looks after his children,
helps his wife. [Business man] at the [pub name] over the time where he was
with [suspect] earning a lot of money. We know that they're takings, the
money going through that pub trebled. It was earning nothing, hundreds of
thousand Pounds were then going through it. At one point, I think in [suspect]
defence he says that he worked at the pub at one time. So it wouldn’t surprise
me if it was being laundered, potentially sort of in that way. In addition to
that, the case that's currently at court is in relation to fraud and money
laundering. That's what they're there for now. And that method was the
people that they had in the houses they were controlling. Some of them that
were under the greatest amount of control and were in the greatest amount
of debt [suspects] they said to the people we'll knock 100 Pounds off your
debt if you go and open a bank account. This came out quite late in the
investigation. We didn't realise this at the beginning that it existed in
exploitation. They said if you open a bank account we'll knock some money
off. The bank account was always registered to one of the control addresses
so the defendants had complete control over the post, for example. The cards
coming to the addresses, the PIN numbers, the internet banking details. And
what we then see in written diaries from the defendants, they've got
passwords for all these accounts, they've set up on line banking, they've set up
sub accounts on the on line banking. And fraudulent checks have gone
through and that money as a result of the fraudulent checks you can see it
goes into this fix and controlled account and then goes out into the defendants
own accounts or gets cashed out at a post office next to [suspect] home

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address. And they used PayPal, again, not really sure how, but thousands of
Pounds worth of fraudulent PayPal transfers go into these victim accounts and
again they get funnelled out the same way. So the exploitation…the person, if
you like…at the centre of the exploitation is just a human commodity that they
use them in multiple different ways to make money. It's completely a business
model based upon making money, it's nothing to do with the person. You
know, as far as these cases in Wisbech go, they're not exploiting people
because they're bad people that want to abuse humans, you know, that's not
their motivation. They're not motivated by harm that they cause to these
people. It's not like that, it's purely business. And, you know, we can go on for
example another money making scheme is in relation to the sham weddings.
So, for example if you have a girl who's in a lot of debt to the exploiters
because they won't give the girls as much as work…this is what was happening
back then…they wouldn't give the girls as much work so it got them into more
debt. They controlled them so that that happened. So they became more and
more dependent upon the exploiters and they became more and more
desperate and some of the girls they had young children and that made it
really, really difficult. They became really desperate so they'd get to open the
bank accounts and they would also say to them, you know, you owe 1,000
Pounds to [suspect] we'll knock 900 Pounds off of that if you go to London
House and have photographs taken with some Indian man. Give us your
passport for the day and if you have to get called to a hearing, you know, you
go to that hearing and you say that yes, I love this man. You know, so…and
they gave nothing from that. It literally was…the money would come in and
then they'd have to…it would go straight out again to [suspect]. So again, it's
the human commodity concept if you like.
S1 That's really interesting. So given that the Modern Slavery Act was passed in
2015 and obviously the investigation started around 2013, at the time in terms
of legislation and law and the type of crimes that were being committed, what
was challenging about that?
S2 Okay. This is the most challenging part of Wisbech. So we had human
trafficking legislation which I think is the treatment of claimant's act, 2004? I
can't remember the section, but that was the act we were using. And as
investigators we very much said that this was human trafficking because…not
in all cases…but in some cases they were organising the travel, facilitating the
movement of these people from poor areas of Latvia…mainly Latvia…and
bringing them into the country on the promise of a better life and they were
then exploiting them. You know, they were doing this for the purpose of
exploitation. The CPS had a very different view. Where the CPS struggled was
around the issue of consent. The CPS very much felt that because these
people had willingly come in, even if they had been coerced or misled or even
lied to, they felt that because these people consented and were consensually
going to work and did not have chains on the doors and, you know, weren't
being forced…it wasn't forced labour…they said that that wasn't the case. So
they wouldn't accept human trafficking all the way along. Another option that
we had was their slavery legislation that was in existence before the slavery

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act which has dropped out of my head, but that's effectively forced labour. It's
where you say, you know, they have no choice and again, it was the lack of
choice issue that we had problems with. So legislation was not fit for purpose.
My understanding I think is the new month slavery act specifically sets out the
issue around consent and makes it a bit easier for the CPS. So we have those
issues, but what's really interesting is not just at Endeavour, but across
Wisbech as a whole, you do have this real interesting phenomenon of where
you have activity which more often than not does not meet the threshold of
modern slavery. So back then it probably wouldn’t have met the threshold for
human trafficking or slavery, and even now it probably wouldn't be captioned
into the modern slavery act. It's exploitation, we're saying it's not right, but
it's not at a level which is severe enough that it would captured by the modern
slavery act, I'd say. And about two months ago, a consultation of what came
out of BIS…that's B-I-S…saying there is a phenomenon in the UK which exists
and it acknowledged this…and it was a report that was looking into something
called labour market exploitation. Saying that the modern slavery act is fine for
modern slavery, but actually, there's a lot that goes on in this country which
doesn't…still is not captured by that. And, yeah, we have assault, fraud, theft,
you know, tenancy or landlord restrictions. We have all of these that are at
our disposal and the GLA regulations, actually we have no collective offense of
exploiting somebody for…you know, in this way in regards to labour
exploitation which isn't quite modern slavery. So they're creating some new
offenses. I will…if you like, I'll send you the report. So I've got the consultation
document and then I've got the result that's just been published a couple of
weeks ago. And they're now going to create a director of market labour…the
market labour director…and they will join up the various different agencies
that investigate this type of crime. So the GLA, police, certain elements of the
HMRC and then there's another really tiny department which I can't
remember, but they're going to join them all up and create an intelligence
HUB. And the market…the director will have control of that. He will be able to
formally request the police force's assistance and it can go both ways. They're
going to create some new offences which will capture some of this offending
and they're also going to give GLA investigators greater powers. So at the
moment, for example, the GLA can investigate up to a certain point or have
certain legal powers. For example, they can't arrest somebody in about 99
percent in circumstances that sit in labour exploitation. They can arrest
somebody for using an unlicensed gang master, but they can't arrest
somebody for being an unlicensed gang master. It's really perverse, so they're
reviewing all those powers and they're changing all those powers. So as far as
Wisbech goes and the use of legislation in 2013 what we had at our disposal
was minimal if we weren't charging with human trafficking. In my opinion, to
the letter of the law we did have human trafficking, but having sat through the
trials with the evidence brought out that way at trial, I don't necessarily think
it would have done. Because the victims come across as very willing, some of
them very supportive of the defendants. The first three or four victims we had
in the box could have been there as defence witnesses, you know, they were

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there saying [suspect] helped me. I was sleeping in a field, you know, and
[suspect] gave me a job and a roof over my house. I may have been earning
only 10 Pound a week, but I wasn't sleeping in a field. So actually, given the
burden of proof that you need and the severity of the human trafficking
legislation, I can kind of almost in retrospect see the point of the CPS.
Although I don't necessarily agree, but if you're not careful, if you use this
labour market exploitation and you label it as modern slavery or label it as
human trafficking, you can almost water down those offences. And that can
do other cases more damage. So it is…there is certainly a tiered approach
that's needed or legislation that needs to be tiered to recognise the
complexities and severities of what goes on in somewhere like Wisbech.
Interestingly enough though there is…I'll have to pull it out for you…there was
a guy in…I want to say Norfolk…who had done exactly what our guy [suspect]
had done. So our case that ran in October, November, December last year was
very similar to this case that ran in Norfolk. And he got something like 11 or
12 years inside and a really helpful guidance document was drawn up by the
judge which was about three or four pages long which listed all the
aggravating factors that ought to be taken into consideration when you're
looking at sentencing somebody. And sort of size of the business, you know,
money earned, all those kinds of things the impact on the victims. And ours
met the same, but we would know…you know, ours got 14 and 16 months
respectively. So there was a real disparity in sort of the sentencing and the
trials. Even though it was gang master offences they were being tried for. So
the legislation was an interesting point because when it comes to what goes
on in Wisbech, you can use human trafficking, slavery, the modern slavery act,
all your fraud and other offences or potentially the GLA offences. Or these
new offenses which are coming. So it's a really a complicated area.
S1 Sounds like it.
S2 Yeah, it's not easy.
S1 Just going back to you're talking about some of the victims almost can be
acting as defendants, how tragic was it to get people to cooperate, to make a
statement, to get that type of evidence?
S2 I think in all honesty, that's where Cambridge has been extremely successful in
comparison to other forces. So I meet other forces around the country and
even in subsequent investigations that I've done, simultaneously with other
areas. So we've maybe gone and done a day of action nationally. We get 20
people into a reception centre, 15 of them give us statements of the victims
and we keep them on board. They take 30 people to a reception centre and
they never want to talk to us. And it is so important that you use the language
skills of…I mean, we're lucky, we have multilingual support officers. We have a
fantastic network of interpreters. Other areas don't have that, I mean, I don't
know any other areas that have multilingual support officers, for example.
And so getting them to engage initially is difficult, but you have to use your
language skills. You can't just pick up language and talk to people via an
interpreter over the phone. It doesn't work, they don't buy into it, you don't
get any emotional connection. You have to use a human being. And if that

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means that I'm spending an absolute arm and a leg with an interpreter with
me for two days and it's the same interpreter so the victim knows who they're
dealing with, well then that's what we'll do. And yeah, that's absolutely how
we did it and then also…so we've got 100 percent success rate in getting all of
our victims to court last time and we've just finished our victim evidence
yesterday and again we've had 100 percent success rate of getting them all
this time. All from 2013 and given the fact that we're not 2016 and everyone's
moved on with their lives, you know, that's been challenging. So the early
appointment of the victim contact officer is the key. So when you arrange
your investigation you have core roles…and this is nationally. So disclosure
officer, OIC, you have core roles which is set out in investigative guidance.
When you investigate modern slavery in whatever legislation you were using,
you have to add another core role from day one, and that's a victim contact
officer. They have sole responsibility for the welfare and maintaining contact
in relationships with the victims. And you have to understand the people
you're dealing with. So for example, still worked long days in factories. So you
can contact them by phone and if you went to go down to see them they
wouldn't be there because they'd be at work. And if you went out late at night
they'd be annoyed because they want to go to sleep because they've got work
the next day. So you'd learn that you text them, because if you text them,
they can probably get a friend to translate or they might be able to understand
a little bit of the written English, or they can Google it and then they can text
you back on their lunch break. They all use Skype so we started to use that
especially people who were going back home, we used that quite a lot. So you
have to be really inventive and there are…I mean, the victim issues we could
go on to be a dissertation itself…but I think a lot of people fall down where you
have this national referral mechanism where you put the victims in for
trafficking. Whether you're prosecuting trafficking or not, you can use that,
it's fine. So we did that with quite a few of our victims. Now, I think where a
lot of people fall down, is you refer the victim into the NRN, they then
automatically get housed with a charity for 45 days where they get the
opportunity to get support, rebuild their lives, decide where they want to go,
et cetera. What I think investigators tend to do and they fall down, is that they
put them in the charity and think that’s it, the charity are looking after them.
It's completely flawed approach because the charity, although they're getting
paid from the government, they're equally stretched, they maybe don't have
the language skills, they might have an interpreter that pops by every now and
again. I found that they sometimes deal with the victims on mass so as a
group they'll hand out leaflets saying this is where your nearest job centre is,
not an individual approach. And before you know it, you've got victims that
are saying hold on a second, I was in a better position when I was living with
my exploiter two weeks ago. At least I had, you know, hot cooking facilities
and my own…I'm now at a B&B, I've got no control over my life again. So you
have to make sure because there's loads of barriers where you're going to lose
people in that 45 day period because they get really pissed off. They get really
annoyed that this has been done to them and so you…I mean, I send drive
officers down to Dover regularly to go and spend three or four hours with the

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victim just to help them. Basic things like how to get a National Insurance
Number and okay, granted, that might not be a police role, but if I want these
victims to come to court in a years' time, they need to trust us. And they also
need to be safe, alive and well and it goes hand in hand. So it's a really
complex issue and it's resource intensive, but it's absolutely necessary. Yeah.
S1 So what we're going to do is almost wrap up in a bit. So as mains really going
to focus on sort of just your kind of honing in on your knowledge and
experience in some of those kind of lessons learned. You sort of highlighted
the importance of having a key role of somebody to connect with victims.
Looking back in a way or even looking forward, in regards to looking from case
of modern slavery or exploitation, working on legislation supports. What are
the kind of signs or what kind of indicators do you think that it was a sign that
a case is happening?
S2 So indicators for modern slavery? So if someone was to put some intelligence
in front of me now and I'd have to assess? Right. Because that happens all the
time now. So depends on the nationality. So you get different phenomenon
within different cultural groups. So as an example, I don't think we have any in
Wisbech, just to give you some context, Slovakian…Roma Slovakians house
victims with them in the family home. What you tend to see more with the
Lithuanians and Latvians is that they'll rent out into properties and put as
many people as possible in there and claim their rent that way. So I
would…depending on the nationality be looking for certain markers. So if I'm
looking at Slovakian piece of intelligence I'd be saying, right, who's living at
that house. I see three people there, they're obviously not part of the family
set up. That would be an immediate indication to me that they're probably
victims of trafficking. So I would be looking for disparities in ethnicity or social
standing because the victims tend to be from very vulnerable, poor, either
often illiterate, they have maybe some health problems. So if, for example, I
went to visit [suspect] three years ago who's quite charismatic, capable young
man who's clearly running a decent business and actually in there are two or
three people who are clearly nowhere near as capable, and, you know, maybe
they're sleeping on mattresses on the floor and his bedroom has got a TV and
a nice bed and he's very well looked after, that's a good indication that there's
a power disparity there. What's happening, what's that relationship about? It
depends on the circumstances so if…what other indicators are good? Like, for
example, cannabis factory. If you get three people out at a cannabis factory,
where have they been sleeping, have they got any food in the house? Have
they got their identity documents on them? Do they know the city that
they're in? They probably don't. Do they know the address that they're at?
They probably don't. How did they come to be in the country? Do they owe
money to people for their travel is a really key one? How did you come to be
in the country, are you in debt for that travel? Because actually if they're in
debt, that's number one. Number one is debt generally because the debt is
how it allows the exploiters to control them. Because especially in the Eastern
Bloc, there is this real culture that if I'm indebted to you, then you hold power
over me, you know? People don't just say well I don’t give a shit about that

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200 quid I owe you. That's not how it works. So that's very much how it works
in Wisbech. People are trapped into this debt bondage in different varieties
of, you know, of extremes in that, but debt bondage is one of the, you know,
key indicators. Do you owe money to anyone? And also, do you have control
of your own wages or does someone control those wages for you? Is a really,
really strong one. Some of the agencies are getting really wise to it now, they
make everybody have, you know, their own bank accounts, et cetera, but all
exploiters do is take control of that bank account and keep hold of that card
and if I stop somebody I think might be a victim. The first thing I probably
want to do is look in their wallet. Are there any bank cards and is there any
identity documents? If there's not, then I'm going to be worried about that,
really. So those kinds of things.
S1 That's interesting.
S2 And has the defendant got a pocket full of bank cards. Because that happens.
S1 Yeah, I see that, definitely see that. I think, really, I suppose, that's really
covered. Because my last question was around giving advice to other
investigators, but I think you've kind of nailed that really in terms of what to
look for. Unless there's anything else.
S2 All I would say is that if I…there's a few documents which I can send you which
might be of help. I've just written a practitioners guide which is going to
be…just have to check one thing, sorry. Yeah, that's fine. I'm doing…I've just
written a practitioners guide which effectively, from what I've learned about
modern slavery, what do cops on the front line need to know. So I can send
that to you because it's got all my indicators and stuff in there. And first steps
how to deal with victims and things. There's the labour market review which I
can send to you. When we finish and end of Part one I'll call it, I don't know if
you were around then, we set up this whole…we set up a conference, were
you around then?
S1 I didn't do the one in Wisbech, I did the one in South Cambs
S2 So, no. About a year ago, January, February after the last trial, what we did
was we got the barrister prosecuted in the Endeavour trial. Me the officer in
case and [name removed] who was the SIO, we sat down and did a learning
document. What would we do differently? What were our learning points
from Op Endeavour? And the barristers fed into it and we did a day at
headquarters of key people throughout the organisation and the barrister did
a whole presentation on where some of the…where we went wrong, but in a
really good way. And I think I've got the Power Point and the learning
document.
S1 Brilliant. That would be fantastic. That would be absolutely brilliant.
S2 And what…so even now, for example, I've now launched Operation Launch.
I'm now doing an investigation in Peterborough which obviously different
completely different, but all the principles I learned then, I'm not making the
same mistakes. Basic things like visual evidence. We were poor on our visual
evidence in Op Endeavour you know, we didn't have all the technology that we
have now. So when I went in for Op Launch, you know, we had tuServ at every

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single address. You know, every inch of every address we've got covered.
Photographed all the victims in situ with evidence gatherers come around. We
didn't do any of that in Endeavour, you know, so more basic investigative
things which until you've taken a case to trial, you can then really start to see
where your gaps are. So, yeah, I'll send you that document.
S1 That's really helpful. And that last bit was really helpful as well.
S2 Good, good, fine. So has that been helpful, yeah?
S1 Very helpful. Thanks ever so much for your time.
S2 Have you got Donna Watts on your list to speak to?
S1 I have. Because I have a question was who to…if you had anybody else to…
S2 [Officer Name]
(Overlapping conversation)
S1 Because I know how busy she is.
S2 Yeah. If you're talking about Wisbech, then, yeah, as I say…I think what would
be useful for you from [name] is she was there day one, she was the SIO that
got the phone call from [officer name] and said [officer name], there's
something brewing in Wisbech, I need you to sort it out. And it literally, that
was her parameters. Go in as an SIO, as an investigator and help. So that
initial six month journey I think will be quite interesting.
S1 Yeah, no because, yeah. I will do because that will be brilliant in terms of the
narrative around it.
S2 Yeah, absolutely. The only other person I can think of speaking to…are you
speaking to anyone else outside of the police?
S1 Only [officer] from the council.
S2 I'll tell you who you can speak to. I'm really sorry for this because he can talk
more than I can. It's a chap called [name} so I'll send you his details. Now,
[name] works for the gang master's licensing. And he was given to us, he was
part of our team, he was an investigator on Operation Endeavour. There is not
a single thing he does not know about Wisbech. He's an absolute phone book
of how it goes on and what happens. And he'll have a really interesting other
side of things because he'll understand more around the labour market and
actually, what disruption techniques and what can we do with partnership
agencies to, yeah, to break the circle of the exploitation. So I'll send you his
details.
S1 Brilliant. Thank you.
S2 Lovely. Thanks ever so much.

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Appendix E – Practitioner C Interview Transcription
Practitioner C
S1 Researcher
S2 Practitioner C
Speaker Transcript
S1 So I'm sort of going to go straight into it.
S2 Yeah, sure.
S1 To start off before modern slavery became a topic in the organisation. What
was your knowledge around modern slavery?
S2 Yeah, in terms of my knowledge, Tom, in fairness in terms of modern slavery
and human traffickers who was then bearing in mind the new Modern Slavery
Act, but I took over the force lead just over two years ago. And when I first
took over the force lead, in terms of knowledge probably the first or, say, the
first even though it was quite an historical job, was probably operation
Cotswold which was seriously organised operation involving an organised crime
group and that dates back to probably 10 years. And that was one I recalled and
that’s one when I wasn't working in Serious and organised and the only reason
it was relevant because when I took over Serious and organised it was the same
time I took over the human trafficking as it was then, force lead. And as a result
of that I was obviously, you know, taking over the lead and I needed to gain
what literature there was in force around what current legislation...obviously
looked at that nationally, but obviously what operations had been undertaken
in force and what policies, procedures were around, previous operations that
had been run so that causes me to look at those jobs and Operation Cotswold
was the most significant. And interestingly that involved an organised crime
group...actually we've recently...I mentored [officer name], which was a
national NCA operation. And I mentored her on that and interestingly that was
exactly the same give or take some of the nominal's that were subject of
Cotswold, but they didn't get prosecuted and they didn't get...well they got
some charges, but they weren't human trafficking charges, but they were very
limited. So really in terms of knowledge that was out there at the time, which
as I say was just over two years ago, really, really limited in terms of what was
available in the force other than one or two approved operations.
S1 So given the impact that Op Pheasant and Op Endeavour did in terms of raising
the profile of modern slavery in Cambridgeshire, the experience that was
gained from Wisbech how was that sort of fed into how the constabulary deals
with cases of modern slavery going forward?
S2 It was really significant and actually that was just coming into enforcement
period when I took over the force lead role. And actually...I actually went...one
of the first things I did was I went to the enforcement briefing because I
thought that was actually a great opportunity to learn a little bit more whilst I
looked at Cotswold historical operations I then became aware quite quickly of
Op Endeavour that was currently ongoing in force. So I thought actually to
become quickly involved in that not from, you know, carrying any lead role in

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the operation at all, but just having oversight of that was actually key because
what that enabled me to do was go and sit as part of the gold debrief which
was chaired by [officer name] where partner agencies and police all sat around
the table, obviously looked at Op Endeavour, looked at what actions needed to
be taken forward as a result of the operation activity on a series of days around
the enforcement period. But then looking at it from a moving forward
prospective what was quickly recognised was this was a growing an emerging
trend in Cambridgeshire and just because Op Endeavour had happened,
enforcement had happened and all of the good work that had undergone with
police and partners working together, that actually that wasn't necessarily
going to remove the problem. In fact, what it actually did was really identifying
and highlight the issues that we faced in Cambridgeshire. And it was a case if
were facing Wisbech I'm sure they exist elsewhere, it's just that it's not on
people's radar as much as it perhaps it should be and certainly that put it on the
radar. So firstly to really answer your question it was a case of it really
heightened awareness and it made people actually alive to the fact that it was
happening there it was probably happening elsewhere. Obviously that was
predominantly around the labour exploitation, so really what it did was cause
the force to relook and also actually as many jobs when you take an operation,
when you analyse it and look into it you realise actually that there's more than
what was just there and then on the day. And as a result of Op Endeavour
resorted other police operations running, which was a significant organised
crime group, Op Eni. And that was actually...it was almost a little bit of a
spinoff, but certainly a lot of the material in Op Endeavour allowed us to
identify other organised crime groups that operated and needed activity
carrying out against them and Op Eni was one of those and actually on a harm
threat and risk basis we obviously score those within the force to deep what
should be prioritised and there's a very set criteria to allow us to do that. When
we actually looked Op Eni and taken a lot of information that came out of Op
Endeavour, it actually scored really, really highly to the extent it was
categorised as what we call a high priority organised crime group. And there's
not many around the country, you know, they're the ones that get flagged to
the Home Secretary because they are deemed to pose some of the country's
most harm, risk and threat to any constabulary and so that was actually
mapped as such. And that was actually dealt with by serious and organised
crime that I was running and the SIO on that was [officer name]. So what it did
was raise awareness across the force that we’ve probably got an issue, identify
other organised crime groups that were operating, but also make us alive to the
fact that perhaps actually not only police, but partners and the public are
perhaps not aware of the signs as perhaps they should be. And actually we
have a responsibility working with partners to get some messaging out there
and obviously do an intelligence request and intelligence gathering exercise to
actually see what are the issues because we have a professional responsibility
to obviously do that knowing that we've got this sort of threat. So it made us
alive to the fact that, you know, we need to make people more aware so that
we can properly gather and assess what real issues are out there.

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S1 So a few questions coming from that, you've mentioned intelligence and you've
mentioned partners. The key thing for me is understanding identifiers so what
are the sort of identifiers for the police and what do you look for and how do
you engage with the public and partners to act on those?
S2 Yeah. There are some traditional signs and indicators of what human trafficking
is. Sometimes there are some obvious signs, but you'll know probably that
human trafficking is a hidden crime and is something that isn't always visibly
obvious to people. People have this image that human trafficking victims are
sometimes kept in houses with the doors locked and bars on the windows and
that's the only way that they can possibly be trafficked, when you know that
simply that isn't the case. People can be controlled, you know, psychologically
through fear which certainly is a common theme and trend for the traffickers to
sort of do to gain the control of those victims, so it's not always easily visible.
However, some of the most obvious signs can be houses of multi-occupancy
where there are far too many people living in sort of very, very squalid
conditions. And obviously the houses are being controlled by the traffickers
and obviously those victims are coming over from different countries and on
the false pretence that obviously they're going to be living in quite different
circumstances and earning far more money than perhaps what they're earning.
But obviously when they get over here, they're put into those conditions and
sometimes it's false labour. Sometimes forced is a word that actually forced
doesn't always mean in the sense that literally they're frogmarched
everywhere, but actually forced because they've got no other option because
their passports and personal documents will be taken away from them. And
unfortunately there is quite a mistrust in the police that some of the victims
have sometimes that will come culturally from the countries that they come
from. And sometimes we don't always help the situation by not being alive to
the signs themselves when they do get reported to us and we have had those
incidences where victims will come forward, but we as police officers don't
always recognise the signs. Again, because actually we know the misconception
is where you're free to walk away at any point. The door isn't locked, so how
can you possibly be held against your will. So sometimes the police themselves
when victims do come forward don't always recognise the signs. We're much
better now, but historically we haven't always been great at it. So as I say some
of the multi-occupancy, having your passports, your personal documents taken
away, they're often common signs. But some of those...certainly having the
passports and stuff removed won't always be obvious to members of the
public, but it might well be obvious to businesses and probably partner
agencies, council people and letting agencies that the property is being rented
from. They are certainly more likely to have an awareness over that going on.
But the members of the public, you know, they'll probably see the signs by
people being collected on a daily basis, sometimes minibuses and stuff and
being too and from work. And some will see numbers of people go from
houses, probably more than perhaps you'd expect a house to actually hold.
Sometimes you will see visible marks. And I'll tell you some of the people that
we've come across, particularly recently, in terms of their physical malnutrition
it's really, really obvious that these people are malnourished, they're in very,

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very bad health. Not all of them are, but these are some of just the obvious
physical signs. Some of them will be solid, but sometimes that's behind closed
doors, so it won't always be immediately obvious to anybody so we can enable
otherwise. And certainly labour exploitation, sexual exploitation are the most
common and sometimes sexual exploitation again that will be occurring behind
closed doors and not always something that is immediately obvious. And as I
say the control, you know, there is this misconception that just because people
can just walk out the door and they're not under control, when simply they are.
So there are some common signs and some common indicators to look out for,
but some of those you do rely on perhaps partner agencies understanding
houses of multi-occupancy. And certainly businesses and certainly your other
partner agencies, particularly around your benefits and where those payments
are not necessarily being made. They've being made to the same individuals,
which are...that should start to have alarm bells ringing. And banks, a lot of the
time there will be bank accounts taken out in victims names, but actually the
use of the bank accounts is by another individual because they will have...they
will actually take charge of their cards and credit cards and withdrawals. Again,
that's not always easy to see because they will be given their pin numbers. So a
lot, a lot of signs and indicators are there, but you've got to do some real work
to actually find out what's going on. It's not always immediately obvious.
S1 So in regards to working with partners and working with businesses and sort of
the different sectors, have you since Wisbech started to develop closer
relationships with those areas...
S2 Yeah, yeah.
S1 ...or closer processes and links between to try and raise the profile, like, you
said hidden crime.
S2 Yeah, absolutely, yeah. I mean obviously Wisbech has got good bedded
partnership arrangements anyway. They simply...they continued and obviously
Op Pheasant around...and obviously you've got your multiagency partner visits
to various premises, particular those in multi-occupancy housing to obviously
try to stop the signs and indicators. So that was already well embedded
through Op Pheasant, which goes back obviously prior to Op Endeavour. Now,
that's good, that's continued, but obviously we've also seen that then get
embedded in Peterborough because we have got...they are our two most
affected areas because human trafficking is often driven by the sort of
employment that's available to people. And it will tend to be historically
around labour exploitation, your factory work and your agricultural work.
Obviously from your agricultural perspective that features in Wisbech, but your
factory work will also feature heavily in Peterborough just because the industry
that's around there. And when we were looking at the intelligence and the
reports and I speak about the organised crime group that historically existed,
which was Cotswold and the recent National Crime Agency, the recent NCA
operation, they were actually a large organised crime group suspected to be
involved in trafficking, they're actually living in Peterborough, operating out of
Peterborough. They did move around the different parts of the country as well,
but they always tended to come back and settle back in Peterborough. So we

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knew we had human trafficking going on Peterborough specifically as well as
Fenland and Wisbech. So Op Pheasant team started up there and the same
embedded partnership arrangements which you'll probably know, Tom, are
also...they're now in place which is run by [officer name] at the moment and his
team there. So again that allows multi...so partnership visits, multi-occupancy
housing just to spot signs and indicators. So that's Peterborough and Fenland
have got really good embedded partnership arrangements where the Op
Pheasant teams visit premises daily to generate intelligence and to safeguard
victims and to get some real early preventive work going on. But in addition to
that Op Endeavour meant that we established really good partnership links
with some of the key players in tackling human trafficking, going from council,
going from the UKHTC, the National Crime Agency because there's a range of
partners that come in, the Salvation Army through the NRM. So we actually
established some really good contacts. So when we have had police operations
need happening to be set up because we've got particular warrants that we
want to arrest or a number of individuals on a small scale or a large scale, that's
really well embedded because we've already got those contacts in now. So
whenever we look to carry out police activity we know exactly who to speak to,
to get what information. And then that really enables us to gather intelligence,
gather information to carry out some early disruption or in fact to support large
scale police operations. We can put that into effect really easily in
Cambridgeshire because of the work that's gone before using all of those good,
embedded established relationships to put in just into play from them.
S1 Yeah.
S2 From them...until now.
S1 Fantastic because what I'd say is that initial identification through some really
good networks. Once there is some good indication that a potentially
organised crime group is in play, obviously you've got your established
networks between partner agencies and forces, how does the organisation
start putting an operation into practice, what sort of evidence are they looking
to gather and sort learning from Wisbech and especially Endeavour, where do
we move from identification to our response in our investigation.
S2 Because that's often where there's an issue so we'll have a very good sort of
reactive response to it, but actually some of the issues can be human trafficking
is quite difficult events to prove. And actually making sure, actually, that that
investigation is strong is terms of gathering all the evidence and getting it
through judicial process which is challenging. And you probably heard from
[officer names], some of the challenges that they had around that and that was
one of the big learning...how do we actually gather the evidence to prove the
offences that are actually being carried out which are more likely human
trafficking than gang license offenses, which often...and other types of offences
where they’d be fraud or some sexual offences that would be separate charges
of those individuals as opposed to painting a full picture. So that the force
recognise that, but actually with Endeavour it puts together an investigation
team, but actually not having prosecuted many human trafficking cases before
certainly of any sort of scale, I think the force were a little bit blind to what

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resources in terms of skill and numbers actually needed to play a part there. So
learning from that what was quite clear was that it needed, you know, sort of
experienced investigators, not just working alone, but clearly working with
partner agencies, getting core roles and responsibilities not dissimilar to how
you'd investigate any sort of major operation, with consideration to IT support
whether that be homes to manage...because there's a volume of information
like that especially when you're dealing with the partner agencies. There's
volumes of information that you've got and be able to manage and you can't
always do that manually. And actually need the right numbers and the right
skills set mixed in with support from partner agencies to do it properly. So in
terms of moving forward, what happened and obviously...then I'll talk about
what's happened since Op Eni and Endeavour and stuff. With Op Eni that
obviously went through the score matrix and that was allocated to our serious
and organised crime team which I was managing at the time. So that is made
up of one DCI, not now, but then because the DCI that sits every now and then,
sits in the CIB managing many other things. But then it was a DCI that sat in
serious and organised, one DI, two DSs and a team of 12 DCs. And obviously not
all of those work in Op Eni because at any one time serious and organised
would run around three or four jobs. But there was a dedicated team of
people...it was in total it was six people with an SIO allocator, deputy SIO and
then your core roles and responsibilities. So you've got some dedicated
investigators there and actually some of us have worked on Cotswold as well,
so they had had experience working on human trafficking operations. And
they're working really closely with other agencies, with the National Crime
Agencies and some of the partner agencies as well and the GLA to get that
offence prosecuted, so recognising that it needed dedicated people in terms of
skills and resources into it. So that was some of the learning and that's certainly
what happened on Endeavour and certainly what's happened more recently on
our launch which is the National Crime Agency operation. I spoke about...which
I'm working with [officer name] with...and that involves the organised crime
group of Cotswold going back about 10 years which we finally managed to
gather some good evidence around. And also it's about...it was so significant
because it wasn't just about putting the right team together to get all the
material through to court, but it's actually around the actual response, the
evidence gathering. That was really, really key because that was a specific bit
out of Endeavour where actually there was such a mammoth amount of
information. And obviously the way technology is has improved and developed
around that as well. But that initial evidence grab, you know, the use of tuServ,
the use of strategies was key, getting the right strategies in place, the victim's
strategies, the investigative strategies. And there's a breadth that we do, you
know, financial strategies and arrest strategies, et cetera, but getting all of that
best practice, all of the learning, we're actually...we believe we lost some
evidence in Endeavour because some of it wasn't collated properly, some of the
stuff that perhaps was asked to be photographed and immediately captured
wasn't necessarily done at the time through a multitude of reasons. But actually
obviously that went through the court Endeavour and the counsel and the
barrister gave some feedback around that. And actually where it would have

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been so much more impacted visually and they were able to display the
evidence, the conditions that some of the people were living in. Getting those
early accounts from people, you know, done differently, that would have
benefitted a prosecution, maybe human trafficking, aided that and
strengthened that hopeful position had they have had that. So learning from
that that's exactly what we've done now. So in addition to getting the right
level of investigators involved that understand human trafficking and have had
some experience or are certainly very capable and skilled officers, then it was
actually around making sure that the evidence we give them is captured in the
right way because obviously the stronger the evidence is and learning from
Endeavour and that's very much in place now, so we've got some good
embedded practices. Actually, nationally there wasn't much out there. Only
recently the APP have come out for modern slavery, otherwise we were almost
forces were almost developing their own best practice because there wasn't a
sort of benchmark or a set standard out there, but now there is, and then there
wasn't. So we were learning ourselves as went along.
S1 So in terms of that learning, moving back within Cambridgeshire, how have you
or how was the force and the constabulary pushing those lessons and that
knowledge to the frontline...to the frontline officers?
S2 Yeah, sure. So I took over as the modern slavery lead and you learn all this
good stuff from Endeavour, so I had a chat with the strategic leader, I feel that
we can learn and pockets of different parts of the constabulary were learning
well and pockets of individuals. But actually we need to recognise that actually
we need to get the learning across the force and also very conscious that the
Modern Slavery Act was impending. We were ahead of the game a bit, we
started having these conversations months and months before, but you always
knew that Modern Slavery Act...that that was going to come into force, so we
need to prepare ourselves for that and so it was really quite sort of timely. So
what we decided to do was form a modern slavery management team, so
essentially what that is made up then is of individuals who are identified and
they're all supervisory level for reason which I'll go on to explain, and we asked
to be identified for those across each of the districts and different areas within
the investigation's department. So what we've got now is a modern slavery
management team made of up of at least sergeant level and as I say that will
come from each district, East Cambs, Peterborough, et cetera. And obviously
we'll have PPD in there. I sit in the crime and op support business world.
[Officer name] is part of that, bringing on her recent experiences from working
on the endeavour operations. And also the Foreign National Offender force
lead which is, as there’s massive overlaps between the foreign national
offender work that's been done and also the human trafficking and a modern
slavery aspect, especially around some the management of individuals and
some of the disruption tools as well and sort of around the victim care. So we
have a modern slavery management team made up of a team of individuals.
We have a media linked into this, the migrant support workers from Wisbech
comes and sits. So we meet I say on a quarterly basis, but when we first started
out we met on a monthly basis because it was a new area of business to start

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getting our head around. And the idea around the modern slavery SPOCS,
effectively champions, out districts that I would take responsibility for, up
skilling them to a level and then they would take responsibility for going and
sharing that skills and knowledge and experience across each of their respective
districts. And the way that we do that is we have force action plan running and
there are various work streams, because it wasn't...obviously there's a lot of
national best...there is quite a bit of best practice out there, even though the
APP wasn't in place. But actually there were a lot of national strategies out
there, there's a modern slavery strategy that's been running, which is
essentially the four p’s model. So there are some good documentation alive
beyond the safe house, there were some really good key documents, about
four or five. So we've got a OneNote where we've got a lot of good embedded
documents set up, so I can signpost them to those. And also we used a lot of
the national best practices particularly around some of the strategies, for
example, the recent job that we did. We have one of the sorts of best practice
victim strategies that we wrote with the NCA when we were doing the recent
operation in Peterborough of launch, so that started as best practice. And as a
result of Op Launch we did a lot of work with Europol and we were one of the
first forces set up some joint international workings and that is now cited as
best practice by Europol when they go out and do their road shows. So actually
there's a lot of national documentation out there. There's some local stuff as
well from the victims strategy that choose to help the team and that's all on our
OneNote embedded document section. So I'm able to signpost that, they're
able to learn from that. We have other work streams as well where we're
identifying where there's a lack of intelligence reporting, lack of judicial
outcomes and also a lack of crime recorded. I say that because when we're
looking at it we're getting more NRM referrals than we are which is actually
being recorded on crimes. So actually there was a disparity there as well
thinking well if they're getting on the reasonable grounds basis, so that's
obviously the team of people who will decide whether someone is or isn't a
victim of trafficking, it can take up to five days when it goes through our NRM
system, there's a disparity there because we've got a lot of victims being
identified through the NRM, but not the same amount of crimes and
prosecutions, but that one might come back to education about how we as
people...as police staff need to respond to it. So we knew there was a host of
work and intelligence wasn't where I'd expect to be. You know, we were
getting intelligence reports in, but there was a bit of an issue around...probably
not enough, so there was a bit of under-reporting around intelligence. And also
it was a struggle as well to actually try and capture it all because it wasn't under
any banner or any sort of heading. So what we did was...we had a chat as a
group, shared a lot of different ideas and thoughts about how we could raise
awareness and how we could make sure, obviously, that we were recording the
activity in the right way because obviously if we were recording we could get
the right resources in, et cetera, et cetera. So there were some key things that
we did. We devised an intelligence strategy which is in the manner of Op Eagle,
very similar to what they did with the CSE work as well. And we had a CIB lead
as part of the SPOCs. As I said there were different people from different

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departments which the CIB was one as well as PPD. And [officer name] the DS
at the time then embedded that, so essentially all of the human trafficking
modern slavery intelligence was flagged under operational Eagle and was a bit
an intelligence drive out there. We were using on one of our articles, we used
some quotes that was with the victim's consent to talk about what this victim's
thoughts were about human trafficking, how she was a victim, how the signs
were not seen, but actually how it affected her, just to sort of connect with
people. And obviously to make it from a victim's perspective, that's always
quite impactful, so we had specific intelligence requirement there. Now, all the
intelligence flagged under Op Eagle so it's much easier when you say what's,
the current picture, where you can now go to a specific flag. And everything is
together which makes it really, really much easier from an analytical
perspective and also then it helped us to raise awareness across the force by
launching the intelligence strategy for human trafficking. And that in itself then
you can put signs and indicators on the back of that. The APP wasn't out at the
time and we felt we had enough information in force to device a false
practitioner's guide and also a force modern slavery training package as well,
which we've just revised and one of the DS’s in Cambridge is just finalising it. It
should be ready at the end of next week or the week after. And so what the
idea of that is then, obviously we get a force practitioner's guide out there
which incorporates all the recent changes with the APP, there are some
changes around the NRM forms as well; so that's all incorporated into one. So
that talks about signs and indicators, talks about the law and it talks about sort
of like their initial response, so their initial actions as to what is required on the
practitioner's guide. And it references in the NRM because there's different
reporting requirements now, so that everyone is quite clear as to what they
should be doing around that particular subject matter. And then the training
guide as well, essentially a PowerPoint which probably on delivery will take
around an hour-and-a-half to deliver. It talks from a national perspective to a
local perspective. Talks about signs and indicators, talks about expectations,
reflects a little bit on the practitioner's guide, brings some live case studies and
is fairly interactive and specifically talks about the new Modern Slavery Act and
different powers and procedures have been brought in as a result of that. So
what will be happening then is the full [responsibility of the SPOCS is to then
going to deliver that out across the force within their respective areas as well.
As I say that's in line with the APP, so all of that together their all work streams
that come out against modern slavery management teams, so they're a team of
people to have a wide effect across the whole of the force and really start to
raise this as the issue that it should be. And obviously there wasn't the same
strategy and now there is, that's aligned to the four P model. I don't know if
you've got that or not.
S1 I've got the national strategy, but...
S2 There's a force one as well.
S1 A force one, okay.
S2 It's really to put government structure in place because there wasn't a really
clear government structure, that's what the modern slavery management team

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does. So there wasn't modern slavery strategy emulates the national modern
slavery strategy because it should, it's the right way to approach and tackle it,
with just some local tweaks. So the strategy was put in place, so the vision is set
and then the teams put in place as part of government structure. And then we
have a force action plan and also a regional action plan because I have to go
then to the region and they have specific areas. So all the...it isn't just
Cambridgeshire then, all of the seven forces, all align to what they're delivering
again. In theory, we're forcing the seven...all the seven forces should have one
and the same management team. Whether they do or not...the majority do.
But some will be different, some might have a designated team of people, like,
we've chosen to have modern slavery SPOCS as opposed to designated
investigations team, which is what I believe we need to move towards because
certainly at the moment we've still got bespoke responses...some seriously
organised... sometimes serious and organised to take it on, otherwise we get a
big job like the one I'm running with Jan we have to put a level two bid in and
just pull a team together from across the force; which obviously does impact on
the force in terms of where their staff have been depleted from because they
can be used for anything from one to two years on any reasonable job. And
that's a long time for them to be lost from their daily business.
S1 That was interesting because it's something which the council highlighted was
funding. And looking at the national strategy, the national strategy obviously
puts in guidance and then requirement for the police to play an important role.
But in regards to the other demands, so it kind of leads into just to some of the
final questions around just some challenges as what have been along the way
some challenges to increase in the constabulary's response to modern slavery.
S2 Yeah, yeah. And there's one bit I want to touch on there as well with the
council bit. But with the constabulary response, their challenges have
been...when we've given them to the serious and organised crime teams or
we've been in a level 2 job, right resources, we were able to properly tackle
issues, properly investigating the issue and hopefully end up with some positive
judicial outcomes. However, there are more than one or two jobs in terms of
human trafficking and modern slavery jobs that are ongoing across the force.
And what's happening is then the challenges that I see is that those other jobs
that fall outside of the designated resources into them don't probably get the
service that they should be getting and the challenges that we're not able to
service and resource all of the jobs that perhaps we should be. And we can't do
everything for everybody, we accept that. But there are some jobs that should
be different in resource in my opinion than others. So the challenge is that with
the current force structure we’ve got in place is good, there are now
governance in place, but I think now we're moving towards...actually when you
look at the data that we have an issue that would necessitate us to now even
review our response again and consider whether we should have a force
designated to human trafficking modern slavery team. And I mean an
investigation team, so that actually when these jobs are coming in actually they
are able to go to one set of people. And that's likely to certainly improve the
judicial outcomes in the way the jobs are managed. I would say the demand is

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there, but the resources aren't necessarily. And certainly that's formed part of
the STCG, the Strategic Tasking Coordinating Group where actually modern
slavery and foreign national offenders are most likely to be endorsed as a force
priority. And as a result of that they will review whether there is a need to put
a designated investigation team in because the challenges for me are we do it
well, some of the operations...and the right ones because there are those
operations that might pose the most harm, risk and threat tend to be organised
by crime groups that are really quite posing issues that are challenging. So
they're in there, but I think we could do better if we had more focus on the
designated people on some of the other operations as well. But just going back
quickly to your partnership issues as well, it is I think really quite important that
one of the biggest changes that's happened across the force in terms of serious
and organised crime is the national serious organised crime strategy which you
may not necessarily have had cite on. And as a result of what the biggest
changes that came out of that that there is a requirement to produce a local
profile, a local serious organised profile. And the reason that that's been done
is then there is a suggested...and it's not statutory, but we've played a little bit
on working partners. We tend to be very good when we need to go for some
specific issue, but actually there's not a thing embedded in place that roles
continuing...which is daily business. And actually we need to be from an
organised crime perspective. And so what we are doing with the profile is the
force...each force across the country should be produced its own organised
crime profile. With that is the certain crime types of which human trafficking
and modern slavery is one that’s identified to pose most harm, risk and threat.
That should feature in there and what that profile should do is analyse using
police and partner agency, all of the information around organised crime
groups that are operating in certain types of crime areas that deem most threat
risk and harm like, CSE and terrorism and some of the most obvious ones are in
drugs trafficking. And they should actually write in a profile and talk about
what those threats are. And that profile should be given to partners in order
that they can produce some multi-agency action plan that is a rolling action
plan where they can agree actions with the police that will continue to tackle
organised crime group activity. That was done and that was rolled out to all of
the CSPs and all the CSPs, 50 percent have already and the other 50 percent are
doing it, so they're creating multi-agency action plans to tackle those
embedded partnership arrangements in place to keep on top of the issues of
which human trafficking is obviously one amongst that which is good because
obviously that makes it daily business. So that profile is produced and
comments on each of the different districts and human trafficking features in
nearly every district and I know it's evident in every district as well. So that's
got partnership buy-in which is helpful as well.
S1 So in terms of any lessons learned so far because the purpose is obviously to
capture some of your experience and knowledge and what could be passed on,
is there any really key lessons learned that you would say to any colleagues in
other forces if they are about to take up a similar role to yourself?

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S2 Yeah, yeah, I would. So in terms of having the governance structure in place,
actually understanding what the problem is and making sure that there is the
right training and tools out there. And that's for police, police staff and
partners that are able to inform them to help tackle the issue. Obviously,
human trafficking sometimes isn't a sexy subject that people might want to go
and investigate and it is really, really challenging. But actually sometimes, you
know, you've got to be alive to the fact that crime changes, the change in
nature of the crime and whatever that is. You need to grip it, so you need to
take time to understand it and you need to challenge as well because actually
what we do we tend to get tendencies amongst staff is still making sure that
they are aware that they are properly understand what human trafficking is.
And do you know what that's not just staff, that's going all the way through the
CPS system as well because a huge challenge is CPS, not through any fault of
their own, everyone is extremely busy, everyone has got different demands
placed on them. But actually human trafficking is not only challenging to
investigate, it's really challenging to prosecute as well. And it's much easier to
prosecute some of the side offences and the spinoff issues, whether that be
fraud or whether that be Gang Master licencing offences, than it is actually
tackling...to take on and actually try and prosecute the actual issue that's going
on. And there are a number of reasons around that, but sometimes culturally
as well even talking into the criminal justice world there would have been views
where all of these people could have just walked away. And I always use the
analogy of domestic violence, well a victim of domestic violence can leave their
partner, but they don't because actually there's an element of fear and control.
So you're using the same and compare, I would suggest with human trafficking.
So a real challenge is around CPS and actually a more recent example is around
operation Launch which actually they were looking...we got to be in charge of
human trafficking, they're looking to reduce the charge because they couldn't
see where that trafficking was because the person in the element of
control...there was nothing physical around it, they could have walked, they
could have walked away. So actually what was really helpful and I would
suggest to anybody who is actually...what we did...and actually from an
investigation perspective an evidence gathering investigation and also a
presentation perspective, prosecution perspective, is we actually broke down
the legislation and we actually put the evidence against each of the different
points proved because there are three different areas that you need to prove in
human trafficking and go and present it and challenge it. And if you actually
spell it out and you put it in front of somebody, whether that be a lawyer or
anybody, it's really hard for them to say no when you're saying well these are
the points we've got to prove and we've proven, this is our evidence and we've
proven every single point. So I guess what I'm saying around that is challenge
because it is difficult and it is a difficult subject to investigate. And a difficult
subject to get CPS aboard and take through the court system and even having
the right counsel appointed because you are quite limited with experienced
counsel prosecution counsel out there that will see these jobs through until the
end. But there are those out there and certainly the Met have got a dedicated
trafficking centre and they've got some really good barristers and counsels

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appointed. So actually it's getting hold of that expertise out there and using it.
Because as soon as you start to get some through the court systems and that
will start to have a trickle affect and start to get some messages to the
offenders as much as people because I think...I think people are...it's very easy
to say well we didn't have a successful prosecution...so you hear that a lot, it's
difficult. But it's difficult if you let it difficult. Yeah, they're probably the
key...the key sort of points.
S1 I think my final question is sort of kind of broad, but it doesn't have to be. The
introduction of the Modern Slavery Act, speaking to colleagues and just
generally that this had a mixed reception as in...Because at the moment we
struggle with or in the past legislation was quite sporadic, where this aim to
bring it all into one. How useful or how affective is the Modern Slavery Act in
assisting the constabulary in prosecuting or taking a lot more action around
cases of modern slavery?
S2 I think it simplifies the legislation more, with the human trafficking legislation
there wasn't much definition around stuff. Like, we didn't really define what
slavery was. It talked about...because there are different parts of human
trafficking that you would have to prove in human slavery was one, but it really
didn't then go on to really provide any definitive guidance around stuff,
whereas this does. For me it simplifies it more and it provides some specifics
and definitive guidance around it. And also it puts responsibility onto others as
well that you can look to enforce when it comes to businesses. So they've got
specific responsibilities now and actually if they don't undertake them they are
liable to prosecution themselves. So for me it brings those extra powers in and
allows us then through having those to engage because there's a reason to
engage and that enables us to actually do...to actually do that. And in terms of
the actual...in terms of the actual prison sentence look at what that's extended
to now, which it wasn't before. But it's interesting in different countries human
trafficking actually...when they do get successful prosecutions they do actually
imprison for long periods of time. And we haven't got a lot to compare it to
here have we because we haven't had that many successful prosecutions. But it
lays...it lays it out there for me and the test is going to be when we actually
prosecute some cases and what the outcome is at court. But it is a much more
for me...although bearing in mind it's not been in for that long, we've had some
people arrested, we've not prosecuted them yet, but it does simplify things.
And I think it should as time goes on simplify it through the court process as
well.
S1 Brilliant. Thanks ever so much.
S2 Okay.

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Appendix F – Practitioner D Interview Transcription
Practitioner D
S1 Researcher
S2 Practitioner D
Speaker Transcript
S1 What was the issues in Wisbech that lead to the cases of modern slavery being
discovered?
S2 The police identified that there was a rise in shoplifting and it wasn't just alcohol
that was being stolen, it was food as well. So that's quite a clear indicator of
poverty. At the same time, the council was aware of an increase in rough
sleeping. Now, our rough sleeping is not huge when you compare us to a city,
it's very, very small, but it's very obvious for us if there's a sudden increase.
Although some of it's quite hidden, we were starting to see people in the streets
and it was very unusual. We had a group of…I think we had a group of about six
or seven…in Lloyd's TSB foyer for some time. So the idea was to kind of get
together and think what's the link between these two? Why are we seeing an
increase in people stealing food and why are we seeing an increase in rough
sleeping, is there any correlation between the two?
S1 And if any sort of systems did you use? Did you collect that data around
Wisbech that you looked at in terms of seeing the rise?
S2 Yeah, I mean we have an outreach worker that we bid for every year. So…and
we have a night shelter as well. So the natural starting point was the night
shelter. Why…you know, for people that are actually in that shelter, what's
their story? We were referring these rough sleepers to the night shelter, but
there's only 12 beds so why are we seeing this sudden increase. So we spoke to
these people…sorry…the night shelter was an all migrant shelter at that time
when this project first started in September '12. And there was a pattern that
these people had come to Finland for work on the promise of work and when
they weren't needed for work they were illegally evicted. The key there was the
fact that they were in a house of multiple occupation HMOs, that was the
common thing for us. So that was a starting point. As far as system, we used
something called ECINS when we started up our project. So…it's called
empowering communities. So there's information that we all share as a
partnership on there. So we have information sharing agreements, so we can
share that within that circle of trust quite freely.
S1 Brilliant. And then did you set up a specific team to look into these issues?
S2 Yes, yes we did. So obviously at this starting point it was then a district council
and the police. So the police team was one sergeant, one PC and one PCSO who
was Lithuanian who was really key to this under the inspector. And then under
myself we had one private sector housing officer, one plying enforcement and
one outreach worker. So quite small teams.
S1 Okay. And did you have to get extra funding for this, and if so, how?
S2 Yeah. We had been bidding for funding for our outreach worker…so an Eastern
European speaking outreach worker for the last…so we started in 2012 so from

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that year, actually. So they were at that point doing the repatriation work, lost
documents, contact with embassies, but we didn't have any funding for this
project. It was all about this is the day job and it was talking to our teams
about, look, it's doing you day job, but in a slightly different way and in a joined
up way. So that's how we did that. There was an opportunity to bid for some
funding in January '14 to tackle rogue Landlords. That was communities and
local government funding. So we bid for that, we got what we asked for,
170,000. And that enabled us to provide additional capacity. So we had an
extra bod in private sector housing team, we had planning enforcement and
tenancy relation post as well, but apart from that, that was…you know, the
emphasis was on, although this is an enormous project potentially and you'll
probably hear from others, tip of the iceberg, but it really was a can of worms.
We had to do it within what resources we had.
S1 So what agencies were involved as this has gone on.
S2 Initially when we established in September '12, it was the police and FDC. We
then got fire service involved and then we had a conference in Wisbech and
again the Gang Masters Licensing authority came along. So I spoke to them and
said it would be great if you could come along and join our project. Then the
MP got involved, which was really helpful, actually. And he asked us to form a
task force, he was very keen on getting involved and wanted it to have I think a
little bit more profile. So whilst the local agencies, the police, fire and FDC were
very much leading the work on the ground, we became this task force, so we
met monthly. So we had HMRC, Home Office Immigration Enforcement as well.
So they would come along to those meetings, share our finding on these things,
they were all part of that. And that's really how the partnership developed.
S1 Oh, fantastic. So how did you work with the police and the partner agencies to
identify the victims and what were you looking for and also potentially what
were the challenges in that?
S2 Okay. Yeah, there's lots of challenges. So we quite quickly realised that
vulnerable people won't…especially when their first language isn't
English…aren't going to come running to your door with a list of issues. That
just wasn't going to happen. These issues were very hidden so we decided that
we would…our first visit was the 9th of November, 2012. I remember it well
because it was a very strange evening and for myself, I went out and it was kind
of, gosh this is what the police obviously do all the time. And we very, very
quickly realised that our focus needed to be on victims. You know, why were
these people living in those properties like they were? We were aware of
housing multiple occupation, but we had no idea the scale. Because we were,
again, looking for it so we thought let's take a victim type approach. Let's go
along together so the police and FDC at this time, let's look at the properties to
make sure they're safe, let's strike up a conversation with those people in the
properties to say look, we're here to help. We've got some free lightbulbs, we
can check your property is safe, is there anything else, you know, that's
worrying you? Here's some information about human trafficking. Are you
getting what you should be getting in your pay packet? Oh, you're not getting a
pay packet? And it's then when we started to sort of pick off these things that

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were going wrong. Obviously GLA's role in that, so the police would share that
information with GLA. So it's really finding a way, having a conversation,
knowing what people should be getting, i.e. minimum wage as a minimum and
where they weren't, that's when we started to sort of map what these issues
were. So that was the approach, but it…the approach hasn't really changed, it's
adapted, but it hasn't really changed from now.
S1 And what were the challenges?
S2 There were quite a few. Building trust, obviously with people that, you know,
didn't speak our language, were new to the area. Some of whom didn't
necessarily know who they were, didn't know who else they were living with.
And these were…you know, that first visit I spoke about just now was a woman
on her own with two little kids and a house full of nine other single males. So
didn't know any of them. So you kind of get the sort of picture that we were
talking about. So trust, distrust of authority in their home land, you know,
people in uniforms. It's, for them, potentially quite intimidating. So, you know,
we realised that having an Eastern European speaking PCSO, fantastic. Because
he could sort of have that cultural in, look, everything's fine, we're coming to
make sure your property is safe and do some reassurance, but again, it was a
challenge to get people to open up at the beginning, but actually what we
wanted to know was, yes, we can go and look at the properties to make sure
they were safe, but actually, what can they tell us about their experience and
that was challenging to say the least. Between ourselves…I think between the
police and FDC, yeah, we were finding our way and working together in a way
that we hadn't worked before. So understanding each other's cultures, how we
work, the remix of what we can do, what's our legislation, what powers have we
all got? Building that sort of trust between ourselves. So for [Officer A] and I,
there was quite a task there to show, look, we're working together, this is how
it's going to be, let's shape this together. And, yeah, it was challenging for a
start, but then quickly, folks started to get on and I think that kind of sharing,
not being precious, but sharing before long, we sort of got over that. And I
think both teams could see the benefits of actually, if we all get together we can
all suss this out in one go. Or, hmm, this is a concern for me, well, let's get the
fire service out with us and then we can sort this. So it took a bit of doing, but
very quickly I think we became a really strong team. Our system, obviously…I've
spoken about ECINS was really key to that sharing. The terminology on ECINS is
about tasking each other which I remember some slight issues like, you have the
police telling you what to do, yeah, but you can tell them what to do as well.
This is the whole point of the partnership. So it was really, let's have a go, but
honestly, very quickly it got into being the day job it wasn't cumbersome as I
think some team members perhaps though initially might be. Oh, having to do
this system and this system. People actually look what we're getting out of it
and they quickly realised what the broader benefits were and the team gelled
extremely quickly which was really good. So I think sort of for the teams to sort
of see how it was mutually beneficial was the real key to that, yeah.
S1 So terms of identifying the offenders and gathering intelligence, what sort of
intelligence did you gather?

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S2 Okay. So when we were doing our home visits, during the conversation we
would sort of start to make notes about so, you know, who do you work for?
And we obviously realised that the accommodation was linked to work. And
that was part of the whole control process. So we would ask for their details
and they'd be really forthcoming, here's my passport, here's my documents or I
haven't got my passport because it was taken from me. Oh, who took that from
you? And it was just trying to unravel this story, and it's really about, you know,
what's your experience like and where do you come from as part of our sort of
patter. And as we got into doing the visits, we started to realise what we
needed to be asking so we had a questionnaire, but we kind of kept it very
informal. So tell us about your experiences? You know, where have you come
from? Some examples of the sort of good intelligence that we got were really
around who they're paying the rent to and we realised that properties were
being controlled by gang masters largely or people further down the line who'd
perhaps been the victims themselves being promoted and then suddenly
become a rent collector. So some of these rent collectors are very intimidating,
very powerful characters and you don't ask any questions because you know
that, you know, something awful might happen if you step out of line. You'll be
kicked out, you will lose your job and home and end up homeless. So sort of
knowing the experience of others that we'd spoken to, we knew what to ask. So
for us, it was about, you know, is this happening to anyone else that you know?
And sometimes people would tell us, sometimes they would give us a bit,
sometimes you could really see that there was resistance to that and they were
actually quite scared. So we took packs out, as I said earlier, with information in
and we'd also have a contact card as well. And that's how we started to get
people contacting the police in particular were going into the police station.
There was one in particular that just wrote Pheasant on an envelope and went
in and handed it into the police station who obviously wanted help. So we were
starting to get through, but also aware that people were very worried about
repercussions in particular. And not just for them, it could be repercussions
back home. These people had come from small, rural villages largely from
Lithuania where they were known.
S1 So how did you identify who was involved in the exploitation?
S2 Yeah. I mean, we're obviously dependent on people telling us. So any
intelligence that we got, we built a picture and the CIB helped with that to
identify which properties were being controlled by which agents or rent
collectors. So that was really key. We asked questions like who do you pay your
rent to? Oh, I don't pay it. Do you…is there an agency in town, where do you go
and pay? Do you have a tenancy agreement? No, I pay this man. I only know
his name is whatever with his phone number. So it's quite often just a single
name, a surname or a Christian name that could be incorrect and a mobile
number. Or he comes every Friday. So that's how we started to get that sort of
intelligence. And then that mapping with right, this property is controlled by X,
but it's also managed…in inverted commas…by a particular agency in town. So,
again, housing would target the agents, we went along with GLA as well to talk
about we're having issues. And that's when we started to really realise what the

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connection was with the agents. The agents were aware of what was going on.
So that was really, really, key to us. So I'll explain in a bit about how that
process works, but any sort of hints and tips on…you know, from people in the
properties around who was controlling that property. That was key, that was
key, and what were their descriptions, when did they come along, what's their
number? Anything they could tell us that helped us. Because quite often where
they were working was irrelevant. It was this middle person who they were
actually working for that was doing the exploiting.
S1 When you engaged with the house, what worked in your experience and what
didn't work and how did you build up that rapport?
S2 With people in the properties, as I said, it's really about showing that we are on
their side. That, you know, from the team's perspective as well, that these
people are potential victims so let's go out to them, let's go out on the pretext
of look, we want to make sure your property's safe, can we give you some
information? You know, people aren't necessarily going to suddenly open up to
you, but say, oh, you've got no smoke detectors up on your property. We've got
some with us, can we put that up? That way you're safe. Make sure you open
your windows to ventilate so you don't get mould and damp et cetera. And
there's lots of you here, you normally…you know, how many of you here?
You've got a tenancy agreement? No. Okay, so who do you pay your rent to as
I've just said. So it's trying to build a picture, trying to get trust and it's really
hard, but the sort of informal conversation. So how long have you been in
Wisbech, then? Where have you come from? And it's all these sort of open
questions and where you've got people that are perhaps on the run is that we
kind of went through. You'd have a whole gathering of people and, you know,
one might say something, one might not. As our officers have continued
through, we've experienced it and people have got a bit smarter about further
down the line of control from the rent collectors. They've told people if people
come in then you're all related, so for an HMO for example, all you need is three
or more unrelated people so a way of getting the council and police off your
back is to say you're all related. So we started to see that kind of change in
approach. Plus, also, there were potential alphas within the properties so the
people that we were talking to. So it was very obvious if you had a very
dominant person that would sort of come to the front of the queue and say
well, right, I'm such and such, there are four people here etc. and try to
neutralise any sort of interest that we might have. So we quickly realised that,
gosh, these people are actually in the properties as well in some cases. We
were very mindful of that. So we did revisits and we'd leave our information
and try and tackle it that way.
S1 I see. So how often did you visit these properties?
S2 Well, we were out probably three or four times a week, the teams are.
Sometimes we can get access, sometimes we don’t. So we'll keep trying, we'll
speak to neighbours. When are people normally around? We try different
times of days because of shift work as well. So…and we would obviously try to
engage with agents as well at this point who knew nothing about what was

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going on in these properties despite their responsibilities to manage which we
challenge and still are.
S1 So going back to the number of visits you do, and as you said sometimes
dominant males would come to the front door. How quickly did these people
start to react to your visits? Did they start to change? Did they pick up very
quickly or how did that sort of develop over the investigation?
S2 I think, normally first started back in September '12, we were all new to it and
kind of learning. And the approach that we took was this very much kind of this
very much informal. As we kind of learned, people in the properties did as well
as we became much more prevalent. Wisbech isn't a massive town, it's
relatively small, but we've got at least 1,000 HMOs and when people are being
moved around all the time, you're meeting lots of new people. So it might be
the same property, next day, there might be completely different people in
there because they're moved around. So that it's fresh people, no these
weren't here. It' their way of kind of disguising who's there and doing what they
want to do without our interference. So our approach had to sort of adapt, but
we've always tried to keep this victim approach and very informal approach, but
as I said, people have got smarter where they're being controlled. We've just
tried to continue to try to get that information out, what can we do, but where
there's an alpha, then when it's very obvious that there is, we try and go back at
a different time to try and get to the other people that are there.
S1 That's great. So moving away from the investigation, were there any issues that
you faced from the public or the MPs in regards to the issues that were in
Wisbech?
S2 Yeah. I think when migration sort of really kicked off in the UK in 2003/4, there
was a massive influx, particularly into Wisbech where there are lots of
opportunities to do agricultural work. And the pay is a lot more lucrative here
than it is, especially in Lithuania. We've met two people, one of whom was an
ophthalmic nurse, one was a trainee vet and they could both earn 3, 40 times as
much money picking pumpkins in Wisbech than they could do in their roles in
their own homes. So there's a big draw on coming to Wisbech. When more and
more and more people have come, so there's probably at least…we know at
least 35 percent migrants in Wisbech. It's probably more because that sort of
information isn't always picked up on census because of the way that people
are moving in and out. They're not able to register. I think there's quite a lot of
community tensions, we know there is, there's lots of cohesive issues. Some of
the feedback that we've had has been, you know, the local population resent
how migrants will walk around in gangs drinking. So what we're very keen to do
is to try and put some publicity out that showed that actually, some of these
people…that there's a story behind this. They go around in gangs because they
don't speak the language, they don't know perhaps where they are, even.
They've been dropped off in the night and then, you know, been…had their
documents taken, they might have been abused. There's all sorts of
exploitation that's happening. So we try to sort of paint an alternative picture
and we did that in kind of a drip feed and that was largely through [police
practitioner] work with the police, actually. Having a page in the local press and

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every so often we'd sort of talk about our work, we'd highlight what we're
doing. When we started to get victims of human trafficking, we publicized that
as well because we thought, actually, this is massive. And it started to resonate
with one or two…we started to see one or two letters in the press, people were
surprised to know that this was happening. So we think, oh, we've not
conquered this. We've not conquered cohesion overnight. It's never going to
be that easy, but actually there were early signs. We started to get our elected
members…I briefed our elected members, our councillors…to say look, they
caught off and they would ring and say, oh, there's an HMO, it's disgusting it's
da da da da da. And we started to sort of try and educate them a little bit and
say look, if you know where there is such a property, can you let us know and
we'll got and check it out? And then we'd give some kind of safe feedback if you
like to say, well, actually, without going into details, we've found some issues
there. Some people are, you know, in need of assistance. So we started to try
and give that feedback to try and change perceptions. We'd had in relation to
the MP, we'd had a lot of interest about the project from him. As it early doors,
as it started to develop and began to gain momentum, we engaged with him
and actually he became extremely helpful and helped champion us. He's a
strong character and came out with us on some visits as well so he could see
things for himself. And his support has been fantastic, actually, to help us
support us getting funding in and raising our profile which is included with
ministers who've some of us have spoken to. So he's role has been really, really
crucial and I think that has helped perhaps bridge a gap between the council
and him and our members, actually, together so that we kind of…it's much more
cohesive within our own approach.
S1 Brilliant.
S2 Yeah.
S1 So in terms of the community of Wisbech, particularly when you were visiting
HMOs, if they saw police and uniforms, was there a negative view from the
community or were you able to use different tactics to try and get there?
S2 I mean, we…when we started out doing our visits, we would go out in the police
van and I know it sounds a bit dramatic, it wasn't meant to be, but we realised
that actually, neighbours are out looking what's going on. And we realised,
actually, we all went out together because it was easier because we could all go
to the same address at the same time and it was, you know, it was good to be
working together, you know, as part of the team bonding. So we decided,
actually, we need to tame things down a bit. So we'd take our own cars, park in
sort of different parts of the street and also we…the police went in on uniform.
My team went out in casual clothing to try and show that we were…yes, we
were there on business obviously we've got a job to do, but actually, we were
there from a positive perspective trying to help them as victims. And, you
know, we never had complaints that, you know, there's a raid going on or
anything like that. We were aware that there was lots of curtain twitching and
just thought, well, we can go and speak to those people, of course we can, but
actually, perhaps we need to tone things down and not raise so much
awareness. Because we thought that could be seen as, you know, inciting a bit

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of racial unrest if you like. Although that was obviously far from what we
wanted to ever do. We were there for victims, but as far as the indigenous
community went, we thought, actually, that might be a better approach.
S1 So a bit of a broad question, a sweeping question, but is modern slavery still an
issue in Wisbech?
S2 Yes, it is, unfortunately. We've had more cases this year. We've had, I believe,
16 cases or referrals through to national referral mechanism this year. So we're
going to continue our approach. We're very keen to use all the powers that we
possibly can. We're taking a report to our cabinet next month to ask consent to
go out for consultation, to introduce a selective licensing scheme. We know we
need a well manged, robust private sector market. We've got lots of properties
in Wisbech and lots of them are, sadly, in poor state of repair. So we're kind of
chasing our tails a bit with the work that we're doing with quite a small team.
So the proposal is that we use some powers that need sign off by the secretary
of state, but will help us to regulate the private rented market. Because we
know that's the hub of where a lot of these issues are happening. And we also
know from speaking to the people in the properties that we visit that they're
actually working in other areas outside of Finland, but the accommodation is
still in Finland. So we've got, you know, a forever task. Our iceberg isn't getting
any smaller. So actually, this won't be the be all and end all, this won't solve it,
but it will make it a lot better for us to be able to regulate as a council. It's a five
year scheme, there will be very, very hefty fines if agents and landlords go
against the conditions in the license. There will be an exact number of people
that are allowed to reside in each property per property. So that will help us as
far as regulating that at the moment. You know, you can put in as many people
as you like and it's fine and it's all about obviously profit. That you charge 50, 60
Quid a week per person irrespective of how many people are in there when
you're a rogue agent. So that's really key for us. We know that, you know, we
obviously want to keep bidding for any funding we can get to help increase
what we're doing. We're a small team, local or public sector is under massive
scrutiny as we both know and it's not going to stop. So we're really keen to try
and sort of impact in the best way that we can. We've always been a small
team. The whole office as a team is quite teeny and reducing, but there's very
much still that focus there. We know we've still got issues and we need to
tackle it.
S1 Brilliant. A sort of question on that is, are you still having success?
S2 Yes. Yes, we are. You know, word of mouth I think has probably been the most
effective tool for us. We've done stuff in the press, but actually, knowing that
we can get people out of awful situations and move onto better things has been
really powerful. People are obviously still frightened and worried about
repercussions. And there's a big cultural issue with, you know, if your family
have paid for you to come to the UK to bring back money to your family and the
shame of going home is a big thing, so we've had to understand all of this. So
we're saying we can get you home, we can repatriate you, you know, it's going
to be great, but actually, the shame of going home…and lots of people will say
to us, well, this is better than home. You know, living in a disgusting property

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under threat and fear, it's better than at home. So it's…there will always be that
sort of challenge, but our approach, you know, it's been effective. The going
out to see people, yes it's time consuming, but we're never going to get to the
bottom if we don't do that. We need to actually go out and speak to people.
We've done lots of engagement with our third sector in Wisbech that are very
supportive. Not just the night shelter, but also community centres and that kind
of thing. So we share information, we've got reporting mechanism that we've
set up if they've got concerns about potential human trafficking. That they will
let us and the police know first rather than send people home themselves. So
it's all from, you know, quite a lot of lessons learned. We've looked at also
how…and we talked about adapting our approach earlier, about how we can
perhaps change our visits…and as we've had a bit more resource, we were kind
of aware that we were getting a bit top heavy again. We were sort of six or
seven people going out on a visit. It was too much, we weren't getting that sort
of…it was a lot harder to engage with someone and have a casual conversation
when you've got a house full of people. So we've set up a slightly different
approach. When the police and the interpreter were fine going first and then
housing on follow up visits. We're trying that at the minute just to see how that
goes, but the important thing is that we keep that communication between us
and the partnership still really strong.
S1 I suppose that this is all final question I wanted to ask is overall, what are the
lessons learned or word of advice for other practitioners who believe they may
have similar issues in this are?
S2 Yeah. I've spoken to lots of other councils and I know the police teams have
spoken to other police forces. And some are…think they might have an issue,
some think maybe. My thought is, I'm sure there's an issue everywhere
whether you know it or not. It's just having the guts to sort of get in and start
scratching at the surface. So words of advice would be work together, share
intelligence and resources, it prevents double doing. See the benefits, publicise
what you're doing, get some service leaders to champion the cause and be
really passionate and enthusiastic about it. It needs that drive to make it
happen. Talk to anyone that will listen about the issues and how you're
approaching them, engage with other partners, talk about the benefits of how
you're going about this and join together. We talked to schools, we spoke to
teachers and said look, if you've got concerns about kids or of kids saying things
like, you know, I have to share my room with my mummy and daddy and my
sister and my brother, we'd like to know. It might not be a safeguarding issue,
but it might just be something that we can take up if we find there are
safeguarding issues. Obviously when we go out and have a look we'll report it,
but…and GPs, health workers, we've tried to sort of think about anyone that
would have an interaction with the person in their home if they've got concerns
that wouldn't necessarily fall into a statutory category, then tell our Pheasant,
then we can have a look. I said already we talked to the public about victims
and sometimes how challenging life can be for them. To start to sort of build
some sort of understanding of cultural differences. The biggest bit of learning
we had was trying to take on too much in one go because we were very, very

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keen. And we started to get some results. We had a list of properties…we used
our council tax list initially…which would have housing multi-occupational and
although it's such a moveable piece and they can be there one minute and gone
the next and somewhere else, we used that as a starting point. And we quickly
realised that we could add, add, add and add to that. So on reflection, yes, less
is more. We then tried to stick to sort of 10 addresses, let's blitz those, let's get
what we need then move on to the next rather than having a massive
properties and we were sort of tying ourselves in knots quite early doors. So
that was some learning. Reflect on direction as well is something together with
partners. Don't be afraid to sort of try different approach. If something isn't
working, why isn't it working, get some feedback, talk together. And we
built…and it's still there now, even with different people in it…such a strong
partnership and trust. Absolutely necessary for this kind of work. Don't expect
the community to come running to you, our approach has been go out to them.
Yes, it's intensive, but you're cracking off 10 potential issues in one visit
together rather than loads of different agencies keep going to that same
address. So there's a saving there. Be wary of individuals experiences, share
this intelligence with broader teams so they know what to look out for. So do
your housing receptionist, do they know about this? To the customer access
team. Know of these sorts of issues and, you know, get them to share their
concerns with us. How they can link in, eyes and ears on the ground. We
briefed our refuse collectors, if they're going to properties where there were
massive overflowing bins, shitloads of rubbish, et cetera, can you let us know?
Because it might be an HMO. Lots of mattresses, that kind of thing. Get
politicians on side, engage with central government via your MP if you can.
Shout about what you're doing. This is good stuff. Yes, it's really challenging
and there are massive issues, but talk about your approach, get them out to see
it for themselves. Again, it's about people having…a few key people that are
really going to champion this…and show them how you're addressing these
issues together. Yeah, so share that, the successes with them. Be selective with
media, especially national media would be my next one. Less is more. Yeah, we
had a very, very positive visit from The Guardian which did us a lot of good, it
really raised the profile nationally. We then had, I think it was 14 other media
companies that wanted to rush and jump on the back of it and we said no.
Because we didn't want it to become a media circus and we had lots of very
popular media who were very keen to speak to victims and come out with us
and we said no. It's not at all appropriate. So, yeah, be selective with who you
engage with. Because there's a story there, but it can be twisted and you need
to make sure that you're getting the balance right with cohesion locally. That's
always a risk. My last thing is engaging with the surrounding areas as well. So
what other district councils, police forces doing, have they got a similar project?
We, through the work of Operation Pheasant could map…obviously with GLA
being involved…that people were coming from Wisbech, they were then
traveling to Cornwall, in the flower season in particular up to Scotland. So, yes,
those areas, are they concerned, do they have concerns about what's
happening? Are they aware, but we know it's obviously a bit help for us locally
is that people are still residing in Wisbech whilst they're working away. So

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there's been tons and tons of learning and there still will be. We're learning
stuff all the time, but that's really been our experience to date.
S1 Lovely. Thank you very much. I just point out that this interview has been
recorded and I hope you're happy for me to transcribe it and then use it
in…thanks ever so much.
S2 Yeah, no problem.
S1 Thank you.

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