PG49. Safeguarding Trafficked and Exploited Children

1. Introduction

This Procedure provides guidance to professionals and volunteers from all agencies in safeguarding children who are abused and neglected by adults who traffick them into and out of the UK in order to exploit them.

The majority of migrating accompanied and unaccompanied children seek asylum at their port of entry or when they arrive in London. However, children who are migrated for exploitative reasons (trafficked) do not come to the attention of the authorities or disappear from contact with statutory services soon after arrival.

All children are rendered more vulnerable as a result of accompanied or unaccompanied migration; trafficked children are at increased risk of suffering Significant Harm.

The Procedure also touches on issues for children who have migrated to the UK and present as unaccompanied asylum seeking children.

2. Policy and Legislation

2.1 International

International legislation relevant to trafficked and exploited children includes:

• The First World Congress on the Commercial Exploitation of Children (Stockholm,1996);
• The United Nations Convention on the Rights of the Child (United Nations, 1989);
• The Second World Congress on the Sexual Exploitation of Children (Yokohama, 2001).

In 2000 Trafficking became enshrined in international law for the first time through the Palermo Protocol within the United Nations Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children. The Protocol defines trafficking as:

'The recruitment, transportation, transfer, harbouring or receipt of a child for the purpose of exploitation shall be considered 'trafficking in persons' even if this does not involve any of the means set forth [elsewhere in the Palermo Protocol]'

2.2 UK

UK legislation and guidance relevant to trafficked and exploited children includes:

• The Children Act (1989);
• Care of unaccompanied and trafficked children Statutory guidance for local authorities on the care of unaccompanied asylum seeking and trafficked children July 2014;
• Safeguarding children who may have been trafficked: non-statutory good practice guidance issued by the Department for Education and the Home Office in October 2011;
• Working Together to Safeguard Children;
• Modern Slavery Act 2015 Home Office Circular;
• The National Plan for Safeguarding Children from Commercial Sexual Exploitation (2001-5);
• The Nationality, Immigration and Asylum Act 2002;
• The Sexual Offences Act 2003;
• ECPAT - UK Briefing Paper on Child Trafficking - Begging and Organised Crime (published in September 2010);
• Safeguarding Trafficked Roma Children and Families, (published by the London Safeguarding Children Partnership in September 2010);
• ECPAT briefing 'On the Safe Side - Principles for the Safe Accommodation of child victims of trafficking'.

3. Definitions

3.1 Trafficking and Exploitation

The two most common terms for the illegal movement of people - 'trafficking' and 'smuggling', are very different. In human smuggling immigrants and asylum seekers pay people to help them enter the country illegally; after which there is no longer a relationship. Trafficked victims are coerced or deceived by the person arranging their relocation. On arrival in the country of destination the trafficked child or person is denied their human rights and is forced into exploitation by the trafficker or person into whose control they are delivered.

The Palermo Protocol establishes children as a special case - any child transported for exploitative reasons is considered to be a trafficking victim - whether or not they have been deceived. This is partly because it is not considered possible for children to give informed consent.

Even when a child understands what has happened they may still appear to submit willingly, to what they believe to be the will of their parents.

4. How does Trafficking Happen?

Traffickers are known to recruit their victims using a variety of methods. Some children are subject to coercion, which could take the form of abduction or kidnapping. However, the majority of children are trapped by in subversive ways:

• Children are promised education or respectable work - as in restaurants, domestic servants etc.;
• Parents are persuaded that their children will have a better life elsewhere.

Many children travel on false documents and for those who do not, the traffickers usually throw away their identification papers.

5. Why Do People Traffick Children?

Most children are trafficked and exploited for financial gain. This can take the form of payment from the child's parents, and in most cases the trafficker also receives payment from those wanting to exploit the child once in the UK. Some trafficking is by organised gangs, in other cases individual adults traffick children to the UK for their own personal gain. Exploitation includes children being used for:

• Sex work;
• Domestic servitude;
• Sweatshop and restaurant work, drug dealing and credit card fraud;
• Begging or pick pocketing;
• Benefit fraud;
• Drug mules or decoys for adult drug traffickers;
• Forced marriage (there were 240 reported cases in the UK 2000-2, in 15% of cases the unwilling partner was male);
• Trade in human organs; and in some cases;
• Ritual killings.

Younger children are often trafficked to become beggars and thieves or for benefit fraud. Teenagers are often trafficked for domestic servitude, sexual exploitation and forced marriage.

6. Why is Trafficking Possible?

Factors in their own country which make children vulnerable to trafficking include:

• Poverty: this is the root cause of vulnerability to exploitation in general. The recruiter's promises of work/income is seen by families as a possible escape route from impoverished circumstances; or at the very least one less mouth to feed;
• Lack of education: attendance at school has proven to be a key means of protecting children from all forms of exploitation, including trafficking. Traffickers promise education for children whose parents cannot afford to pay school fees or where schools are difficult to access or of poor quality;
• Discrimination: this can be based both on gender and ethnicity. In some cultures girls are expected to make sacrifices in terms of education and security for the benefit of the family, they represent less of an investment for the family because their contribution to the family will end when they leave to marry (and marriage itself may be too expensive for the family);
  
  Many trafficking victims are from minority communities who are socially discriminated against and disadvantaged in their own country.
• Cultural attitudes: traditional cultural attitudes can mean that some children are more vulnerable to trafficking than others e.g. the caste system and a tradition of bonded labour in India puts tribal and low caste children at risk;
• Dysfunctional families: children may choose to leave home as a result of domestic abuse and neglect;
• Political conflict and economic transition: conflict almost inevitably leads to large scale people movements and the erosion of economic and social protection mechanisms, leaving children vulnerable;
• Inadequate local laws and regulations: trafficking involves many different events and processes and legislation has been slow to keep pace. Most countries have legislation against exploitative child labour, but not all have laws specifically against trafficking. Even where there is appropriate legislation, enforcement is often hampered by lack of prioritisation and ignorance of the law.

7. How Are Children Brought To The U.K.?

Children enter the UK in two key ways, accompanied adult/s or as unaccompanied minors.

Accompanied children:

 Very little is known about accompanied children, many of whom are brought in by adults either purporting to be their parents or stating that they have the parent's permission to bring the child. There are many legitimate reasons for children being brought to the UK, such as, education, re-unification with family or fleeing a war-torn country.

Unaccompanied children:

More is known about these children because they come to the notice of the authorities when they claim asylum. Although there appear to be some groups of children who do not seek help from the authorities, notably Chinese children who 'disappear' into the Chinese communities in the UK.

Many African children are referred to Children's Social Services after applying for asylum, and even register at school for up to a term, before disappearing again. It is thought that they are trafficked out of the UK to Europe. Children also come to London via Gatwick and Dover. However, recent experience is that as checks have improved at the larger ports of entry, traffickers are starting to use the smaller, less well known ports, such as Luton and Stansted airports. 

7.1 Trafficking Schemes

There are three phases in the trafficking process; the recruitment phase, the transit phase and the destination phase. The traffickers might be part of a well organised criminal network, or they might be individuals helping out in only one of the various stages of the operation, such as the provision of false documentation, transport, or a 'safe house'.

To respond to trafficking Section 55 of the Borders, Citizenship and Immigration Act 2009 came into force on 2 November 2009. It requires the UK Visas and Immigration to make arrangements to safeguard and promote the welfare of children in discharging its immigration, nationality and general customs functions. On 1 April 2013 the UK Visas and Immigration was split into two separate operational units within the Home Office. The units are:

• UK Visas and Immigration - responsible for handling visa applications to come to the UK, applications to extend a stay in the UK on a temporary and permanent basis, applications for asylum, appeals, correspondence and Sponsor management;
• Immigration Enforcement - responsible for investigating immigration offences, detaining and removing individuals with no right to be in the UK, preventing abuse of the immigration system.

8. What Happens to Children before they Arrive in the UK

Even before they travel children can be subjected to various forms of abuse and exploitation to ensure that the trafficker's control over the child continues after the child is transferred to someone else's care:

• Voodoo is used to frighten children (usually girls) into thinking that if they tell anyone about the traffickers, they and their families will die;
• Confiscation of the child's identity documents;
• Threats of reporting the child to the authorities;
• Violence, or threats of violence towards the child;
• Threats of violence towards members of the young person's family;
• Keeping the child socially isolated;
• Keeping the young person locked up;
• Some children are told that they owe large sums of money for their air fares, accommodation and food, and that they must work to pay this off - however they never earn enough to do this;
• Depriving the child of money.

9. The Impact of Trafficking on Children

Trafficked and exploited children are not only deprived of their rights to health and freedom from exploitation and abuse - they are usually also deprived of their right to an education and the life opportunities this brings.

Once children have been trafficked and exploited, they are vulnerable to:

9.1 Physical Abuse and Neglect

• This can range from inappropriate chastisement, not receiving routine and emergency medical attention (partly through a lack of care about their welfare and partly because of the need for secrecy surrounding their circumstances);
• Children in the sex industry are open to sexually transmitted infections, including HIV; and for girls there is the risk of early pregnancy and possible damage to their reproductive health (see also: Sexual Exploitation);
• Children frequently suffer physical beatings and rape;
• Children also frequently suffer physical deprivations, including beatings, sensory deprivations and food deprivation;
• Some trafficked children are subdued with drugs, which they then become dependent on. They are then effectively trapped within the cycle of exploitation, continuing to work in return for a supply of drugs;
• Children often develop alcohol addictions;
• Victims can suffer physical disorders such as skin diseases, migraine, backache etc.

9.2 Psychological Harm

• Children become disorientated after leaving their family environment, however impoverished and difficult, and arriving in the Western world. This disorientation can be compounded for some children who have to assume a new identity or have no identity at all;
• Children can be isolated from the local community in the UK by being kept away from school and because they cannot speak English;
• Trafficked and exploited children are living in fear both of the adults who have control of them and of the discovery of their illegal immigration status;
• Victims lose their trust in all adults;
• Trafficked and exploited children will all suffer from a form of post traumatic stress relating to their sense of powerlessness and the degree of violence they experienced at the hands of their traffickers, which can be extreme;
• Many trafficked and exploited children develop dependant relationships with their abusers;
• They suffer flashbacks, nightmares, anxiety attacks, irritability and other symptoms of stress, such as, nervous breakdowns;
• Trafficked and exploited children experience a loss of ability to concentrate;
• They can become anti-social, aggressive and angry, and/or fearful and nervous - finding it difficult to relate to others, including in the family and at work;
• Victims have very low self-esteem and believe that the experience has 'ruined' them for life psychologically and socially. They become depressed, and often suicidal;
• The children worry about people in their families and communities knowing what has happened to them, and become afraid to go home;
• All children who have been exploited will suffer some form of physical or mental harm, usually, the longer the exploitation, the more health problems that will be experienced. Although in some cases, such as contracting HIV or the extreme abuse suffered by Victoria Climbie, fatal damage happens very quickly.

10. Identifying Trafficked and Exploited Children

Children are being trafficked to and exploited in counties and cities all over the UK. All entry and exit points in the UK are potential channels for trafficking children. Children who arrive in the UK are protected under the Children Act 1989.

It is incumbent on all agencies to work together to safeguard and promote the welfare of children trafficked into and out of the UK, providing the same standard of care as that available to any other child in the UK.

All practitioners who come into contact with children and young people in their everyday work need to be able to recognise when children have been trafficked and exploited, to understand the areas of vulnerability that this can generate for a child or young person and should be competent to act to support and protect these children.

This may be the crucial intervention which breaks the cycle of the child being vulnerable to continuing or further exploitation.

10.1 Risk Indicators

There are a number of circumstances which could indicate that a child may have been trafficked to the UK, and may still be being controlled by the traffickers or receiving adults. These include situations in which the child:

• Does not appear to have money but does have a mobile phone;
• Is driven around by an older male or 'boyfriend';
• Is withdrawn and refuses to talk;
• Shows signs of sexual behaviour or language;
• Shows signs of physical or sexual abuse, and/or has contracted a sexually transmitted disease;
• Has a history with missing links and unexplained moves;
• Is required to earn a minimum amount of money every day;
• Works in various locations;
• as limited freedom of movement;
• Appears to be missing for periods;
• Is known to beg for money;
• Is being cared for by adult/s who are not their parents. Children in these circumstances are being privately fostered - see Children Living Away from Home Procedure, Foster Care. The quality of the relationship between the child and their adult carers is not good;
• Has not been registered with or attended a GP practice;
• Has not been enrolled in school;
• Is required to earn a minimum amount of money every day;
• Has to pay off an exorbitant debt, perhaps for the travel costs, before being able to have control over his/her own earnings;
• Hands over a large part of their earnings to another person;
• Is excessively afraid of being deported;
• Has had their journey or visa arranged by someone other than themselves or their family;
• Does not have possession of their own travel documents;
• Has false papers, and these have been provided by another person;
• Is unable to confirm which adult is going to accept responsibility for her/him;
• Fits current profiles for those at risk of exploitation;
• Has entered the country illegally;
  
  or, the person:
  
  
• In control of the child has applied for visas on behalf of many others, or acts as guarantor for other visa applications;
• Who guarantees the visa application has acted for other visitors who have not returned to their countries of origin on the expiry of the visa.

If there are concerns that a child is a victim of trafficking, the practitioners will need to inform the National Referral Mechanism, which is a framework for identifying victims of human trafficking or modern slavery and ensuring that they receive the appropriate support. The child's details should be provided using the forms available on the National Referral Mechanism Digital Referral System: Report Modern Slavery.

11. Children at Port of Entry

All aspects about immigration, visas and arrivals in to the country are addressed in the guidance to frontline staff through the UK Visas and Immigration which can be accessed here and further information can be accessed in the HOME Office document 'Statutory Guidance Modern Slavery: How to Identify and Support Victims'.

12. Children already in the Country

12.1 Community Groups, Neighbours and the Public

As most children who are victims of trafficking who arrive in the UK are not aware of their rights or that they can claim asylum, once they have gained entry to the country they are unlikely to come to the notice of asylum or immigration services.

Trafficked and exploited children often come to the notice of any agency only when it is too late. Some are enrolled at school and concerns are only raised when they leave unexpectedly, and there is no trace of them or their 'family' at their home address. Others are never registered at school or with a GP. These children do not come into contact with the statutory services who could raise concerns about their welfare. Younger children may be known to local Housing or benefits services. However, most trafficked children are invisible. Protecting them and promoting their welfare depends on the awareness and co-operation of community groups, neighbours and the public. This has implications for awareness raising campaigns. (See Local Safeguarding Children Partnerships below).

12.2 Private Fostering

Private fostering is defined in the Children Act 1989 as occurring when a child under 16 years (or under 18 if disabled) is placed for more than 28 days in the care of someone who is not a close relative, guardian or someone with Parental Responsibility (close relatives are defined by the Act as parents, step-parents, siblings, siblings of a parent and grandparents).

As the current systems relies on the parents and the foster carers to notify the local authority of a private fostering arrangement (preferably before, but certainly within 48 hours, of the child arriving to stay), only a very small proportion of placements are notified, and private fostering remains an underground activity, ideal for people who traffick children.

Staff or volunteers in an agency who have concerns that a child may be trafficked and privately fostered should contact local authority Children's Social Care, who can investigate under their regulatory duties in relation to private fostering (Children Acts 1989 & 2004). These duties are: to identify private fostering arrangements, inspect the home and assess the suitability of the arrangement in terms of the child's welfare, visit the child regularly, and monitor and keep records of the placement.

There is also a new requirement on local authorities to raise awareness of the notification requirements within local communities (section 7a of the Children Act 2004) and to ensure that staff or volunteers in all agencies encourage notification.

12.3 All Agencies

Wherever staff or volunteers in an agency come into contact with a child who has arrived unaccompanied in the country and is not in contact with Children's Social Services or a child who is accompanied, but for whom they have concerns regarding their welfare or safety, they should consult and follow one of the following:

• The actions indicated in this Procedure, including in Appendix 1: Practitioners and volunteers in different agencies' actions up to and including referral to Children's Social Services;
• Their own agency's Safeguarding Children procedures (approved by the LSCP);
• The London Child Protection Referral and Assessment Procedure, Implementation of Child Protection Plans and Resistant Families Procedure;

All these procedures will ultimately guide practitioners and volunteers to contact their local Children's Social Care if they are concerned that a child has been, is being or could be abused through trafficking.

12.4 Local Authority Children's Social Care

Local authority Children's Social Care have responsibility for assisting all unaccompanied children and children who have come to the UK with their parents for whom there are concerns regarding their welfare and safety.

See Referrals Regarding Possible Trafficking and Exploitation of a Child and S.47 Enquiry below for local authority Children's Social Care duties to undertake an assessment and, where appropriate, a S.47 enquiry. This is in line with the Referral and Assessment Procedure.

12.5 Health Services

Trafficked children who need healthcare are more likely to be seen at Accident and Emergency services, Walk-in Centres, minor injury units or gum clinics, than by primary care services. Reception staff need to be alert to inconsistencies in addresses, deliberate vagueness and children or carers being unable to give details of next of kin, names telephone numbers etc.

When children or their carers give addresses in other countries, with the information that the child is resident outside of the UK, reception staff should always record the current holiday address as well as the home address in the other country. Staff need to be alert to 'local holiday' addresses in case patterns emerge that would suggest large numbers of children moving in and out of one address. Home visitors such as Health Visitors and Senior Nurses who may follow up visits to Accident and Emergency and Walk-in Centres, should also be alert to the moving in and out and rapid turnover of different children to any one address.

12.6 Education Services

Children trafficked into the country may be registered at a school for a term or so, before being moved to another part of the UK or abroad again. Schools therefore need to be alert to this pattern of registration and de-registration. This pattern has been identified in schools near ports, however it could happen anywhere in the UK.

There is general agreement that children who have experienced certain life events are more at risk of going missing from education. Trafficked children are particularly vulnerable: see The Impact of Trafficking on Children above. Schools need therefore to be alert to the possibility that a child who goes missing from school, may be, or have been, a trafficked child, who is living with or is running away from an exploitative situation.

The London Guidance Safeguarding Children Missing from School should assist schools in identifying situations where children have been or are being trafficked.

12.7 Local Authority Asylum Team

Many local authorities have asylum teams who have responsibility for families, single adults and unaccompanied young people for whom there are no concerns additional to their migrant status. Where this is the case, there should be a locally agreed protocol to assist other teams and agencies in working jointly with the asylum team.

12.8 Police

London's Child Abuse Investigation Teams and Borough officers are supported by a Metropolitan Police Paladin Team. This is an integrated team of Police and Immigration Officers who specialise in safeguarding children issues. The team is based at Heathrow Airport and provides a limited service to the UKVI's Asylum Screening Unit and the International Eurostar Terminal at Waterloo Station. The Paladin Team undertakes proactive and preventative initiatives against the trafficking of children throughout London. The team has some capacity to investigate specific trafficking and migration offences, as well as providing an advisory service to Child Abuse Investigation teams on child trafficking issues.

12.9 Local Safeguarding Children Partnerships

Local Safeguarding Children Partnerships (LSCPs) should have an interagency strategy and protocols in place for the early identification and notification to the relevant agencies of potential victims as they arrive in the country.

SCPs should offer training to improve:

• Practitioners and volunteers ability to recognise a trafficked and exploited child; and
• Multi-agency working to protect and promote the welfare of such children.

SCPs should maintain close links with community groups and have a strategy in place for raising awareness within the local community of the possibility that children are trafficked and exploited, and how to raise a concern.

SCPs with a detention/deportation centre in their area should develop a close working relationship with the centre in order to safeguard and promote the welfare of both the accompanied and unaccompanied children who reside at the centre.

12.10 Refugee Council Children's Panel

The Refugee Council Children's Panel of Advisers comprises about 30 advisers who travel all over the country to support unaccompanied asylum-seeking children. The Panel offers support to children who:

• Have applied for asylum on entering the UK;
• Have lived in the UK for some time before applying for asylum;
• Are abandoned by relatives, agents or friends;
• Have been picked up by the police;
• Are in detention centres or prisons;
• Are living on the streets or are already in the care of Children's Social Services, carers or community groups.

The support includes:

• Assisting children in accessing quality legal representation;
• Guiding children through the complexities of the asylum procedure;
• If necessary, accompanying children to asylum interviews, tribunal and appeal hearings, magistrates and crown court appointments;
• Building up a support network for children involving a range of statutory and non-statutory service providers;
• Accompanying children to appointments with GPs, hospitals, Children's Social Services or other agencies.

The Panel also offers this support to children at a drop-in advice service in Brixton; where they can also get hot lunches, showers, second hand clothes and help with tracing missing relatives.

The nature of the Children's Panel Advisers' work is such that they may well gather information which enables them to identify and refer children who are trafficked.

13. Referrals Regarding Possible Trafficking and Exploitation of a Child

An agency or individual practitioner or volunteer who has a concern regarding possible trafficking and exploitation of a child to local authority Children's Social Care, should contact the local authority Children's Social Care for the borough in which the child currently resides. For immigration officers at ports of entry, this will be the address which the child is planning to reside at when s/he is allowed to enter the UK.

13.1 Referral and Information Gathering

Appendix 1: Practitioners and volunteers in different agencies' actions up to and including referral to Children's Social Services sets out what practitioners and volunteers in the different agencies should do when they suspect that a child may have been or is being trafficked and exploited. This section describes in more detail the response from local authority Children's Social Care to a referral from one of the agencies:

• The social worker should obtain as much information as possible from the referrer, including the child's name, D.O.B, address, name of carer/guardian, address if different, phone number, country of origin, home language and whether s/he speaks English, names of any siblings or other children;
• The social worker should verify that the child is living at the address as soon as possible;
• In the case of a referral from a school or education department the list of documentation provided at admission should also be obtained;
• A Home Office check should be completed to clarify status of the child/ren and the adult/s caring for them.

13.2 Referring a Potential Victim of Modern Slavery to the National Referral Mechanism (NRM)

The National Referral Mechanism (NRM) is the UK's framework for identifying and supporting victims of modern slavery.

A local authority (as a 'first responder') identifying a potential victim of modern slavery must refer them to the National Referral Mechanism (NRM) for consideration by the Single Competent Authority (SCA) in the Home Office.

Children's Social Care departments are able to make a referral into the NRM, as they may be entitled to further support. Victims can be of any nationality, and may include British national children, such as those trafficked for child sexual exploitation or those trafficked as drug carriers internally in the UK. The NRM does not supersede child protection procedures, so existing safeguarding processes should still be followed in tandem with the notifications to the NRM. See also: GOV.UK, Report Modern Slavery as a First Responder.

There is no minimum requirement for justifying a referral into the NRM and consent is not required for children. Communicate honestly with the child about your concerns and reasons for referring them into the NRM.

To complete and see where to send the forms, and the associated guidance, visit Digital Referral System: Report Modern Slavery.

The Duty to Notify - Local authorities have a duty to notify the Home Office about any potential victims of Modern Slavery. It is intended to gather better data about modern slavery. This requirement can be satisfied by completing the National Referral Mechanism Digital Form.

NOTE: In June 2021, the Government launched a 12-month pilot programme in some local authority areas that will test alternative models of decision making for child victims of modern slavery and human trafficking. See GOV.UK Guidance: Piloting Devolving Decision Making for Child Victims of Modern Slavery.

If the child is in an Independent Child Trafficking Guardian (ICTG) area (see Barnardo's website), a referral must also be made to the Independent Child Trafficking Guardian service (see Independent Child Trafficking Guardians (ICTG) below).

The NRM referral and ICTG referral should be made in parallel.

Independent Child Trafficking Guardians (ICTG)

In areas where the ICTG service has been implemented, if the first responder considers a child to be a potential victim of modern slavery, they should refer them to the ICTG service by completing the online Independent Child Trafficked Guardians Referral Form. This is in addition to following usual safeguarding routes and NRM referrals.

Referrals must be made through the online referral form. A 24/7 assessment line number for the ICTG Service (0800 043 4303) is available for advice on referring a child into the service.

Independent Child Trafficking Guardians (ICTGs) are an independent source of advice for trafficked children; somebody who can speak up on their behalf and act in the best interests of the child. This service was formerly known as Independent Child Trafficking Advocates. The Government has committed to rolling out ICTGs across England and Wales.

An ICTG's advocacy and involvement throughout the decision-making process is intended to ensure the child is protected from further harm, prevent possible repeat victimisation, re-trafficking or going missing and promote the child's recovery. ICTGs are independent of those authorities who are responsible for making decisions about the child.

See also: Interim Guidance for Independent Child Trafficking Guardians.

The ICTG service model provides two discrete services to children who have been trafficked:

• ICTG Direct Workers - support children for whom there is no one with parental responsibility for them in the UK;
• ICTG Regional Practice Co-ordinators - whose role is to focus on children who do have a figure with parental responsibility for them in the UK.

ICTG Direct Workers provide one-to-one support to a child who has been trafficked and help them navigate, as appropriate, the respective local authority children's services and the immigration and criminal justice systems, as well as ensuring that their educational and health needs are met through liaison with the appropriate statutory agencies and public authorities.

ICTG Regional Practice Co-Ordinators hold a strategic role, working with professionals who are already engaged with and supporting the child, rather than directly working with the child. The ICTG RPC has in-depth and specialist knowledge of provisions in their local area and is able to offer expert advice to professionals working directly with children on how best to safeguard the children in their care.

The ICTG Direct Worker or ICTG Regional Practice Coordinator must be invited and provided with the opportunity to take part in all meetings and discussions which relate to and impact upon the child, including individual agency meetings such as those with the local authority, police, immigration authorities and those which may take place within the criminal justice system as well as multi-agency meetings and strategy discussions. The ICTG Service must also be informed of all decisions relating to the child.

The public authorities in the ICTG Sites must provide the ICTG Service with access to all relevant information, subject to any restrictions on the disclosure of the information, relating to the child to enable the ICTG Service to perform their role effectively in line with safeguarding responsibilities.

Likewise, the ICTG Direct Worker or ICTG Regional Practice Coordinator must share relevant information they have obtained from their meetings with the child with the public authorities to enable them to continue to perform their role in the child's support and care, effectively.

The ICTG Service should receive information from public authorities in a timely fashion a minimum of 2 working days before a meeting where practical. This paperwork could include an agenda as well as any background or more recent papers on the child that will inform or be discussed at the meeting. This will enable the ICTG Direct Worker or ICTG Regional Practice Coordinator to be fully prepared when attending meetings with professionals and subsequently with the child. This will also enable ICTG Direct Worker or ICTG Regional Practice Coordinator to carry out their role and duties to the child in an effective and productive manner, allowing them to increase their knowledge and understanding of the child in order to develop appropriate strategies or options to continue to support them.

Where the child's ICTG Direct Worker or ICTG Regional Practice Coordinator is not available to attend certain multi-agency meetings between public authorities or those involving individual agencies which relate to and impact upon the child, they should, where possible, arrange and brief an alternative ICTG Direct Worker or ICTG Regional Practice Coordinator to represent them at the meeting or provide key thoughts and opinions to the chair of the meeting or to key professionals who will be in attendance to ensure their views are reflected. The ICTG Service's assessment line staff are also able to remotely dial in on these occasions, therefore conference calling facilities should be made available where necessary. The ICTG Service should receive key notes and actions as well as any decisions reached during the meeting in a timely fashion or within a maximum of 2 working days.

Where the ICTG Service considers that it is necessary and appropriate to do so, they may obtain legal advice or instruct a legal representative to act on the child's behalf. This advice or representation may relate to the support and care needs of the child, any immigration or criminal proceedings the child is involved in, or circumstances which may be considered to have a detrimental impact on the child.

13.3 Action after the Information Gathering

On completion of the information gathering the social worker discusses the referral with their supervising manager to agree and plan one of four ways forward:

13.4 Decision to Interview

Once all possible information has been gathered, the social worker and their supervising manager, together with the police should decide whether to conduct joint interviews with the police, either the Child Abuse Investigation Team (CAIT) or the Immigration Service and the Borough Police.

• Where it is decided that the family should be visited and interviewed, standard social work practice should be followed. The child should be seen alone, preferably in a safe environment. Ensure that the carers are not in the proximity. Children and young people will usually stick to their account and not speak until they feel comfortable;
• Where it is decided that the family should be visited and interviewed, standard social work practice should be followed. The child should be seen alone, preferably in a safe environment. Ensure that the carers are not in the proximity. Children and young people will usually stick to their account and not speak until they feel comfortable;
• Professional interpreters, who have been DBS checked, should be used, it is not acceptable to use a family member;
• Questions should focus on the following:
  • Family composition, brothers, sisters, ages;
  • Parents' employment;
  • Task they do around the house;
  • Length of time in this country;
  • Where they lived in their country of origin;
  • Where they went to school in their country of origin;
  • Who cared for them in their country of origin.

The adults in the family should be interviewed (separately if possible) on the same basis, using the same questions, a comparison can then be made between the answers to ensure they match.

• All documentation should be seen and checked. This includes Home Office documentation, passports, visas, utility bills, tenancy agreements, birth certificates. Particular attention should be given to the documentation presented to the school at point of admission. It is not acceptable to be told 'the passport is missing' or 'I can't find the paperwork right now'. It is extremely unlikely that a person does not know where their paperwork/official documentation is kept;
• This interview should be conducted as fully and complete as possible to ensure accuracy and to avoid intrusion on the family over a longer period than is absolutely necessary;
• On completion of the assessment a meeting should be held with the social worker, their supervising manager, the referring agency as appropriate, the police and any other professionals involved to decide on future action. Further action should not be taken until this meeting has been held and multi- agency agreement obtained;
• Where it is found that the child is not a family member and is not related to any other person in this country, consideration should be given to establishing status and assisting the child as an Unaccompanied Minor;
• Any action regarding fraud, trafficking, deception and illegal entry to this country is the remit of the police and the Home Office. The local authority should assist in any way possible, however, the responsibility for legal action usually remains with the other agencies (exceptions include benefit fraud, the responsibility of the Department of Work and Pensions, and Education offences, pursued by the LEA).

See also the London Guidance for Safeguarding Children Missing from School.

14. S.47 Enquiry

Whenever a practitioner or volunteer becomes concerned that a child has suffered, or is likely to suffer, significant harm, a referral must be made to local authority Children's Social Care, (verbal referral, followed by a written referral within 48 hours) in accordance with Recognising Abuse and Neglect Procedure), Referral and Assessment Procedure.

If the concern is raised at a port of entry, then immigration service should without delay, contact the local authority Children's Social Care for the local area serving the port of entry. If the child is already in the country, the referral must be made to the local authority Children's Social Care for the area in which the child resides.

Local authority Children's Social Care must convene a Strategy Meeting within two working days of:

• The child becoming looked after; or
• Arrival in the borough where they are intending to reside, if a s.47 enquiry is appropriate.

The Strategy Meeting must:

• Share information - this will involve Immigration, the Police, Children's Social Services and any other relevant professionals;
• Develop a strategy for making enquiries into the child's circumstances, including consideration of a video interview;
• Develop a plan for the child's immediate protection, including the supervision and monitoring of arrangements (for Looked After children this will form part of the care plan);
• Agree what information can be given about the child to any enquirers; and
• Agree what support the child requires.

15. Looked After Children

An Assessment of the child's needs must be undertaken immediately by the social worker and residential worker/carer to include:

• Establishing relevant information about the child's background;
• Understanding the reasons the child has come to the UK; and
• Assessing the child's vulnerability to the continuing influence/control of the traffickers.

Planning and actions to support the child must minimise the risk of the traffickers being able to re-involve a child exploitative activities. Thus:

• The location of the child must not be divulged to any enquirers until they have been interviewed by a social worker and their identity and relationship/connection with the child established, with the help of police and immigration services, if required;
• Foster carers/residential workers must be vigilant about anything unusual e.g. waiting cars outside the premises and telephone enquiries;
• The social worker must immediately pass to the police any information on the child (concerning risks to her/his safety or any other aspect of the law pertaining either to child protection or immigration or other matters), which emerges during the placement.

The child's social worker must try to make contact with the child's parents in the country of origin (immigration services may be able to help), to find out the plans they have made for their child and to seek their views. The social worker must to steps to verify the relationship between the child and those thought to be her/his parent/s.

See Appendix 2 for a list of addresses and contact details for embassies and consulates for various parts of the world.

Anyone approaching the local authority and claiming to be a potential carer, friend, member of the family etc, of one of the child, should be investigated by the social worker, the police and immigration service. If the supervising manager is satisfied that all agencies have completed satisfactory identification checks and risk assessments the child may transfer to their care.

16. Support for Trafficked and Exploited Children

Children who have been trafficked and exploited are likely to need some of the following services:

• Appropriately trained interpreting;
• Counselling;
• Child and adolescent mental health services (CAMHs);
• Independent legal advice;
• Medical services (including, for victims of torture);
• Education;
• Repatriation.

16.1 Issues for Professionals to consider when working with Trafficked and Exploited Children

Children who have been trafficked and exploited need:

• Practitioners to be informed and competent in matters relating to trafficking and exploitation;
• Someone to spend time with them to build up a level of trust;
• A 'safe house' if they are victims of an organised trafficking operation;
• Legal advice about their rights and immigration status;
• Their whereabouts to be kept confidential;
• Discretion and caution to be used in tracing their families;
• A risk assessment to be made into the danger they face if they are repatriated;
• Accommodating - for those who meet the criteria;
• To be interviewed separately. Children and young people will usually stick to their account and not speak until they feel comfortable;
• Consider talking to children and young people using the phone, email, text;
• Consider interviewing children in school as they may feel more able to talk;
• Ensure that carers are not in the proximity;
• Ensure that interpreters are CRB checked;
• Contact with further education establishments.

16.2 Missing Children

London practitioners responding to the disappearance of vulnerable children from abroad, following their arrival in this country, can access additional guidance in Missing from Care, Home and Education,

16.3 Issues for the Prosecution of Traffickers

Attempting to persuade a child victim to testify against a trafficker is complicated. The child usually fears reprisal from the traffickers and/or the adults whom the child was living with in the UK if they co-operate with the police. This includes reprisals against their family in their home country. Children who might agree to testify, fear that they will be discredited because they were coerced into lying on their visa applications/ immigration papers.

16.4 Repatriation and Deportation

Trafficked and exploited children who eventually return home can suffer discrimination from the community - particularly girls who have been sexually exploited. A risk assessment needs to be into the danger a child may face if they are repatriated.

Appendix 1: Practitioners and volunteers in different agencies' actions up to and including referral to Children's Social Services

Click here to view Appendix 1: Practitioners and volunteers in different agencies' actions up to and including referral to Children's Social Services.

Appendix 2: List of addresses and contact details for embassies and consulates for various parts of the world

Click here to view Appendix 2: List of addresses and contact details for embassies and consulates for various parts of the world.

Appendix 3: Further Information

Statutory Guidance Modern Slavery: How to Identify and Support Victims

Care of Unaccompanied Migrant Children and Child Victims of Modern Slavery: Statutory Guidance for Local Authorities, November 2017 - guidance for local authorities and those making multi-agency safeguarding arrangements. This guidance sets out the steps local authorities should take to plan for the provision of support for looked after children who are unaccompanied asylum seeking children, unaccompanied migrant children or child victims of modern slavery including trafficking. Elements of this guidance will also be relevant for the care of looked after UK nationals who may also be child victims of modern slavery. It does not provide detailed guidance on steps that local authorities should take, in partnership with other agencies, to identify and protect child victims of modern slavery, including trafficking, before they become looked after. This is described in:

Statutory Guidance Modern Slavery: How to Identify and Support Victims (updated 2021) - describes the signs that someone may be a victim of modern slavery, the support available to victims and the process for determining whether someone is a victim.

Interim Guidance for Independent Child Trafficking Guardians

Independent Child Trafficked Guardians Referral Form - in areas where the ICTG service has been implemented, if the first responder considers a child to be a potential victim of modern slavery, they should refer them to the ICTG service by completing the online referral form

Modern Slavery Victims: Referral - guidance on referring potential victims of modern slavery/human trafficking to the National Referral Mechanism.

National Transfer Scheme Protocol for Unaccompanied Asylum Seeking Children - national transfer procedure on transferring unaccompanied asylum seeking children (UASC)

Cross-border child protection cases: the 1996 Hague Convention (DfE) - guidance for local authorities dealing with international child protection cases.

Guidance on Processing Children's Asylum Claims - sets out the process which immigration officials follow in determining an asylum claim from a child and the possible outcomes for the child.

Unaccompanied Asylum-seeking Children and Leaving Care: Funding Instructions: Instructions to local authorities about funding for the support and care of former and unaccompanied asylum-seeking children.

Support for Victims of Modern Slavery (Home Office 2016) - a leaflet outlining the support available for victims of modern slavery in 11 foreign languages.

Modern Slavery Act 2015

Home Office Circular - Modern Slavery Act 2015

Local Government Association - Council Support: Refugees, Asylum Seekers and Unaccompanied Children - resource for council staff, designed to answer questions about supporting refugees, asylum seekers and unaccompanied children.

College of Policing - Modern Slavery

Modern Slavery Human Trafficking Centre (MSHTU) (National Crime Agency)

NSPCC - Are You a Child Who Has Come to the UK from Another Country?

Modern Slavery - Royal College of Nursing Guide for Nurses and Midwives

Refugee and Unaccompanied Asylum Seeking Children and Young People - Guidance for Paediatricians (Royal College of Paediatrics and Child Health)

Refugee Council - Children's Panel - national remit to offer advice and support to unaccompanied children, and advise other professionals who are involved in their care.

Modern Slavery Helpline and Resource Centre - Unseen (Registered Charity)

ECPAT - Every Child Protected Against Trafficking - is a children's rights organisation working to protect children from trafficking and transnational exploitation.

Gangmasters & Labour Abuse Authority

Modern Slavery, Human Trafficking and Smuggling - CPS Guidance

BASW Age Assessment Practice Guidance brings together best practice on age assessment, useful techniques and information as well as exploring the relationship between existing and new legislation on age assessment and the implications.

Operation Innerste Process: Caseworker Guidance - Operation Innerste is a multi agency operation focused on safeguarding unaccompanied migrant children that are encountered inland in the UK. This document contains all details of the process when an Operation Innerste referral is made that the police, local authorities and Immigration Enforcement staff should follow.