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.

0909274 40
“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.

0909274 41
“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)

0909274 42
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

0909274 43
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.

0909274 44
“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,

0909274 45
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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