Modern Slavery Act 2015 · NRM First Responder Duties

Modern Slavery & Human Trafficking

A practitioner guide covering the Modern Slavery Act 2015, types of exploitation, warning signs in children and adults, the National Referral Mechanism (NRM), first responder obligations, and referral pathways for England-based professionals.

17,004
Potential victims referred to NRM in 2023 — record high (Home Office)
34%
Of NRM referrals involve children (Home Office 2023)
136
Countries of origin of victims referred to NRM in England & Wales
30%
Of referrals in 2023 involved UK nationals — modern slavery is not just foreign victims

⚖️ Modern Slavery Act 2015 — Key Provisions

Section 1 — Slavery, servitude & forced labour
Holding a person in slavery or servitude, or requiring forced or compulsory labour. Maximum sentence: life imprisonment.
Section 2 — Human trafficking
Arranging or facilitating travel of another person intending to exploit them. Maximum sentence: life imprisonment.
Section 45 — Statutory defence
A child cannot be criminally liable for an offence committed as a direct consequence of being trafficked or exploited. Critical when county lines victims are prosecuted.
Section 52 — Duty to notify
Specified public authorities (including schools and NHS) must notify the Secretary of State when they encounter suspected victims of slavery or trafficking.

🔍 Types of Exploitation

Labour exploitation
Forced work in agriculture, construction, hospitality, nail bars, car washes, and food processing. Most common form in the UK.
Sexual exploitation
Forced into prostitution, pornography, or sexual services. Often linked to online recruitment. Primarily affects women and girls but not exclusively.
Domestic servitude
Forced to work in private homes — cleaning, cooking, childcare, elder care. Victims are often hidden from view, making identification difficult.
Criminal exploitation
Forced to commit crimes: drug supply (county lines), theft, cannabis cultivation, pickpocketing. Disproportionately affects children and young adults.
Organ harvesting
Rare but documented — people coerced or deceived into donating organs. Key indicator: unexplained surgical scars.
Forced marriage
Marriage without free and full consent of one or both parties. Forced Marriage Protection Orders available under Family Law Act 1996 s.63A.

⚠️ Warning Signs — What Practitioners Look For

Physical & environmental
  • Multiple people living at one address
  • Person collected/dropped off by different vehicles at irregular hours
  • Signs of physical abuse, malnourishment, or exhaustion
  • Poor living conditions or no fixed address
  • Someone else paying wages or speaking on behalf of the person
  • Unexplained surgical scars
Behavioural & psychological
  • Appears withdrawn, fearful, or avoids eye contact
  • Scripted or inconsistent answers — answers on behalf of another person
  • Does not know their own address or the area they are in
  • Has limited freedom of movement
  • Unaware of their rights or doesn't know they are in the UK illegally
  • Unexplained absences from school; no fixed address or frequent changes
County lines link: A child or young person carrying drugs between cities, found with large amounts of cash or multiple phones, or going missing overnight may be a victim of criminal exploitation under the Modern Slavery Act 2015. Apply the MSA s.45 statutory defence consideration before any criminal justice action.

📋 The National Referral Mechanism (NRM)

The NRM is the UK government's framework for identifying and supporting potential victims of modern slavery. All public authorities have a duty to refer suspected adult victims where they consent; children can be referred without consent.

Step 1 — Identify Practitioner identifies potential victim and discusses the NRM with them (adults must consent).
Step 2 — Refer First Responder submits an NRM referral form to the Single Competent Authority (SCA) via the Home Office online portal.
Step 3 — Reasonable Grounds SCA issues a Reasonable Grounds decision within 5 days. Victim receives a 30-day recovery period (Conclusive Grounds decision follows).
Step 4 — Support Victim receives safe house, legal aid, and support from an organisation such as Unseen or the Salvation Army.
Who can be an NRM First Responder? Local authorities (including children's services), police, NHS trusts, the Home Office, UKVI, BICS, NGOs approved by the Home Secretary, and schools (as local authority agents). Schools should refer through their local authority if unsure.

If You Suspect Modern Slavery — What to Do

Immediate danger
Call 999. Do not alert the suspected trafficker.
Modern Slavery Helpline
0800 0121 700
Free, 24/7. For professionals and victims. Operated by Unseen.
NRM Referral
Submit via the Home Office NRM online portal. Contact your MASH / local authority safeguarding team for support.
Child safeguarding referral
If the victim is a child, make a simultaneous s.47 referral to children's social care — NRM and CP referrals are not mutually exclusive.
Gangmasters & Labour Abuse Authority
0800 432 0804
For labour exploitation in regulated sectors.
Record keeping
Document all observations contemporaneously. If you are a specified public authority, the duty to notify (s.52 MSA 2015) applies.
Related resources
→ County Lines hub → Online Grooming & CSE → CSE hub → Continuum of Need

Statutory references: Modern Slavery Act 2015 · Children Act 1989/2004 · KCSIE 2025 · Working Together 2026 · Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act 2015 (NI) · Nationality and Borders Act 2022
Statistics: Home Office Modern Slavery: National Referral Mechanism and Duty to Notify Statistics UK, end of year 2023