Modern Slavery and Human Trafficking Policy

Street Lights Collective CIC is committed to preventing modern slavery, human trafficking, forced labour, criminal exploitation, sexual exploitation and all forms of abuse connected to exploitation within its activities, partnerships, programmes and supply chains.

Street Lights works with young people, families and communities affected by trauma, serious youth violence, knife crime, postcode conflict, exclusion, social isolation and reduced opportunity. Because of this, the Organisation recognises that exploitation may be hidden in plain sight and may be connected to wider contextual safeguarding concerns such as gang activity, county lines, debt bondage, grooming, coercion, online harm, family pressure, unsafe peer groups, school exclusion, poverty and community fear.

This policy sets out how Street Lights will identify, prevent, respond to and report concerns relating to modern slavery and human trafficking. It applies to all directors, advisors, staff, volunteers, practitioners, contractors, partners and anyone acting on behalf of Street Lights Collective CIC.

Street Lights will not tolerate modern slavery or human trafficking in any form. The Organisation will take proportionate steps to ensure that its work, purchasing, partnerships, recruitment, events, outreach, referrals and programme delivery reflect dignity, safety, accountability and community protection.

This policy is informed by the Modern Slavery Act 2015, which includes offences relating to slavery, servitude, forced or compulsory labour, and human trafficking. It is also informed by statutory guidance on identifying and supporting victims of modern slavery, safeguarding guidance for children and young people, and the principles of UK data protection law.

Street Lights Collective CIC is not currently expected to meet the commercial turnover threshold for mandatory annual modern slavery statements under section 54 of the Modern Slavery Act 2015. However, the Organisation adopts this policy voluntarily as a matter of good governance, safeguarding practice and ethical leadership.

This policy should be read alongside the following Street Lights Collective CIC documents:

• Safeguarding and Child Protection Policy
• Data Protection Policy
• Equality, Diversity and Inclusion Policy
• Complaints and Whistleblowing Policy
• Constitution and Governing Document
• Code of Conduct
• Safer Recruitment procedures
• Risk assessment procedures

The purpose of this policy is to ensure that Street Lights Collective CIC has a clear, practical and robust approach to modern slavery and human trafficking. It aims to:

• set out the Organisation’s commitment to preventing modern slavery and human trafficking
• explain how modern slavery may appear in youth work, community work and supply chains
• support staff, volunteers and practitioners to recognise indicators of exploitation
• ensure concerns are reported quickly and safely
• clarify the role of the Designated Safeguarding Lead
• protect children, young people, adults at risk, staff, volunteers and community members
• ensure partners and suppliers are expected to act ethically
• support lawful information sharing where there is risk of harm
• ensure learning is used to improve practice

This policy applies to:

• directors and board members
• board advisors and specialist advisors
• staff and sessional workers
• six trauma informed practitioners working with Street Lights
• volunteers and youth ambassadors
• contractors and consultants
• strategic partners and delivery partners
• suppliers and service providers
• schools, community organisations and faith groups working with Street Lights
• anyone acting on behalf of Street Lights Collective CIC
• The policy applies to all Street Lights activities, including mentoring, TIPS, Hood Lessons, the Street Lights Ambassador Programme, NEET Futures Initiative, community outreach, events, community education, professional training, online activity, referrals, partnerships, festivals, youth programmes and any future community hubs or youth spaces.

Modern slavery is an umbrella term used to describe situations where a person is exploited and controlled by another person, often through coercion, deception, force, threat, abuse of power, debt, manipulation, fear or vulnerability.

Modern slavery may include:

• slavery, where a person is treated as property or controlled by another person
• servitude, where a person is forced to provide services and cannot leave
• forced or compulsory labour, where a person is made to work against their will
• human trafficking, where a person is moved, recruited, transported, transferred, harboured or received for exploitation
• criminal exploitation, including county lines, forced drug dealing, forced theft, financial exploitation and forced involvement in crime
• sexual exploitation, including grooming, coercion, abuse and trafficking for sexual purposes
• domestic servitude, where a person is forced to work in a household
• labour exploitation, where a person is forced to work in abusive or unlawful conditions
• child exploitation, where a child is used, controlled, coerced or manipulated for another person’s benefit
• Children cannot consent to exploitation. Any child who is recruited, moved, controlled or used for exploitation must be treated as a potential victim, even where they appear to comply or where they do not recognise themselves as being exploited.

Street Lights Collective CIC understands modern slavery through a contextual safeguarding lens. This means the Organisation recognises that harm may occur outside the family home and may be driven by peer groups, social media, estates, transport routes, schools, parks, online platforms, gangs, community conflicts, older peers, adults in the community or criminal networks.

Young people affected by trauma, exclusion, poverty, family breakdown, low self worth, school disengagement, unmet need or lack of trusted adults may be more vulnerable to grooming and exploitation. A young person may be drawn into exploitation through friendship, gifts, protection, money, status, fear, threats, debt, loyalty, shame, online pressure or perceived belonging.

Street Lights will respond to exploitation concerns as safeguarding concerns. The Organisation will not label a young person as simply making poor choices when there may be coercion, grooming, fear, threat or manipulation behind the behaviour.

Signs of modern slavery and exploitation may not be obvious. Staff, volunteers and practitioners should remain professionally curious and should report concerns even where they are unsure.

Any concern about modern slavery, human trafficking, exploitation, coercion, forced labour or criminal exploitation must be reported to the DSL as soon as possible.

Where there is immediate danger, staff or volunteers must call 999. Where there is a crime but no immediate danger, the police may be contacted through 101. Where a child is at risk, children’s social care must be contacted in line with local safeguarding procedures. Where an adult with care and support needs is at risk, adult safeguarding procedures should be followed.

The reporting process is:

• Listen carefully and take the concern seriously.

Avoid asking leading questions or investigating.

Do not promise secrecy.

Record the concern using the person’s own words where possible.

Report to Phillip Chackochen, DSL, without delay.

If the DSL is unavailable and risk is immediate, contact emergency services or statutory safeguarding services directly.

Follow any instructions given by statutory agencies.

Store all records securely and confidentially.

If someone discloses modern slavery, trafficking or exploitation, the person receiving the disclosure should:

• stay calm and listen
• thank the person for telling them
• reassure them that they have done the right thing by speaking up
• explain that information may need to be shared to keep them or others safe
• avoid judgemental language
• avoid confronting the alleged exploiter
• avoid making promises about outcomes
• report the matter to the DSL immediately
• Staff and volunteers must not attempt to rescue, confront, mediate with, challenge or investigate suspected exploiters. This could increase risk to the victim, staff, volunteers or wider community.

The National Referral Mechanism is the UK framework for identifying and supporting potential victims of modern slavery and human trafficking.

Where a child may be a victim of modern slavery or trafficking, a referral should be considered through the appropriate safeguarding route. Consent is not required for a child to be referred, but the child should be involved and supported in an age appropriate way where safe to do so.

Where an adult may be a victim, consent is generally required for referral into the National Referral Mechanism unless there is another legal basis for sharing information due to risk of serious harm or legal duty. If an adult does not consent to a referral, a duty to notify may still apply to specified public authorities. Street Lights will seek advice from statutory safeguarding partners where needed.

Street Lights is not a first responder organisation unless formally authorised. Where a National Referral Mechanism referral may be required, Street Lights will liaise with the appropriate first responder organisation, children’s social care, adult safeguarding services or police.

Street Lights will reduce the risk of exploitation, abuse and unsafe practice through safer recruitment and workforce controls.

• role descriptions for staff, practitioners and volunteers
• identity checks
• references where appropriate
• DBS checks where required
• safeguarding induction
• code of conduct agreement
• supervision and line management
• clear boundaries for working with young people and families
• whistleblowing route for concerns about adults or organisational practice
• removal from duties where safeguarding risk requires action

Although Street Lights is a community interest company and not a large commercial organisation, it will take proportionate steps to ensure that its suppliers and contractors act ethically.

This may include checks on:

• venue providers
• transport providers
• catering providers
• security providers
• event suppliers
• merchandise and printing suppliers
• digital and media suppliers
• training providers
• contractors and consultants
• Street Lights will seek to avoid suppliers where there are reasonable concerns about forced labour, worker exploitation, unsafe conditions, unlawful working practices, child labour, trafficking, financial abuse or unethical conduct.

Where appropriate, contracts or agreements may require suppliers to confirm that they comply with applicable employment, safeguarding, equality and modern slavery laws.

Street Lights works with schools, local authorities, charities, faith groups, community organisations, businesses, employers and specialist services. Partnership work must never compromise safeguarding standards.

Before significant partnership work begins, Street Lights should consider:

• whether the partner has safeguarding arrangements in place
• whether the partner understands modern slavery and exploitation risks relevant to the work
• whether clear roles and responsibilities are agreed
• whether information sharing arrangements are lawful and proportionate
• whether risks to young people, families and staff have been assessed
• whether the partner’s values and conduct align with Street Lights

Street Lights delivers community activity in settings where exploitation, postcode conflict, community fear and safeguarding risk may be present. Event and outreach planning must include consideration of modern slavery and exploitation risk.

Risk planning should consider:

• young people arriving with unknown adults or older peers
• young people being pressured, watched or controlled by others
• online threats before or after an event
• postcode or gang related tensions
• unsafe travel routes
• missing children or young people
• photography and filming risks
• confidential spaces for disclosure
• clear reporting routes for safeguarding concerns
• staff and volunteer briefing before delivery

Street Lights recognises that modern slavery and exploitation can be facilitated online. Grooming, coercion, debt, threats, sexual exploitation, criminal exploitation, humiliation, blackmail and recruitment may take place through social media, messaging apps, gaming platforms, live streams and private groups.

Staff, practitioners and volunteers should report concerns where a young person appears to be controlled, threatened, groomed, exploited, blackmailed or pressured online. Online harm should be treated as a real safeguarding risk, not as separate from community risk.

Street Lights will ensure that directors, staff, practitioners and volunteers receive appropriate safeguarding information and understand the relevance of modern slavery and exploitation to the Organisation’s work.

Training and awareness may cover:

• definitions of modern slavery and human trafficking
• indicators of child criminal exploitation and county lines
• indicators of sexual exploitation
• contextual safeguarding
• responding to disclosures
• recording and reporting concerns
• safe information sharing
• online exploitation
• risks in procurement, events and partnerships
• the role of the DSL

All modern slavery, trafficking and exploitation concerns must be recorded accurately, factually and securely. Records should include the date, time, location, people involved, concern raised, words used by the person where relevant, actions taken, advice received and referrals made.

Records must be shared only with those who need to know for safeguarding, legal or operational reasons. Confidentiality must not be used as a reason to avoid sharing information where a child, adult at risk or another person may be at risk of harm.

Any person involved with Street Lights may raise a concern if they believe modern slavery, trafficking, exploitation, unsafe practice, cover up, neglect of duty or serious misconduct is taking place within the Organisation, a partner organisation or a supplier relationship.

Concerns may be raised through the Complaints and Whistleblowing Policy. Street Lights will not tolerate victimisation of anyone who raises a concern in good faith.

Where concerns arise about a partner, contractor or supplier, Street Lights will take proportionate action. This may include:

• seeking clarification from the organisation
• requiring immediate safeguarding action
• pausing work or payments where appropriate
• referring concerns to statutory agencies
• ending the relationship
• reviewing due diligence processes
• reporting to funders or commissioners where required

Modern slavery and exploitation risks should be considered within Street Lights risk assessments. This is particularly important for:

• programmes involving vulnerable young people
• work with young people at risk of criminal exploitation
• community outreach in high risk areas
• events involving multiple partners
• transport arrangements
• placements, work experience or employer engagement
• online engagement
• procurement of venues, catering, security or transport

Street Lights supports young people with futures, next steps, placements and progression. Any placement, work experience, employer visit or pathway must be safe, ethical and appropriate.

Before connecting young people to employers or placements, Street Lights should consider:

• whether the placement is legitimate and safe
• whether supervision arrangements are clear
• whether working hours and expectations are appropriate
• whether the young person understands the opportunity
• whether consent and emergency contact details are in place where required
• whether there are risks of exploitation, unpaid labour or unsafe conditions
• whether the young person knows how to report concerns

This policy will be reviewed annually by the Board of Directors or sooner if there is a serious incident, change in law or guidance, significant change in Street Lights activity, new area of delivery, or learning from practice.

The Board will monitor:

• number and type of exploitation concerns raised
• referrals made to safeguarding services
• training completed
• partner and supplier concerns
• learning from incidents
• policy implementation
• improvements required

Street Lights Collective CIC is committed to protecting people from exploitation, coercion and harm. The Organisation will act with presence by remaining alert and visible, with power by challenging exploitation and strengthening community protection, and with purpose by helping young people, families and communities move towards safety, dignity, freedom and hope.

• Modern Slavery Act 2015
• Home Office statutory guidance on modern slavery and identifying and supporting victims
• Home Office Transparency in Supply Chains guidance
• Working Together to Safeguard Children
• Keeping Children Safe in Education
• UK GDPR and Data Protection Act 2018
• Street Lights Collective CIC Safeguarding and Child Protection Policy