National Referral Mechanism (NRM)
The National Referral Mechanism (NRM) is the UK government’s primary mechanism for identifying, referring and supporting victims of modern slavery.
First responders refer potential victims of Modern Slavery into the NRM where the competent authorities make decisions on whether or not an individual is a potential victim/victim of modern slavery for the purpose of the National Referral Mechanism (NRM).
Support available in the NRM
Individuals who are recognised to be a victim of modern slavery in the NRM have access to specialist tailored support for a period of at least 30 days while their case is considered. Victims will have support until a conclusive grounds decision is made which can take over 30 days. If the victim receives a positive conclusive grounds decision long term tailored support will be provided to the victim. Victims will have access to the following services:
- Accommodation at safe house if destitute, has no recourse to public funds and is currently not housed by Home Office (asylum seeker accommodation)
- Confidential legal advice
- Healthcare
- Counselling
- Educational opportunities and support in obtaining employment and housing
- Financial Support
- Material Assistance
- Information on compensation entitlements
- Home country returning assistance and discretionary leave
- Assistance during criminal proceedings
- Interpreter and translation access
- Transition support in transferring to alternative support
Who can fill in an NRM?
Only first responders defined in the Modern Slavery Act can fill in and submit an NRM form on behalf of a victim of modern slavery.
The current statutory and non-statutory first responder organisations are:
- police forces
- certain parts of the Home Office:
- UK Visas and Immigration
- Border Force
- Immigration Enforcement
- National Crime Agency
- local authorities
- Gang-masters and Labour Abuse Authority (GLAA)
- Salvation Army
- Migrant Help
- Medaille Trust
- Kalayaan
- Barnardo’s
- Unseen
- NSPCC (CTAC)
- BAWSO
- New Pathways
- Refugee Council
Guidance for filling in an NRM
It is advisable that all first responder organisations train their staff in how to fill out an NRM form. If you are interested in getting trained, please contact us.
If you are a first responder and would like further guidance please click here for the national guidance
If you are first responder and need to submit an NRM form, please click here
Consent and the NRM
Consent is required for an adult to be referred to the NRM.
If the potential victim is under 18, or may be under 18, you should complete a child referral form. Child victims do not have to consent to be referred into the NRM and should be referred to wider child safeguarding processes for support.
In order to give their informed consent, first responders must explain:
- What the NRM is
- What support is available through it
- What the possible outcomes are for an individual being referred to the NRM
It should also be made clear that information may be shared or sought by the SCA from other public authorities, such as the police and local authorities, to gather further evidence on an NRM referral.
What if an individual does not consent to the NRM?
Some adults may choose not to enter the NRM, this is a valid choice and it should not be influenced by any service providers.
What the individual can do now depends on their status in the UK, if the individual has recourse to public funds, they should be referred to their local authority for safeguarding and support.
If the individual has no recourse to public funds, legal advice should be sought as soon as possible, and referrals to third sector resources.
A Duty to Notify form should be completed to alert the Home Office of a modern slavery crime if the adult survivor of modern slavery does not consent to submit an NRM form.
The process
Individuals who are recognised to be a victim of modern slavery in the NRM have access to specialist tailored support for a period of at least 30 days while their case is considered. Victims will have support until a conclusive grounds decision is made which can take over 30 days. If the victim receives a positive conclusive grounds decision long term tailored support will be provided to the victim.
First Responders submit NRMs and Duty to Notify (DtN) forms through an online portal. The form has been designed to be responsive and will change depending on the options selected including identifying whether a case is an NRM referral or a DtN referral (for individuals in England and Wales).
The online form will identify whether someone is a first responder by verifying their work email address. First responders will need to complete this verification to progress with the form.
After submitting the form (which will be sent to the Single Competent Authority) the first responder will be sent a link to download a copy. Once it’s been received by the Single Competent Authority the form will be assigned a reference number which will be emailed to the first responder.
We recommend that you use the prompt sheet when gathering information from the survivor and then upload that to the online form later. This frees you from time restrictions when working with survivors and protects you from losing your information.
You can find the prompt sheet by clicking here
Information required
Information required will include journey of the victim, and how what has happened meets the elements of human trafficking – act, means and purpose, or modern slavery – means and purpose.
First responder’s professional opinion is important, especially about the specific vulnerability of the victim. First Responders should be clear why they are making a referral and why they think this victim is particularly vulnerable to exploitation.
Include information on (if known):
- Movements in or to the UK, including dates
- Suspected place of exploitation
- Name of agent, exploiter or trafficker
- Name of other victims
- Record any action you have taken including referral to other agencies (for example The Salvation Army, police, UK Visas and Immigration) where appropriate
- Note any immediate concerns regarding the potential victim’s health, psychological well-being or safety.
- Where appropriate, include medical information
First responders will have to provide a point of contact for the Competent Authorities to contact if they need further information and to communicate decisions with the victim if needed.
Best practice for professionals dealing with victims / survivors
“Principles that underpin early support provision for survivors of trafficking” states that:
If a referral to the NRM is made, this should be done together with the survivor, in person, so they are able to read the content of the NRM form and accompanying narrative in a language they understand before they sign the form; consent can only be obtained after they have understood and agreed to the content.
First Responders must explain their own privacy note prior to ‘processing data’ and explain the Home Office’s policy prior to completing and submitting any personal data.
All survivors should be provided with a copy of the NRM form at the point it is submitted and know they can request copies in the future.
All survivors should be able to get copies of any associated paperwork; for example, correspondence about the referral that may arise after it, or supplementary documents that are sent in (before the NRM Reasonable Grounds decision), and the consideration minutes accompanying any decision.
Access to any NRM related documents should be easy for the client if asking directly or if requested by any representative or third party who has the appropriate consent (i.e. a consent form) and should not be by way of a subject access request or require a fee to be paid.
Staff acting as First Responders to the NRM need to be fully trained and able to demonstrate their knowledge of what happens with different authorities after an NRM referral when taking consent. This includes communicating that if a person chooses to enter the NRM, the NRM form will be shared with the Competent Authority, and then with the police force local to the exploitation, who may conduct an investigation, regardless of whether the survivor wish to report the crime – but that this does not mean they have to engage with police.
Advocates or caseworkers within the Places of Safety and NRM First Responders may be contacted in the future to assist with the case, so it is essential that accurate notes are kept, following organisational policy and Data Protection guidelines.
British Red Cross, the Human Trafficking Foundation, the Anti-Trafficking Monitoring Group, and Anti Trafficking and Labour Exploitation Unit (ATLEU). 2018. ‘Principles that underpin early support provision for survivors of trafficking’.
Best practise when working with survivors
Completing the NRM with best practice
As a first responder you should aim to settle these fears in survivors by reassuring survivors that your role is to help and understand them. You should never push or pressure a survivor to answer a question on an NRM form.
When talking to survivors to gather information about their experience to put on their NRM form, first responders should:
- Explain the identity, role and duties of all professionals in the room.
- Demonstrate interest in survivors’ immediate safety, health and practical needs.
- Tell survivors that they have time to be heard. Create an illusion of time even if you are busy and in a rush.
- Maintain focus on the ‘Here and Now’ – minimise any distress by referring to the ‘Here and Now’, focus on current and future safety needs.
- Use and record survivor’s names appropriately.
- Understand survivors’ presentation, remaining calm, consistent, and welcoming.
- Ensure that consent is informed and given freely.
- Set realistic goals and objectives.
- Ensure breaks are offered and taken – movement is helpful. Do not leave survivors by themselves.
- Never victim blame – for example, “why did you not leave your exploiters?” “if you had an opportunity to leave, why didn’t you?”.
- Ensure that you use the correct tone of voice, remaining empathetic, considering appropriate body language and cultural sensitivity at all times.
Rationale for victims being reluctant to disclose
It is possible that survivors of modern slavery will be reluctant to tell you their story. You should consider the possible reasons for this when faced with this situation:
- Survivors may fear being re-trafficked.
- Survivors may fear that they will not be believed – perpetrators may have convinced survivors that they have influence within the police service or government agencies.
- Survivors may fear that the potentially illegal activities in which they were involved through coercion will be discovered.
- Survivors may not know that agencies and authorities are able to help.
- Survivors may have fear resulting from belief in spiritual practices, e.g., black magic, witchcraft and juju.
- Survivors may accept their current situation as it is more favourable than their home circumstances.
- Survivors may fear that once they give evidence, they will not be paid for their work.
- Survivor may have feelings of empathy and attachment to their traffickers (Stockholm Syndrome).
- Survivors may fear that first responders will discriminate against them based on their cultural/ethnic/religious communities or families
- Survivors may have feelings of shame or guilt about the traumatic and humiliating nature of the abuse they may have experienced.
- Survivors may also be experiencing trauma and post-traumatic stress disorder, which can result in symptoms of hostility, aggression, difficulty in recalling details or entire episodes, and difficulty in concentrating.
Best practice approaches for professionals
Professionals of all disciplines who work with victims/survivors of trafficking and modern slavery should adopt and incorporate the following minimum professional standards into all aspects of their work:
- Accessibility and non-discrimination: making sure that survivors are treated fairly and with dignity. Service provision should be diverse, inclusive and flexible to meet the various requirements of each person.
- Human rights-based approach: support should never be contingent upon a survivors’ ability or willingness to cooperate with the authorities.
- Holistic and victim centred approach: survivors must be placed at the centre of any decision- making process and support must be prioritised in accordance with their individual needs.
- Empowering approach: recognise that survivors are individuals with goals, dreams, and aspirations, provide support in a way that recognises individual strength, resourcefulness, and resilience as well as vulnerabilities and difficulties.
- Freedom of thought, religion, and belief: signpost to pastoral care or religious support if requested.
- Multi agency approach
- Professional boundaries
- Trauma-informed approach
Sources
The Slavery and Trafficking Survivor Care Standards (2018)
College of Policing: Authorised Professional Practice (2020)