Futures of Work ~ Reflections and recommendations from the second U.K. Independent Anti-Slavery Commissioner

The role of the Independent Anti-Slavery Commissioner was established by the Modern Slavery Act 2015 to encourage good practice in the prevention, investigation and prosecution of modern slavery offences and the identification and support for victims.

In 2019, I was appointed as the UK’s Commissioner and served for three years. This article reflects upon my experience in that role, makes observations on recent developments and recommendations for future legislation on modern slavery.

My strategic plan set four high-level objectives in 2019: improving victim care and support; supporting law enforcement and prosecutions; focusing on prevention; and getting value from research and innovation.

Improving victim care and support

The focus of victim care had historically been on identification and immediate support, and while this remained important, I was also keen to increase support over the long term and enable survivors to live lives of sustainable independence. Key to this were issues such as access to education and training, job opportunities, decent accommodation, settled immigration status and long-term psychological support. I worked closely with survivor groups on this agenda and employed a survivor in my office.

However, my work to support victims took place in an increasingly hostile environment. Shortly after I took up my appointment, there was a change of government, and modern slavery was no longer a political priority; victims of trafficking were seen almost exclusively through an immigration lens. The focus of ministers was on immigration legislation and recommendations of the Independent Review into the Modern Slavery Act[1] to amend and strengthen the Act, which the government had largely accepted were never implemented. The New Plan for Immigration was published in March 2021, and the accompanying press release claimed ‘an alarming rise in people abusing our modern slavery system by posing as victims in order to prevent their removal and enable them to stay in the country’[2].

The evidence of this alleged abuse was never produced, and annual increases in the number of victims identified were seen as proof of abuse – with no account taken of the Home Office’s positive assessment of 85-90% of cases. This strategy laid the way for two pieces of legislation: the Nationality and Borders Act in 2022 and then the Illegal Migration Act in 2023. Both severely undermined victim protection in general. As a consequence of the change in government, many of these provisions have not been enacted, but they remain on the statute book.

However, as the political focus on irregular arrivals on small boats across the Channel has intensified, it was inevitable that the current Labour government would return to the issue. In September 2025, an Eritrean man who had arrived in the UK by small boat and was due to be returned to France under the “one in, one out” returns pilot scheme between the UK and France won a last-minute legal claim to temporarily block his removal to France.[3] His lawyers successfully argued that he needed more time to present evidence that he might be a victim of modern slavery.

The government has put much store by the agreement with the French, and it was no surprise to hear the Home Secretary observe, “Migrants suddenly deciding that they are a modern slave on the eve of their removal, never having made a claim before, make a mockery of our laws and his country’s generosity”.[4] The Home Office immediately challenged this decision in the Court of Appeal but was unsuccessful. This skirmish in the courts has led the Home Secretary to vow to look again at the Modern Slavery Act[5] and the Prime Minister to argue that we need to look again at the interpretation by the courts of the European Convention on Human Rights (ECHR) and other international treaties in immigration cases.[6] There is increasing unease that some provisions of international law are being interpreted too expansively to allow states to cope with the modern scale of migration. Victims of modern slavery in need of protection may well be impacted.

Supporting law enforcement and prosecutions

I used my knowledge and networks as a former chief constable to encourage prioritisation and professionalisation. Cases of slavery and trafficking are complex and complicated – they require the development of expertise and adequate resourcing. I convened and supported law enforcement, and in particular, encouraged the use of financial investigation and prosecutions that did not rely on the testimony of vulnerable victims. The House of Lords report on the Modern Slavery Act in 2024 reported that the prosecution rate was low at 1.8% but acknowledged the difficulty of evidence gathering given the hidden nature of the crime and the similarity to rates for domestic abuse and sexual offences, which are respectively 1% and 3%. [7]

‘Follow the money’ was originally about political corruption, but it is a good response for anti-slavery. I pursued this theme while encouraging good practice with both law enforcement and the financial services sector. I published two reports on financial investigation and recommended to law enforcement that they make a step change in their use of financial investigation, financial intelligence from suspicious activity reports and their investment in public-private partnerships.[8] [9] Financial investigation can provide vital evidence for the prosecution, but it also increases the opportunity of returning the proceeds of crime to victims.

However, as the political focus on modern slavery diminished, it was inevitable that the law enforcement focus would do so too. In the last few months, the Independent Anti-Slavery Commissioner has reported that “the leadership and coordinated action that once drove progress have faded. The policing structures built to tackle modern slavery are being dismantled, leaving hard-working officers ill-equipped to tackle modern slavery.”[10]

Focusing on prevention

Protecting victims and prosecuting traffickers is not enough. There needs to be a greater focus on prevention. Given an estimated 28 million people in forced labour across the globe, more needs to be done to tackle the global systems and structures that allow this devastating crime of modern slavery to thrive[11]. Aggressive commercial practices and corporate negligence intersect with fragile communities, migrant labour, corruption and criminality, resulting in exploitation across the globe. Modern slavery and human trafficking are economic crimes generating US$236 billion a year in profit[12]. In my time as Commissioner, I published several reports on the role of business in preventing exploitation.[13][14]

In the four years since I stepped down as the Commissioner, I have focused my efforts on the role of business in preventing modern slavery. At the University of Nottingham’s Rights Lab, we partner with Sainsbury’s to research their salient and evolving human rights risks, interpret how these risks will affect their business in the future and understand how they can respond. [15] At CCLA Investment Management, we have benchmarked the top UK companies on their performance in addressing modern slavery so that investors can hold them to account and encourage improvement.[16]

And lastly, I was keen to bridge from the academy to policy and practice. Building collaborations with many research centres and supporting their work was a priority. And no,w as a member of a research centre, I am continuing that work from the other side of the bridge.

Recommendations

It is tempting to collate a long wish list of recommendations, but I have tried to focus on the priorities and restricted myself to three.

Light-touch approaches to forced labour in businesses and their supply chains have not impacted the business models where short-term profit is pursued at the expense of long-term harm. The transparency in supply chains requirements of the Modern Slavery Act need to be tightened up to include the public sector, to mandate the information required by modern slavery statements, and to impose civil penalties for non-compliance. But ultimately, this legislation is about disclosure. Legislation needs to prompt action to identify risks and prevent and mitigate them. While this government urges businesses to conduct human rights and environmental due diligence, the Joint Committee on Human Rights recently concluded that goods made with forced labour were entering the UK – cotton, tomato products, solar panels and critical minerals.[17] Voluntary approaches are clearly not succeeding, and the government should introduce legislation to hold companies to account for conducting human rights and environmental due diligence.
The conflation of modern slavery and immigration puts the Independent Ant-Slavery Commissioner in the political crosshairs. The independence of the role needs to be strengthened: the appointment and renewal should not be in the hands of a minister where there is an obvious conflict of interest; the appointment should be for five or seven years so that a post holder can speak without fear of favour and there should be adequate resourcing.
Modern slavery is the most egregious form of exploitation, but it flourishes where labour inspection, enforcement of standards and worker engagement are poor. The establishment of the Fair Work Agency is an opportunity to make a step change in the protection of workers; it must not be wasted.

Dame Sara Thornton, a former chief constable, served as the U.K.’s Independent Anti-Slavery Commissioner from 2019-2022. She is a Professor of Practice in Modern Slavery Policy at the Rights Lab, University of Nottingham and a consultant in modern slavery at CCLA Investment Management.

[1] https://www.gov.uk/government/publications/independent-review-of-the-modern-slavery-act-final-report/independent-review-of-the-modern-slavery-act-final-report-accessible-version

[2] https://www.gov.uk/government/news/alarming-rise-of-abuse-within-modern-slavery-system?utm_medium=email&utm_campaign=govuk-notifications&utm_source=6c102776-b34d-40fa-be92-832918e4befd&utm_content=daily

[3] https://www.bbc.co.uk/news/articles/c1dqe2443l1o

[4] https://www.bbc.co.uk/news/articles/cj3yrrnydero

[5] https://www.theguardian.com/uk-news/2025/sep/23/home-office-blocked-from-appealing-against-halt-to-deportation-of-eritrean-under-one-in-one-out

[6] https://www.bbc.co.uk/news/articles/cd72p30v574o

[7] https://publications.parliament.uk/pa/ld5901/ldselect/ldmodslav/8/8.pdf

[8] https://www.antislaverycommissioner.co.uk/media/jk0ohl1i/financial-investigation-of-modern-slavery-march-2021.pdf

[9] https://www.antislaverycommissioner.co.uk/media/n5emst4j/financial-review-part-2-november-2021-iasc.pdf

[10] https://www.antislaverycommissioner.co.uk/news-insights/report-policing-response-to-modern-slavery-how-has-it-changed-in-the-last-10-years/

[11] https://www.ilo.org/publications/major-publications/global-estimates-modern-slavery-forced-labour-and-forced-marriage

[12] https://www.ilo.org/resource/news/annual-profits-forced-labour-amount-us-236-billion-ilo-report-finds