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Supporting modern slavery victims through homelessness services at Westminster City Council

Over the past three years Westminster City Council, working with The Passage, a local homelessness charity, has used an emergency bed protocol to target support at victims of modern slavery and human trafficking.

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This protocol is backed up by the development of a multi-agency case conference (MACC) approach to supporting victims of modern slavery identified through homelessness services. Last year, the approach was supplemented through the creation of a dedicated navigator post, based in The Passage, to support victims.

Westminster has a dedicated rough sleeping team, managed separately to the statutory homelessness (housing solutions) team, reflecting the borough’s historically high rates of rough sleeping and the fact that many rough sleepers do not have a local connection and therefore are not owed a housing duty.

The council’s rough sleeping team (which incorporated the prevention team, rough sleeping, supported housing and links to local homelessness services) already had an emergency bed protocol through which around 6-7 emergency beds were available, for example to support people with no recourse to public funds. Although this included provision for victims of modern slavery, it was not apparent that the protocol had been used for this purpose.

In 2018, The Passage highlighted to Westminster that they were starting to see victims of modern slavery accessing their services and asked what support the council could provide. The emergency bed protocol was highlighted as one solution, leading to the development of a new approach to providing emergency accommodation and a wraparound approach through the MACC. Recognising that there is no statutory duty to accommodate victims of human trafficking specifically, the protocol is operated using the council’s powers under the Localism Act.

Cases of modern slavery identified other than through the rough sleeping / homelessness team will subsequently be referred to the team to utilise the emergency bed protocol/MACC approach where the victim is homeless. However, in Westminster, most cases of modern slavery are picked up through the rough sleeping team and through homelessness services such as day centres and outreach teams, rather than through adults without housing approaching the council.

What does the protocol/MACC approach involve?

The protocol is aimed at clients who are recent victims of crime, or where the National Referral Mechanism (NRM) has been exhausted or reasonable grounds decisions are awaited. The protocol enables four local charities - St Mungo’s, The Passage, West London Mission and Connections at St Martin’s – to make referrals for emergency beds without the approval of Westminster’s Commissioning Team. The council created a new trafficking emergency bed service email address to ensure that all members of the team were aware of cases as they came through.

Emergency bed referrals can be made by other agencies but must first be approved by the Commissioning Team.

The emergency beds are based in local hostels. Although hostels may not be the ideal environment, it was preferable to other alternatives due to the risks of individuals being targeted when night centres require people to vacate places first thing in the morning. Often the beds may be spaces in office spaces but where available void spaces are used; in both cases, there is no additional cost attached to the council.

Once a person is in an emergency bed, the priority is to try and find the right or available provision for them: emergency beds can be accessed for a maximum of seven days. The length of stay can be extended at the discretion of the manager of the hostel and approval of Westminster City Council, although in such cases Westminster will seek to expedite the actions of the Salvation Army and the NRM.

In late 2018 the council collaborated with The Passage to launch the Multi Agency Case Conference pilot, a dedicated approach to victims of modern slavery which goes beyond the accommodation provided under the emergency bed protocol to people with a range of vulnerabilities. The aim of the approach is to provide proactive, preventative relief that helps to prevent re-trafficking and re-exploitation. When a potential victim is identified by The Passage or within Westminster, a MACC is arranged within 48 hours bringing together:

  • The Passage
  • Westminster Council Adult Social Care
  • Westminster Council Rough Sleeping Team
  • An immigration advisor (if appropriate)
  • An NHS nurse (Homeless Team) (if appropriate)
  • Police (if appropriate)
  • Pre-NRM safe house case worker (if appropriate)
  • Any other key workers from external agencies providing support to the potential victim (PV).

The housing solutions service have also been involved in MACCs when cases are identified through the housing solutions service rather than homelessness services.

The MACC will discuss a range of issues including:

  • a risk and vulnerability assessment and wider needs assessment
  • the health and mental health of the potential victim
  • support provided by the passage
  • emergency accommodation and who is providing it
  • capacity to consent
  • referral into the NRM or duty to notify, and the lead first responder for this
  • any legal issues (eg, immigration status, involvement in criminality)
  • children.

The aim of the MACC is to agree an action plan for the victim setting out the steps different partners will take and by when. The creation of a detailed plan of actions and timelines has had a positive impact on victims.

Since 2020, following a successful funding bid to what was the Ministry of Housing Communities and Local Government’s Rough Sleeping initiative, The Passage’s input to the MACC has been through its modern slavery navigator post, which is commissioned by the council. The navigator post provides a dedicated support worker function for potential victims of modern slavery, creating capacity to work with victims through the victim support process until they are in a safe place (e.g., safe housing, or safe assisted voluntary return). The navigator post works with victims at the pre, post and no-NRM situations and helps to develop tailored plans based on the housing, medical, legal, financial, emotional and social needs of victims. Alongside advocacy, the role involves practical support with tasks such as registering for healthcare, supporting legal homelessness applications, accessing legal advice etc. Following a successful first year of the pilot, in 2021, funding for the post was extended for a further year.


So far, 46 MACCs have taken place, 61 per cent of which took place within 48 hours, with action plans produced in all cases. 17 external organisations have been involved as well as Westminster.

76 per cent (35 cases) led to an NRM referral, from which 94 per cent (33 cases) received a positive reasonable grounds decision. In 11 cases, an NRM referral was not made because the client disengaged, refused to enter the NRM after further consideration, or because they had already received a positive conclusive grounds decision but became homeless after that.


Westminster’s approach has been influenced by the historic prevalence of rough sleeping within the city and by the council’s rough sleeping team consequently being closely linked to local homelessness services including day centres and outreach. Similarly, having the pre-existing emergency bed protocol in place prior to the development of the Modern Slavery and Human Trafficking protocol was helpful, because it meant that providers did not need to be persuaded to do something new. However, there are nevertheless learning points that all councils without this background can draw on.

One of the benefits of Westminster’s previous work in this area was that key expertise such as outreach, health, immigration advisors, were already linked into the council and could be included within the MACC approach. In areas where this isn’t the case, councils may need to play a role in bringing partners around the table. The MACC approach of bringing partners together, ideally within 24 hours but a maximum of 48 hours of identification, requires partners to be committed and responsive.

Westminster has worked in partnership with The Passage on this project, and other councils seeking to replicate the model may find it helpful to work with local charities to do so. However, other councils have used a different approach of creating a single integrated modern slavery team which brings different teams and services together. The key point is to have someone to drive the development of the approach, as well as buy in and support from senior officers and politicians, and from external partners.

Access to grant funding proved extremely helpful as it enabled the workstream to add the victim navigator post to the overall approach.

One challenge that has been experienced is that, due to Care Act thresholds, it has not been possible to ensure a consistent approach to support for victims through adult safeguarding processes. Stage three of the MACC process sets out that a safeguarding referral will be made if appropriate; the information and advice team in adult safeguarding will screen for Section 42 and undertake a safeguarding 3-point test. However, in practice it is rare that it is identified that a safeguarding referral is required under the Act.