International recruitment to adult social care: A guide for councils

In September 2020, as a result of the continued high number of job vacancies in adult social care, the Migration Advisory Committee (MAC) recommended that senior care workers were included on the Home Office shortage occupation list. 

In February 2022 care workers were also added to the shortage occupation list and eligible for a Health and Care Worker visa. This means that overseas recruits working in care would be eligible to obtain sponsorship by an eligible sponsor, in other words, the NHS, an organisation providing medical services to the NHS, or an organisation providing adult social care to come and work in the UK. This does not include agencies employing care workers to deliver temporary care.

While it is recognised by government and councils that overseas recruitment to adult social care is not a long-term solution to addressing the workforce challenge facing the sector, it has been welcomed as an approach to tackling workforce capacity pressures in the short and medium term.  

Many councils and providers report that international recruitment can help to boost workforce capacity, bring in additional skills and expertise, and help to provide a more diverse workforce that is more representative of those needing care and support. However, international recruitment to adult social care also creates the conditions that can enable exploitation of social care staff. 

It can lead to safeguarding and quality issues and raise market contingency concerns. In extreme cases it can provide a channel for criminality, including people trafficking and modern-day slavery.

The purpose of this guide is to provide an overview of the international recruitment process as it relates to adult social care. It sets out the role of the council as a key stakeholder within this process and signposts to resources that are available to support councils. 

It is recognised that international recruitment is a dynamic process with rapid learning and development taking place. It is intended that this guide will be updated as developments continue, and emerging good practice becomes available to share. 

This guide is primarily aimed at commissioning, workforce, quality assurance and safeguarding colleagues working in adult social care in councils in England. 
 

Good international recruitment to social care involves the consideration of some key elements that ensure the selection of competent and qualified professionals, while adhering to ethical and legal requirements. 

As with domestic recruitment, the focus should be on a values driven and informed approach.

This checklist describes the characteristics of good international recruitment:
 

The health and care worker visa
 

The health and care worker visa allows professionals to come to the UK to do an eligible job with the NHS, an NHS supplier or in adult social care. It is tailored to address shortages in the health and care sector.

An applicant for a health and care worker visa will be expected to: 

• pay an application fee. The fee depends on the length of time that the recruit intends to work in the UK. Up to three years costs £284 per person, while more than three years is £551 per person. The fee is the same whether the applicant applies from inside or outside the UK. 
• be able to support themselves financially upon arrival in the UK. Applicants must have at least £1,270 in their bank account and be able to demonstrate that they have had this available to them for at least 28 consecutive days prior to applying. Applicants are exempt if they have been in the UK with a valid visa for at least 12 months and/or if their employer has agreed to cover costs during the first month in the UK. Any dependents will also need to prove that they can support themselves while in the UK.

No other charges should be passed on to the individual applying for a visa. It is important to be aware that recruitment agencies should not charge applicants to match them to roles. Any fees should fall to the employer, not the employee.

More information about the health and care worker visa is available on the government website.
 

Sponsor organisations

Organisations wishing to sponsor international recruits must be registered with the Home Office to enable recruitment into UK-based care sector roles. International recruits cannot be sponsored by private households or individuals, other than sole traders sponsoring someone to work for their business. A list of registered licensed sponsor employers is available on the government website. The list is updated daily.

The duties and responsibilities of sponsor employers who wish to recruit from overseas have been set out by the government. This includes the checks and monitoring requirements of sponsor organisations.

The Department of Health and Social Care (DHSC) has published a code of practice for international recruitment, including best practice benchmarks, for organisations undertaking international recruitment. It is expected that all employers will adhere to the 15 best practice benchmarks when recruiting from overseas. 

Some countries should not be targeted when actively recruiting health or care professionals. These are known as red list countries. Direct applications from these countries are still permitted. 

Domestically these countries face the most urgent health and care workforce challenges, and so recruitment of professionals to the UK is discouraged. 

UK Visas and Immigration (UKVI) manage sponsorship and visa processes and ensure sponsors comply with regulatory requirements. 

This includes:

• compliance with immigration rules. Sponsors must comply with immigration rules, including but not limited to, ensuring that sponsored employees meet the requirements for the health and care worker visa.
• maintaining sponsorship duties: This includes keeping accurate records of sponsored workers, reporting specific changes or events regarding sponsored workers to UKVI, and fulfilling other obligations related to record-keeping. The Home Office, in their 'Workers and temporary workers guidance for sponsors', set out sponsor duties and compliance.  
• monitoring and reporting: Sponsors are responsible for monitoring their sponsored employees to ensure they continue to meet the conditions of their visas. They need to report any significant changes to each sponsored worker's circumstances to UKVI.
• cooperation with UKVI: Sponsors must cooperate with UKVI in terms of audits, compliance checks, or requests for information related to sponsored employees.
• adherence to conditions: Sponsors are required to ensure that sponsored workers are employed according to the terms specified in their CoS. Also that their employment conditions and rights are in line with UK employment law. 

Compliance in international recruitment
 

The Home Office and UKVI set out the rules and regulations that govern organisations who hold a sponsor licence to employ international recruits to work in adult social care in the UK. 

UKVI ensure compliance with immigration laws and safeguard the interests of sponsored employees. Any breach by the sponsor of their duties can result in UKVI suspending or revoking the sponsor licence.

UKVI undertake the following steps to ensure compliance.
 

For health and care workers, the compliance process is particularly stringent. This is due to the potential impact on public safety and the importance of maintaining high standards in health and care services.

UKVI may revoke a sponsor licence for reasons including:

• non-compliance with sponsorship duties: Failure to comply with the duties and responsibilities outlined by UKVI for sponsors. This includes failure to maintain appropriate records, notify UKVI of significant changes, or adhering to immigration law and regulations
• employing unauthorised workers: Allowing individuals to work who do not have the legal right to work in the UK
• failure to report changes: Failing to report changes to UKVI within specified timeframes, for example changes in a sponsored worker's circumstances or employment
• non-adherence to sponsorship conditions: Not complying with the specific conditions and terms set out by UKVI for sponsored workers through the CoS
• providing false information or documents: Supplying false or misleading information or documents to UKVI in support of a sponsorship application or during the sponsorship period
• systemic failures: Widespread or systemic failures in the sponsor's systems or practices that prevent them from effectively fulfilling their sponsorship duties
• criminal convictions or insolvency: Sponsors facing criminal convictions or insolvency
• failure to pay fees or penalties: Non-payment of fees or penalties owed to UKVI
• sponsor poses a risk to immigration control.
   

Responding to suspensions and revocations can present challenges for councils and partners. There is system-wide improvement work taking place regionally and locally to drive quality in the market and help prevent instances of non-compliance occurring. Some of this activity is outlined in ‘working collaboratively with councils and local partnerships.’

At suspension and revocation stage councils consider the impact on those in receipt of care as well as the impacted workers. These instances can create significant capacity issues, especially where councils are dealing with high numbers of suspensions, revocations, displaced workers and/or unethical practice.

Councils receive notification of suspensions and revocations for commissioned and non-commissioned services. Where services are not commissioned by the council there is still a need to assess and consider the risks and issues impacting local people and recruits.

The considerations and actions required during a suspension or revocation are the same in terms of the assessment and contingency planning process. Not all suspensions will become a revocation, however, there will still need to be an assessment of risk and identification of issues for both. If the compliance check does become a revocation, councils will be required to implement business continuity plans immediately. 

Immediate revocations can be more challenging, particularly where the council is unsighted on the provider, business continuity plans are not fit for purpose, or there are immediate safeguarding issues.  

This section sets out the information needed to respond to non-compliance, based on emerging practice in the sector. It describes the process itself, steps that councils can take to engage with providers and their role in supporting displaced recruits. 

The diagram shows the eight key steps councils and partners are taking as part of effective management of the suspension and revocation process. Further detail is given on each step.
 

Step 1: Notification

In 2023 UKVI agreed an information sharing protocol with DHSC, Care Quality Commission (CQC), Local Government Association (LGA) and the Association of Directors of Adult Social Services (ADASS). The protocol allows councils to be informed of suspensions and revocations at an early stage in the compliance process. The aim of the protocol is to help councils and local partners to mitigate risks associated with non-compliance.

Under the new information sharing protocol UKVI informs DHSC, CQC, LGA and ADASS of a suspension or revocation when a concern or breach has been identified. The email notification identifies the name and registered address of the provider, the reason for suspension/revocation and the number of recruits potentially impacted by it. 

The actual number of impacted recruits may later differ from the early information received. This could be due to the provider operating in several areas, or because they have more licences than the number of workers currently employed. 

The reasons for suspension / revocation will be categorised under a number of headings:
 

• certificate of sponsorship misuse
• recruitment concerns
• monitoring issues
• recouping of fees
• supply sponsored worker to third party as labour
• reporting and document retention
• genuineness of vacancies
• failure to retain documents
• sponsor reporting issues
• not complying with UK law
• salary underpayments
• sponsor poses a risk to immigration control.

On receipt of the email notification, CQC check the registration status of the provider and report any issues to the national group. Information will then be forwarded to the relevant regional international recruitment lead(s) by the national ADASS lead. If the regional lead requires specific or additional information, they liaise with the national ADASS lead, who will contact UKVI for a response.

Step 2: Conduct local checks

When a notification is received, councils assess the implications and issues arising from it by undertaking local checks. 

There are some useful sources of information to help with this:

• the name(s) of responsible people within the sponsor organisation or any associated companies and/or services can be identified on the provider website, via CQC or Companies House. The CQC can verify if the provider is registered with them
• the registered address of the sponsor organisation is given on the notification e-mail. However it is advisable to look beyond the registered address of the provider to ascertain the spread of provision across other councils or regions, NHS services and self-funders. Where additional information is found, this is shared with the relevant organisation(s)
• the safeguarding team in the council and CQC can help to identify any safeguarding and/or other concerns about the organisation. Some non-commissioned providers may be known to the safeguarding teams so important to triangulate information
• the Home Office online register of worker and temporary worker licensed sponsors will identify locally registered care providers.  

Step 3: Strategy discussion

Within 24 hours of notification of suspension or revocation of a sponsor licence many councils are now holding a strategy discussion. The purpose is to agree what action needs to be taken, by whom and who needs to be engaged. A further strategy meeting takes place once the initial information has been gathered. 

There may be obvious issues and complexities identified in the strategy discussion that will require support from other agencies. Given the timescales involved, early contact with other agencies is helpful in enabling an effective multi-agency approach. 

Councils may consider placing a hold on purchasing additional services from the provider until the outcome of the compliance investigation is known.  
 

Step 4: Contact the provider

Consideration needs to be given to determine the best way to approach the provider. The provider may not be known to the council or have a pre-existing relationship with them. Some areas work closely with the local care association at this stage and report finding it helpful in brokering the relationship. 

The purpose of the contact is to understand the implications of the suspension or revocation on service provision, continuity of care, safeguarding for service users and international recruits.

During the contact, councils may wish to clarify with the provider:

• details of service users supported by international recruits, continuity of care plans and safety implications 
• if the provider is able to provide continuity of care. If not, what action can the council take to support? Does the council need to make contact directly to inform or provide reassurance? What are the implications for business continuity? 
• the numbers of workers impacted
• if the revocation will result in displaced recruits. What can be done to ensure the workers have appropriate support and advice? 
• other areas where the company operate
• any concerns of the organisation or support required

Further information about operating areas should be shared with the relevant regional international recruitment lead.  

Step 5: Business continuity / safeguarding

The council has a significant role in supporting the provider to conduct impact assessments, develop contingency plans and to ensure the ongoing continuity of care for people. 

Councils will be presented with a range of providers with differing issues and employing differing numbers of workers. In some instances a provider may have a high percentage of sponsored workers resulting in implications for the wider system in the event of provider failure. 

At suspension stage it may be appropriate for the council to provide information to UKVI to assist in understanding the local relationship. This could be relevant for organisations with an existing contractual relationship with councils. 

In some cases, the scrutiny that takes place due to a revocation, identifies safeguarding and quality issues that need to be addressed with the provider or through formal routes.

Step 6: Agree a multi-disciplinary response

A multi-disciplinary response may have already been initiated prior to this point. However, following contact with the provider new information may have come to light which requires involvement with other agencies. Local partners that the council may need to engage include the provider alliance, other councils contracting with the provider, the police, NHS and so on.

There are several national organisations that are engaged in compliance for international recruitment, including UKVI, CQC, the Gangmasters and Labour Abuse Authority (GLAA) and the Employment Agency Standards Inspectorate (EAS). There is further information about these organisations under signposting to support.

Step 7: Engage the provider

There are many reasons why a provider may have had their sponsor licence suspended or revoked. For some it could be due to management capability or over enthusiastic recruitment, others can be a result of unethical practice or criminal activity. Distinguishing between the reasons will be important for informing risk management strategies for councils. 

It is likely to be a stressful time for providers, who will undoubtedly be concerned for their ongoing business. As a result, some providers may be reluctant to engage with councils. Taking a supportive and collegiate approach and working with the local care association, where available, can help to navigate these dynamics. 
 

Step 8: The role of councils in supporting displaced recruits

International recruits are an important part of the local social care workforce. It is in the best interests of the council and system to retain and support recruits where possible. 

A sudden loss of employment, arising from the revocation of the employers sponsor licence, would leave many international recruits feeling vulnerable. This in turn may potentially lead to safeguarding and other support needs. 

Re-employment

It is not the responsibility of councils to find employment for displaced workers. Often the recruit themselves will be proactive in finding new employment. Councils can however support providers in connecting displaced workers with new employment opportunities. For example by organising or supporting job fairs.

There may be local providers with a sponsor licence who are willing to step in and sponsor displaced recruits. Having good connections with the provider network and understanding the market can help to identify the providers with sponsor licences who may be able to employ displaced workers. 
 

Signposting to support and advice

Councils can work with regional and local partners to ensure there are services in place to provide support and advice to displaced workers. For international recruits, knowing where to access support and advice can reduce vulnerability and empower them to navigate the implications of a sponsorship revocation. Signposting to support and advice services needs to be part of an ongoing process and not just take place at the revocation stage. 

There can however be challenges connecting with the international workforce at this stage. Councils are not currently provided with the names of displaced international recruits as a matter of course. The best route to connecting with recruits can be through the employer, staff networks and other community and support services. Sometimes workers may disappear into another area of work or become a victim of exploitation before they can be reached by the council or someone from the sector. 

Ensuring that workers are informed about support and advice routes should be part of a good induction process. Councils can also take steps to ensure that information is visible in the workplace, such as in staff rooms or through training courses. Unions are also a good source of support and information. Social media networks are a powerful way of building peer support communities between international recruits.

No recourse to public funds (NRPF)

Displaced recruits may find themselves with no recourse to public funds (NRPF). A NRPF condition is usually imposed when a person has been issued with leave to enter or remain for a temporary purpose, such as to visit, study or work. 

Local authorities have a duty to provide support and assistance to individuals, including those with NRPF, only under certain circumstances. The responsibility is outlined in the Children Act 1989, the Immigration and Asylum Act 1999, the Care Act 2014 and the Mental Health Act 1983, as amended in 2007.

Here are some key points:

• children's services: Councils have a duty to safeguard and promote the welfare of children, regardless of their immigration status. If a child is in need and has NRPF, the council may provide support, accommodation, and other services to ensure their well-being.
• adult social care: If an adult is vulnerable and has care and support needs, the council may have a duty to assess those needs and provide necessary support, irrespective of immigration status. Councils are not required to meet the needs of individuals with NRPF who do not meet the legal thresholds for care and support, when these needs have arisen because of destitution.

Each individual is likely to require a case by case assessment and the No Recourse to Public Funds Network has produced guidance for council officers working with people with no recourse to public funds who are destitute or at risk of homelessness. 

The network run the NRPF Connect database which seeks to expediate Home Office decision making on individual cases and make recommendations for wider council practice.
 

Checklist for councils

Ethical recruitment and retention of care workers is the responsibility of a number of national and local partner organisations, including councils. 

Government sets immigration policy and the Home Office and UKVI are responsible for ensuring compliance by issuing, suspending or revoking licences to providers. Providers are responsible for ethical recruitment, pastoral care and the pay and working conditions of their staff. 

Directors of adult social care have responsibility for three key elements of international recruitment:

• safeguarding under the Care Act
• market shaping, commissioning, contract management and quality assurance
• working collaboratively with providers and local partnerships.

This section outlines current and emerging practice in these three key areas, with practical steps councils can take to ensure ethical international recruitment. 

 

Unethical international recruitment can present safeguarding challenges for councils. As well as the potential detrimental impact on the people who are drawing on care and support, recruits and their dependents could present with care and support needs.  

Ethical international recruitment incorporates a focus on ensuring that recruits have the required language skills to be able to undertake their role effectively. They have an induction process that enables them to understand the cultural nuances of life in England so that they can adapt to living and working here. 

There may be differences in the approach to delivery of care in the UK and different legislative frameworks that recruits need to get used to. Approaches to dementia care, person centred approaches and deprivation of liberty, for example, can be fundamentally different to overseas. 

Recruits need good pastoral support to ensure that they are not isolated and have their basic needs met, particularly in the early weeks and months. Where these support needs are not met there can be quality of care or safeguarding implications for the people in receipt of care. 

In extreme cases people who are recruited unethically from overseas may be exposed to criminality. This may take the form of modern slavery, debt bondage or labour exploitation.

The CQC, in the 'State of Care 2022/23' reported that there was a notable rise in referrals for concerns regarding modern slavery and labour exploitation within the UK Care sector. In 2022/23 CQC made 37 referrals, more than four times the number of referrals made in 2021-22.

As a consequence of this treatment, recruits may suffer the effects of deprivation in the form of poor or no accommodation, inadequate funds to live on and inadequate support for dependants. All these circumstances may result in support needs from councils or the wider public sector. 

Many places have developed multi agency approaches to tackle modern slavery and exploitation in the care sector. Initiatives have included awareness raising and developing system improvements to mitigate the risks of unethical international recruitment. 

Community Safety Partnerships have safeguarding responsibilities as part of their broader commitment to enhancing public safety. There may be activity taking place within the partnership to respond to modern slavery and criminal exploitation.
 

Emerging practice examples

Identifying and reporting unethical practice

Modern slavery, debt bondage, labour exploitation and other unethical practices can be difficult to identify. International recruits may be fearful of engaging with authority or discussing their situation with other people. This may be because of previous life experience, concerns about losing their visa or coercive control by others. 

The exploitation can also be hidden by virtue of the working arrangements or employer. Recruits working in home care or employed by agencies may have fewer opportunities to access support and information than those working as part of a team in a care home. 

Employment Agency Standards (EAS) Inspectorate has oversight of agencies in the social care sector. In a webinar in 2023 they shared some examples of unethical practices they have found, including:

• work finding fees being charged by some agencies
• fees being charged for additional services
• charges for certificates of sponsorship
• students working in excess of their visa allowance
• potential National Minimum Wage issues.

The University of Nottingham Rights Lab, working with councils and the LGA, produced a guide on establishing modern slavery risk assessment and due diligence in adult social care for commissioning officers and managers within adult social care teams in councils. It provides advice on to how to set up effective local systems to identify and manage the risks of modern slavery. 

There are several organisations that have a role in the oversight of ethical working practices in the social care sector, including UKVI, CQC, GLAA and EAS. These organisations are key partners when dealing with unethical practice. Information about these agencies, their roles and signposting for further information are given at the end of the guide.

Checklist for councils

Local government responsibilities around international recruitment are not explicitly outlined in the Care Act. However, international recruitment influences the workforce composition and service provision within the adult social care market, thereby impacting the broader efforts of market shaping by councils. 

When market shaping and commissioning services, councils should consider the potential contribution and challenges associated with international recruitment in their strategies.

Local provider market capacity, quality and continuity of care can be impacted both positively and negatively by international recruitment, depending upon individual provider approaches. It is important to be clear about the difference between good providers undertaking ethical international recruitment, providers who are less proficient and need support, opportunists wanting to secure labour for new or expanded business and unscrupulous or criminal activity associated with trafficking and slavery. 

Local partners will take a different response to each of these groups and scenarios, often with different lead organisations.  
 

Understanding the market

Councils can take steps to understand the extent to which international recruitment impacts the local market. This includes knowing the number of providers in the area that hold sponsor licences, the number of workers and type of organisation. 

It is important for councils to understand what is happening in relation to international recruitment in their area due to its potential impact on business continuity. However, there are challenges for councils in capturing this information. 

Due to the complex nature of the social care market, it can be difficult to get a clear view of the number and nature of providers and agencies with sponsor licences in any one area. The government publish a register of licensed sponsors, however this is based on the registered address of the provider and does not identify areas of operation.

Not all locally based social care providers or agencies will be commissioned by the council. Others will be registered in different areas from those in which they operate, and councils are not routinely provided with this information. 

In some areas, the number of providers operating will create challenges of scale in gathering the information on those with sponsor licences. 
Some regions have tested the use of capacity tracker to gain additional information about international recruitment. 

The addition of questions about the number of workers sponsored and in which business area, has given a better understanding of the market. It is anticipated that this approach will be adopted nationally which will help councils in understanding the local market. 

The West Midlands has sought to address this issue through the development of an international recruitment sponsors dashboard. 
 

Emerging practice example

There is an opportunity through the commissioning and contract management process for councils to manage some of the risks presented by international recruitment.

Emerging practice examples

Checklist for councils
 

It is a duty under the Care Act for councils to work collaboratively with providers and local partners. Collaborative working is particularly important for international recruitment given the number of stakeholders and the fact that responsibilities for ethical international recruitment are spread across the system. 

Both providers and international recruits may have support needs. If these needs are not met, it can have implications for service delivery and consequential demand on the wider system. Councils are not accountable for meeting all of the support needs, but they could be accountable for adverse outcomes that emerge as a result of them not being met. By collaborating with partners, councils can work to mitigate risk and support the effective management of ethical international recruitment.  
 

National and regional infrastructure

Every region in England has one or more people who act as a professional lead for international recruitment in their area. ADASS and the regional international recruitment leads support DASS’s and regional colleagues in the instance of a sponsor having their sponsor licence suspended or revoked. The steps in the compliance process are set in the guide.

We are supporting the sector through the facilitation of a national network of international recruitment leads. This network includes colleagues from DHSC and other key partners. The aim of the network is to share good practice and collectively develop solutions to common challenges around international recruitment.

Utilising funding from government all regions or sub regions have developed international recruitment partnerships or hubs that are focussed on driving quality in international recruitment. Some offer support to providers, supporting the training and pastoral needs of recruits, as well as initiatives to match recruits to new employers when needed. 

Emerging practice examples

Local partnerships, community and voluntary organisations

Local partnerships, community and voluntary organisations can help when responding to the needs of international recruits. Many may already be working with international recruits or have services that would be of benefit to them. Some areas have commissioned locally based organisations to provide additional support and advice to recruits. These include Citizens Advice Bureau, Justice and Care and the Salvation Army.

Provider networks

Engaging with provider networks and local care association alliances on international recruitment gives an opportunity to build a consistent approach to market development, due diligence and quality assurance. 

Strong relationships across the network can help to develop collaborative approaches to support the needs of the sector and the recruits. It can also help with managing the challenges when a sponsor licence is revoked or re-employing displaced workers. 

Networks offer an opportunity to share knowledge and resources, alongside a space to collectively drive quality. The guide signposts to resources or support with ethical international recruitment.
 

Checklist for councils
 

Planning for capacity to manage risk is complex. Revocations can occur suddenly, having implications for business continuity and the safety of people in receipt of care and support as well as resulting in high numbers of displaced recruits who may need support. 

Councils are increasingly trying to mitigate some of the risks presented by building international recruitment considerations into commissioning and contract management processes as outlined in the guide. However risk strategies need to be developed for instances where mitigating action is not effective. 

This section sets out some of the current system challenges and considerations for risk planning.

• International recruitment is not limited to any single council or region of the country and some providers operate in multiple locations nationally. Not all providers or agencies will be directly commissioned by the council to which the provider is registered and therefore the notification is sent. Some may provide services to residents in the company registration area and others may be operating in a different council area. This can create challenges in understanding the local market, and at revocation stage.
   
• At present, the Home Office do not share aggregated data with councils, the LGA or ADASS on compliance.  As data controller the Home Office do not share information about sponsor licences unless there is a suspension or revocation. In practice this can result in councils having to respond quickly based on limited information. 
   
• Initiation of a revocation or suspension will require a quick response from local government. A revocation could have continuity of care and safeguarding implications and, depending on complexity, may require a multi-agency response and additional resources. 
   
• Not all suspensions will result in a revocation, but they will still require input from the council in relation to risk assessment, potential safeguarding and business continuity planning. 
   
• Whilst there are many good providers engaged in ethical international recruitment, there are also organisations engaged in criminal activity including immigration crime, modern slavery and labour exploitation. Councils need to determine which organisations they are working with and what support is needed, if any.
   
• With NRPF international workers could quickly become destitute and/or vulnerable to exploitation. Where a person finds themselves with no accommodation or income, they may approach the council for help. 
   

Checklist for councils
 

The Care Quality Commission (CQC) help to ensure that care providers adhere to fair and lawful employment standards. In November 2023 CQC published a regulatory policy position on modern slavery and unethical international recruitment. The new assessment framework enables CQC to routinely assess how a provider is managing the risks of modern slavery and ensuring the wellbeing of internationally recruited staff.

Employment Agency Standards Inspectorate (EAS) protects the rights of agency workers by ensuring that employment agencies and businesses treat their workers fairly. It is part of the Department for Business and Trade. EAS is responsible for seeking compliance with the Employment Agencies Act 1973. This legislation requires recruitment agencies, including those in social care, to abide by specified minimum quality standards. 

Gangmasters and Labour Abuse Authority (GLAA) works in partnership to protect vulnerable and/or exploited workers. It has the responsibility to license and regulate labour providers in regulated sectors. This includes ensuring compliance with employment standards, preventing worker exploitation, and investigating cases of labour abuse or modern slavery. 

HM Revenue and Customs (HMRC) National Minimum wage. Payment of the national minimum wage is enforced by HMRC on behalf of the Department for Business and Trade. They provide information to employers and prevent wrongdoing. If an underpayment is identified employers will receive a notice of underpayment setting out arrears due and the penalty, which is 200 per cent of the total underpayment (max £20,000). 

Justice and Care is a charity that provide support to victims of modern slavery. They work alongside the police and other regional partners to identify people trapped in modern slavery and support them to be free. 

Modern Slavery and Exploitation Helpline is operated by Unseen UK an anti-slavery charity. The helpline provides advice and guidance to those who believe they have seen or experienced modern slavery or human trafficking. They can help with access to support services and can make referrals into the National Referral mechanism. 

The National Referral Mechanism (NRM) is a framework for identifying and referring potential victims of modern slavery and ensuring they receive the appropriate support. Only first responder organisations, which includes local authorities, can refer a potential victim of modern slavery into the National Referral Mechanism. Referrals are then actioned by the Home Office. 

UK Visas and Immigration (UKVI), which is part of the Home Office, is responsible for determining who has the right to visit or stay in the country. They should be contacted when there is suspicion a sponsor organisation is involved in immigration crime, or other unethical practice.