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Crown Court
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Slavery, servitude and forced or compulsory labour/ Human trafficking

s.2, s.1, Modern Slavery Act 2015

Effective from 01 October 2021

Slavery, servitude and forced or compulsory labour, Modern Slavery Act 2015, section 1

Human trafficking, Modern Slavery Act 2015, section 2

Triable either way
Maximum: Life imprisonment
Offence range: High level community order – 18 years’ custody

These are Schedule 19 offences for the purposes of sections 274 and 285 (required life sentence for offence carrying life sentence) of the Sentencing Code.

For offences committed on or after 3 December 2012, these are offences listed in Part 1 of Schedule 15 for the purposes of sections 273 and 283 (life sentence for second listed offence) of the Sentencing Code.

These are specified offences for the purposes of sections 266 and 279 (extended sentence for certain violent, sexual or terrorism offences) of the Sentencing Code.

Guideline users should be aware that the Equal Treatment Bench Book covers important aspects of fair treatment and disparity of outcomes for different groups in the criminal justice system. It provides guidance which sentencers are encouraged to take into account wherever applicable, to ensure that there is fairness for all involved in court proceedings.

Step 1 – Determining the offence category

The court should determine the offence category with reference only to the factors in the tables below. In order to determine the category the court should assess culpability and harm.

Culpability

Where there are factors present from more than one category of culpability, or where the level of the offender’s role is affected by the very small scale of the operation, the court should weigh those factors in order to decide which category most resembles the offender’s case.

A - High Culpability

  • Leading role in the offending
  • Expectation of substantial financial or other material advantage
  • High degree of planning/premeditation
  • Use or threat of a substantial degree of physical violence towards victim(s) or their families
  • Use or threat of a substantial degree of sexual violence or abuse towards victim(s) or their families

B - Medium culpability

  • Significant role in the offending
  • Involves others in the offending whether by coercion, intimidation, exploitation or reward
  • Expectation of significant financial or other material advantage
  • Some planning/premeditation
  • Use or threat of some physical violence towards victim(s) or their families
  • Use or threat of some sexual violence or abuse towards victim(s) or their families
  • Other threats towards victim(s) or their families
  • Other cases falling between A and C because:
  • Factors in both high and lower categories are present which balance each other out and/or
  • The offender’s culpability falls between the factors as described in A and C

C - Lower culpability

  • Engaged by pressure, coercion or intimidation, or has been a victim of slavery or trafficking related to this offence
  • Performs limited function under direction
  • Limited understanding/knowledge of the offending
  • Expectation of limited or no financial or other material advantage
  • Little or no planning/premeditation

Harm

Where there are factors present from more than one category of harm, the court should weigh those factors in order to decide which category most resembles the offender’s case.

If the offence involved multiple victims or took place over a significant period of time sentencers may consider moving up a harm category or moving up substantially within a category range.

The assessment of harm may be assisted by available expert evidence, but may be made on the basis of factual evidence from the victim, including evidence contained in a Victim Personal Statement (VPS). Whether a VPS provides evidence which is sufficient for a finding of serious harm depends on the circumstances of the particular case and the contents of the VPS. However, the absence of a VPS (or other impact statement) should not be taken to indicate the absence of harm.

 

Loss of personal autonomy is an inherent feature of this offending and is reflected in sentencing levels. The nature of the relationship between offender and victim in modern slavery cases may mean that the victim does not recognise themselves as such, may minimise the seriousness of their treatment, may see the perpetrator as a friend or supporter, or may choose not to give evidence through shame, regret or fear. A victim’s apparent consent to their treatment should be treated with caution.

 

Sentencers should therefore be careful not to assume that absence of evidence of harm from those trafficked or kept in slavery, servitude or in forced or compulsory labour indicates a lack of harm or seriousness. A close examination of all the particular circumstances will be necessary.

Category 1

  • Exposure of victim(s) to high risk of death

A category 2 offence may also be elevated to category 1 by –

  • The extreme nature of one or more factors
  • The extreme impact caused by a combination of factors

Category 2

  • Serious physical harm which has a substantial and/or long-term effect
  • Serious psychological harm which has a substantial and/or long-term effect
  • Substantial and long-term adverse impact on the victim’s daily life after the offending has ceased
  • Victim(s) deceived or coerced into sexual activity

Category 3

  • Some physical harm
  • Some psychological harm
  • Significant financial loss/disadvantage to the victim(s)
  • Exposure of victim(s) to additional risk of serious physical or psychological harm
  • Other cases falling between categories 2 and 4 because:
  • Factors in both categories 2 and 4 are present which balance each other out and/or
  • The level of harm falls between the factors as described in categories 2 and 4

Category 4

  • Limited physical harm
  • Limited psychological harm
  • Limited financial loss/disadvantage to the victim(s)

Step 2 – Starting point and category range

Having determined the category at step one, the court should use the corresponding starting point to reach a sentence within the category range in the table below. The starting point applies to all offenders irrespective of plea or previous convictions.

An adjustment from the starting point, upwards or downwards, may be necessary to reflect particular features of culpability and/or harm (for example, the presence of multiple factors within one category, the presence of factors from more than one category (where not already taken into account at step 1), or where a case falls close to a borderline between categories).

Harm Culpability
A B C
Category 1

Starting point
14 years’ custody

Starting point
12 years’ custody

Starting point
8 years’ custody

Category range
10 – 18 years’ custody

Category range
9 –14 years’ custody

Category range
6 – 10 years’ custody

Category 2

Starting point
10 years’ custody

Starting point
8 years’ custody

Starting point
4 years’ custody

Category range
8 – 12 years’ custody

Category range
6 – 10 years’ custody

Category range
3 – 7 years’ custody

Category 3

Starting point
8 years’ custody

Starting point
6 years’ custody

Starting point
2 years’ custody

Category range
6 –10 years’ custody

Category range
5 – 8 years’ custody

Category range
1 – 4 years’ custody

Category 4

Starting point
5 years’ custody

Starting point
3 years’ custody

Starting point
26 weeks’ custody

Category range
4 – 7 years’ custody

Category range
1 – 5 years’ custody

Category range
High level community order – 18 months’ custody

Where another offence or offences arise out of the same incident or facts concurrent sentences reflecting the overall criminality of offending will ordinarily be appropriate: please refer to the Totality guideline and step six of this guideline.

The tables below contain a non-exhaustive list of additional factual elements providing the context of the offence and factors relating to the offender. Identify whether any combination of these, or other relevant factors, should result in a further upward or downward adjustment. In some cases, having considered these factors, it may be appropriate to move outside the identified category range.

Factors increasing seriousness

Statutory aggravating factors:

  • having regard to a) the nature of the offence to which the conviction relates and its relevance to the current offence; and b) the time that has elapsed since the conviction

Other aggravating factors:

  • Offending took place over a long period of time (in the context of these offences, this is likely to mean months or years) where not taken into account at step 1
  • Victim’s passport or identity documents removed
  • Large-scale, sophisticated and/or commercial operation (where not taken into account at step 1)
  • Substantial measures taken to restrain the victim
  • Victim forced to commit criminal offences (whether or not he/she would be able to raise a defence if charged with those offences), where not taken into account at step 1.

Factors reducing seriousness or reflecting personal mitigation

  • Offender has been a victim of slavery/trafficking in circumstances unrelated to this offence

Step 3 – Consider any factors which indicate a reduction for assistance to the prosecution

The court should take into account section 74 of the Sentencing Code (reduction in sentence for assistance to prosecution) and any other rule of law by virtue of which an offender may receive a discounted sentence in consequence of assistance given (or offered) to the prosecutor or investigator.

Step 4 – Reduction for guilty pleas

The court should take account of any potential reduction for a guilty plea in accordance with section 73 of the Sentencing Code and the Reduction in Sentence for a Guilty Plea guideline.

Step 5 – Dangerousness

The court should consider:

1) whether having regard to the criteria contained in Chapter 6 of Part 10 of the Sentencing Code it would be appropriate to impose a life sentence (sections 274 and 285)

2) whether having regard to sections 273 and 283 of the Sentencing Code it would be appropriate to impose a life sentence.

3) whether having regard to the criteria contained in Chapter 6 of Part 10 of the Sentencing Code it would be appropriate to impose an extended sentence (sections 266 and 279)

When sentencing offenders to a life sentence under these provisions, the notional determinate sentence should be used as the basis for the setting of a minimum term.

Step 6 – Totality principle

If sentencing an offender for more than one offence, or where the offender is already serving a sentence, consider whether the total sentence is just and proportionate to the overall offending behaviour in accordance with the Totality guideline.

Step 7 – Ancillary orders

In all cases, the court must consider whether to make a compensation order and/or other ancillary orders. The following are most relevant in modern slavery cases:

Forfeiture

A court convicting someone on indictment of human trafficking under section 2 of the 2015 Act may order the forfeiture of a vehicle, ship or aircraft used or intended to be used in connection with the offence of which the person is convicted (see section 11 of the 2015 Act).

Step 8 – Reasons

Section 52 of the Sentencing Code imposes a duty to give reasons for, and explain the effect of, the sentence.

Step 9 – Consideration for time spent on bail

The court must consider whether to give credit for time spent on bail in accordance with section 240A of the Criminal Justice Act 2003 and section 325 of the Sentencing Code.

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