Referral into the NRM
When trafficking is suspected, police are required to refer victims into the NRM or notify the Home Office. The National Referral Mechanism (NRM) is the UK system used to identify, support, and protect people who may be victims of modern slavery or human trafficking.
Suspected trafficking survivors can get a Home Office decision on their trafficking status by referring into the NRM (National Referral Mechanism). This can only be done with survivors' consent, and is initiated by a designated first responder organization – including the police and certain NGOs. You can find the Government's official webpage on the NRM here.
NOA is not qualified to offer assessments or advice on individual cases. However, we have partnered with the charity Unseen, which has been empowering and supporting survivors of trafficking since 2008. In April 2026, Operation Cornpoppy, the Met's ongoing investigation into enablers of Mohamed Al Fayed's offending, announced that it has also begun to refer victims into the NRM.
Unseen (South West UK) and their partner NGOs Medaille Trust (Manchester, Halton, Hampshire, London, Swindon; Kent), BAWSO (Wales), and Migrant Help (Scotland) are willing to support survivors of exploitation at Fayed-controlled enterprises. These organisations can help survivors decide if they want to refer into the NRM and apply to have their cases recognised as trafficking by the Home Office.
First responders can advise on whether you must be physically in the UK when the referral is initiated.
What's the NRM for?
The National Referral Mechanism (NRM) is the UK system used to identify, support, and protect people who may be victims of modern slavery or human trafficking.
Its purpose is to make sure potential victims are recognised by authorities, given access to safe accommodation, healthcare, legal advice, and other support. Unless victims of trafficking are identified and referred into the NRM, the Government cannot recognise that trafficking has occurred – or take action to investigate or prevent it.
In order for the Home Office to make a decision about your trafficking status, you will need to share information about your exploitation with them via the first responder handling your referral, as you may also do with the police. If you have reported to the police, your police files may be accessed by the Home Office.
If you refer, the Home Office may share your information with the police. If you do not wish this to happen it is important to make this clear to the first responder handling your referral.
The information you share will include information identifying you and the circumstances of your trafficking. This information is protected and cannot be accessed by parties outside the government. You can find out more here.
To get help to decide if this step is right for you, here’s what you need to do:
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Review information on the NRM and first responding process. You can view the NRM prompt sheet here – this tells you what kinds of questions to expect.
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Contact a First Responder local to you, this will be the faster route into the NRM. The police and all local authorities can act as first responders.
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If for any reason you do not want the police or local authority to act as your first responder, you can utilize NGO first responders local. Please contact the organisation local to you from the list below.
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BAWSO (Wales)
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Migrant Help (Scotland)
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Unseen (South West)
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Medaille Trust (Manchester, Halton, Hampshire, London, Swindon, Kent)
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For support outside of these areas, Unseen may be able to provide support subject to a wait list.
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Trafficking investigation for a trafficking case
The Fayed operation, as described by survivors and documented in court proceedings, was not simply one man committing assaults. It involved women being recruited through job advertisements, subjected to medical examinations before they started work, required to sign non-disclosure agreements, transported between properties in the UK and abroad, and in some cases having their documents confiscated and movements monitored.
That pattern — consistently described across multiple survivors — maps onto the legal definition of trafficking under the Modern Slavery Act 2015, and the Sexual Offences Act 2003, which criminalise the recruitment, movement and harbouring of people for the purpose of exploitation.
College of Policing guidance states that every report of modern slavery must be investigated from the point of disclosure or suspicion, and that suspected modern slavery offences must be treated as a serious crime even when potential victims may not immediately identify themselves as such. Read more about why a trafficking investigation matters.
Duties apply to historical trafficking
As the government's investigations of Epstein trafficking in the UK show: historical trafficking must be taken seriously.
The Modern Slavery Act of 2015 is clear: police duties to identify victims and investigate trafficking apply in any suspected cases of trafficking, regardless of when the offending occurred.
"From 1 November 2015, specified public authorities are required to notify the Home Office about any potential victims of modern slavery they encounter in England and Wales...”
Government regulatory guidance is clear:
“human trafficking” means— (a) conduct which constitutes an offence under section 2 of the Act, or would constitute an offence under that section if the person responsible for the conduct were a UK national, or (b) conduct which would have been within paragraph (a) if section 2 had been in force when the conduct occurred;
The requirement is also confirmed in Home Office guidance and by the Independent Anti-Slavery Commissioner in correspondence with NOA.
Identification of trafficking – further guidance
While the legal definitions of trafficking for sexual exploitation are clearly defined under the Modern Slavery Act and preceding legislation, some areas of current policing and government guidance conflate Modern Slavery/Trafficking with Human Smuggling. This confusion has been highlighted as a concern by the Independent Anti-Slavery Commissioner (this report is worth reading).
NOA has submitted to the Home Office call for evidence on the identification of victims of modern slavery, which seeks to improve the modern slavery identification system.
Trafficking and the law
Under UK and international law, the Government and police must recognise individuals as potential victims of human trafficking where there are credible indicators of exploitation or control, regardless of whether a perpetrator is identifiable or prosecutable. Once such indicators are present, the duty to investigate is triggered and must be proactive and effective.
Trafficking investigations are required to go beyond individual suspects and examine wider networks, including recruitment pathways, patterns of abuse, premises, financial activity, and any institutional or regulatory failures that may have enabled the exploitation.
Failure to recognise victim status or to pursue these wider lines of inquiry may place the State in breach of its positive obligations under Article 4 of the European Convention on Human Rights, the Council of Europe Convention on Action against Trafficking in Human Beings, and its domestic statutory duties under the Modern Slavery Act 2015, including the obligation to identify, protect, and support victims of slavery, servitude, forced or compulsory labour, and human trafficking. Such failures may also engage the State’s duties under the Human Rights Act 1998 and relevant safeguarding and investigative obligations arising under UK public law.