Trafficking Identification
and Investigation
The abuse of hundreds of young women and girls by Fayed and his associates was enabled by a sophisticated sex trafficking operation. Anti-trafficking laws require police to look beyond individual offenders to investigate wider networks, recruitment chains, financial flows and institutional complicity. Yet the Met will not confirm that it is investigating trafficking at all.
What is sex trafficking?
Under the Palermo Protocol, the European Convention Against Trafficking (ECAT), and the Modern Slavery Act 2015, trafficking is defined by three elements: act, means, and purpose.
The act involves the recruitment, transport, transfer, harbouring, or receipt of persons; the means include coercion, deception, abuse of power, or exploitation of vulnerability; and the purpose is exploitation.
Sex trafficking involves sexual exploitation for any reason – it need not involve prostitution.
Crucially, trafficking does not require cross-border movement and can occur entirely within one institution or city. Survivors of the Fayed/Harrods case display all key indicators:
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recruitment through vulnerability;
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coercive control;
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transfer and harbouring within Fayed-controlled spaces;
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and sexual exploitation for power and gain.
Is the Fayed/Harrods case sex trafficking?
Despite identification of trafficking flags by lawyers, academics, the press – and the formal investigation of Fayed-connected trafficking in France – British government and police officials have yet to formally recognise that the exploitation of hundreds of victims may involve trafficking offences as defined under the Sexual Offences Act (2003) and Modern Slavery Act (2015).
Indeed, systematic medical testing; profiling of targeted victims; sham jobs; surveillance and harbouring on Fayed-controlled properties – strongly suggest that the entire Fayed system of exploitation should be characterised as a trafficking enterprise.
The failure to identify trafficking extends the silencing of victims and conceals the seriousness of the harm done. Identification of suspected trafficking also establishes the State’s responsibility to investigate, which “must go beyond individual suspects to examine wider networks, recruitment chains, premises, financial activity, and potential institutional complicity*”.
* Independent Anti-Slavery Commissioner
Was I trafficked?
When trafficking is suspected, police are required by law to refer victims into the NRM or notify the Home Secretary. Yet there are no known referrals of Fayed/Harrods cases into the NRM, and the Met's Cornpoppy investigation is narrowed to enablers of Mohamed Fayed's offending.
Survivors who wish to formally assess whether their cases fit legal definitions of trafficking, triggering the State's responsibility to investigate, can refer their cases into the NRM via experienced and respected anti-trafficking NGOs.
Fayed Trafficking Map
Trafficking involves the movement of victims for exploitation. Movement can occur within a building, between cities – or across continents. The Fayed Trafficking Map visualises the domestic and cross-border trafficking routes described in survivor accounts.
Click to enlarge
The Government's Responsibilities
The State has a legal obligation to investigate, protect, and provide access to justice for victims of trafficking.
Investigations must be prompt, independent, and capable of leading to the identification and punishment of those responsible – including wider networks, recruitment chains, premises, financial activity, and potential institutional complicity.
Regardless of when the offending took place, police must do one of two things if they suspect trafficking:
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Ask the victim for their consent to be referred into the National Referral Mechanism [NRM], which provides temporary and, after assessment, official confirmation of their trafficking status.
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If the victim does not give consent, police must notify the Home Secretary that suspected trafficking has occurred.
NOA is not aware of any Fayed/Harrods survivors being identified as possible trafficking victims.
Why does the identification and investigation of trafficking matter?
For survivors
Identification of the harm done is an important part of healing – especially after being silenced and dismissed for decades.
For the State
Identification of trafficking clarifies the State’s responsibilities to investigate the networks linking individual offenders and enablers in a system of exploitation.
For everyone
Identification of trafficking highlights the seriousness of the offending and the institutional failures to protect hundreds of victims. For those seeking change – stronger laws and consistent application of the laws we have – identifying trafficking names the problem we must collectively solve.
It should not be possible to operate a multi-decade sex trafficking operation from within a British company.
Nor should it be possible to cover it up – full stop.
Perspectives on Trafficking
Trafficking expert Professor Bridgette Carr on the Fayed case
"...the documentary failed to identify what happened as human trafficking. As a result... the BBC diminished what happened to the women and constrained our ability to secure justice for them."
– Professor Carr
French police investigate trafficking
“The police investigation, ordered by the Paris prosecutor's office, will focus on "potential acts of aggravated human trafficking…
with multiple victims"
– BBC
"Women were moved between countries"
“Ms Svensson claimed that women were being trafficked around the world, drugged, and were unwilling participants of al Fayed's.
She said that he decided to "traffic women... it's as simple as that."
– Kristina Svensson (survivor)
Al Fayed’s victims say compensation scheme ignores ‘trafficking’
"Harrods felt like a corporate trafficking system – not on the margins, but embedded in the very structure of the institution"
– Isabella (survivor)
Fayed accuser criticises Met refusal to investigate trafficking claims
“...in order to get this called trafficking, I’ve had to go to France. The Met are not calling it sex trafficking.
How do they expect us to have faith in this ongoing investigation that has been now a year into the works with zero arrests?"
– Pelham Spong (survivor)
Former Harrods Employee Accuses Al-Fayed of Trafficking and Says His Brother Knew
"Ali Fayed was a witness to her trafficking and has “unique and critical evidence regarding the direction, operation, and knowledge of a more than two-decade long trafficking scheme that ensnared and irrevocably injured what is reported to be more than 100 women.”"
– lawyers for Jane Doe (filing)
Leigh Day lawyer identifies trafficking in the Fayed case
“This should be properly viewed as an extreme example of sex trafficking because it involved a system within the Harrods organisation and elsewhere which enabled this abuse by the ultimate perpetrator, Al Fayed, and without that assistance and co-operation, it wouldn’t have been possible.”
– Richard Meeran
Fayed accusers unite
“Justine... called for recognition that many of the women had been trafficked. She said: “To deny that is to erase their rights, minimise their suffering and let corporate entities escape liability. The British justice system protected Fayed’s reputation before his death, but has failed to defend the women trafficked through his companies.”"
– Justine (survivor)
"We were lambs to the slaughter"
"Sexual assault, harassment, daily groping, trafficking, attempted rape, false imprisonment: that is what Lindsay says her reality was while working for Fayed"
– Lindsay (survivor)
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.
These obligations apply irrespective of when the exploitation occurred, including where historic trafficking is identified or disclosed after 2015.
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.
NOA Submission to the Home Office: Identification of Victims of Modern Slavery
Identification of Victims of Modern Slavery – Survivor-Led Response
This submission from No One Above (NOA) highlights systemic failings in how UK authorities, particularly the Metropolitan Police, identify victims of modern slavery.
Drawing on the Harrods / Mohamed Fayed case, where over 400 women and girls were exploited, NOA shows that police have repeatedly misclassified clear trafficking indicators as “historic sexual abuse,” denying survivors recognition and protection. This breaches UK duties under the Modern Slavery Act 2015 and the European Convention Against Trafficking (ECAT). Misclassification erases victims, shields perpetrators, and undermines justice.
NOA calls for mandatory training, historic recognition, independent oversight, and survivor-centred reform so the UK can meet its anti-trafficking obligations.
