Modern slavery and unethical international recruitment — our regulatory policy position

Care Quality Commission
4 min readNov 23, 2023

By Joyce Frederick, Director of Policy and Strategy, and Rebecca Bauers, Director for people with a learning disability and autistic people.

Our recent State of Care report showed that recruitment and retention remain a key challenge for providers across health and social care sectors. Over half of respondents to our survey of adult social care providers in England said they were having challenges recruiting new staff. 31% said they were having challenges in retaining them. This is despite a steady decrease in the staff vacancy rates for care homes — down from 11% in January to March 2022 to 7% in April to June 2023.

One way that providers have been meeting these challenges is by recruiting from overseas. Providers of adult social care services have told us that recruiting staff from overseas has enhanced the diversity and skills of their team and helped resolve staffing issues. There was a more than three-fold increase in international recruitment to direct care roles in the independent adult social care sector in 2022/23 compared with the previous year. And it’s clear that workers recruited from overseas can be a hugely valuable and important part of the workforce.

Chart shows the comparison of people arriving in the UK to work in adult social care between 2021/22 (20,000) and 2022/23 (70,000)

Worryingly, however, our State of Care report also highlighted that there’s been a large increase in issues surrounding modern slavery and unethical international recruitment. A nationwide shortage of health and social care staff, combined with recent changes to immigration visas, has increased the risk of unethical international recruitment practices and modern slavery. We made more than four times as many referrals for concerns relating to modern slavery, labour exploitation and international visas in 2022/23 than in 2021/22.

Chart shows comparison of number of referrals made to agencies by CQC regarding modern slavery in 2021/22 (8) and 2022/23 (37)

Modern slavery is defined as the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. Under the Modern Slavery Act 2015, it is a criminal offence to knowingly or to be in a position where you should know that persons are being held in a position of slavery, servitude, compulsory labour, or in fact facilitating their travel for the intention of exploiting them.

Unethical international recruitment can have a devastating impact — on everyone. From people using care, staff who are exhausted from working punishingly long hours, to the risk of artificially low prices leading to providers being undercut in the market. And, of course, people who have come here to work and found themselves in precarious, harmful and abusive situations.

What we have done:

We have recently published a regulatory policy position on modern slavery and unethical international recruitment. In it we make it clear that such practices are illegal and are incompatible with our values. We note that providers who treat their staff poorly are more likely to deliver poor quality care to the people who use their services. We also make it clear that anyone can become a victim of modern slavery — not only people recruited from overseas.

What we expect:

We expect providers to have policies and procedures in place to protect people and that offer support and guidance for staff if they suspect someone is at risk of modern slavery. Our statement sets out how we will react to such cases.

While there are limits to the direct action we can take, we work with other agencies to tackle these issues when we encounter them in our regulatory duties. If, during assessments, we identify signs of modern slavery or unethical international recruitment, we will log this risk. We will refer identified or potential victims though our established safeguarding referral routes and to first responder agencies under the National Referral Mechanism for victims of human trafficking or modern slavery.

Our new assessment framework will enable us to routinely assess how a provider is managing the risks of modern slavery and ensuring the wellbeing of internationally recruited staff. We will use all our regulatory powers and consider taking appropriate regulatory action where we see this pose a risk of harm.

Other agencies:

The sponsor licence scheme is run by the Home Office. In the year to March the government had issued 102,000 skilled worker, health and care visas to foreign workers — that’s up 171% on the previous year. The holder of a sponsor licence must be the registered provider — those providing the regulated activities. We will monitor registration applications to check for warning signs of possible exploitation. Where a registered provider holds a UK sponsor licence to recruit skilled workers, we will monitor notifications of them becoming dormant (for example, no longer delivering care from the registered location) to check for warning signs that could indicate modern slavery.

We commit to working with other organisations at a national level to address the root causes and reduce the likelihood of modern slavery and unethical international recruitment practices in health and social care settings. These include:

We also share national information about risks to equality and human rights, including those associated with modern slavery, through our existing memorandum of understanding with the Equality and Human Rights Commission.

It’s everyone’s responsibility to act if they see signs and indicators of modern slavery and unethical international recruitment. We want to ensure that these practices do not happen and people, whether working or receiving health and care services are protected from harm.

Joyce Frederick, Director of Policy and Strategy, and Rebecca Bauers, Director for people with a learning disability and autistic people.



Care Quality Commission

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