The Guardian - "Trafficking victims should be granted leave to remain in UK, high court rules".
The High Court has ruled in a landmark judgement that victims of trafficking should be granted leave to remain in the UK. Before this ruling, the UK government would send accepted human trafficking victims back to their home countries where they were at risk of being trafficked again. Read more HERE.
No More Tiers for CBCT Training as Innovative Distance Training Courses Prove Highly Successful!
When the COVID-19 pandemic hit this year, leading to the first lockdown and subsequent social distancing measures, new solutions needed to be found to ensure that professionals could maintain their continuing professional development.
Working together with colleagues at the University of Hull, a new highly interactive and dynamic distance training programme addressing Child Criminal Exploitation was developed by Dr Craig Barlow. Also on the team from the University were Dr. Alicia Kidd (researcher in modern slavery at the Wilberforce Institute) and Dr. Luke Cartwright (lecturer in Social Work).
Using a virtual learning environment (VLE), this advanced training was provided to social workers, lawyers, police officers, teachers and researchers over two weeks. Craig Barlow said, "We ran this as a pilot program. We had no idea whether it would be successful and used this to gain critical feedback from professionals who were taking part. We learnt a lot in terms of the design and delivery of distance training and the course was extremely successful. With very positive and constructive feedback from participants it enabled us to continue to develop and refine not only content, but also delivery."
Since the pilots of the course in June, Dr Barlow has continued to work with the team in Hull to develop a suite of training courses on different aspects of modern slavery and human trafficking.
In November of this year, Dr Barlow and Alec Love delivered a highly successful Achieving Best Evidence course for social workers in Central Bedfordshire.
"It felt like a safe environment. Its the best virtual training programme I have been on!"
One social worker said, "I thought this was brilliant, I was skeptical about how I would engage with a 5-day virtual course based on previous day-long virtual courses, but this worked so well... It was really well paced with gaps within webinars so we could take time away and reflect and go through case notes. Both Alec and Craig were really approachable and friendly so it felt like a safe environment. It's the best virtual training programme I have been on!"
Another social worker agreed, saying, "I was really impressed by the quality of the content, especially as it is the first course that had been run online. Everything was presented well and the course notes were helpful. I think that the skills learnt will be invaluable in my role. Not just for ABE interviews but as interchangeable interviewing skills."
Distance Training in 2021
"I am very excited by what we've achieved this year using the VLE and our distance training model. In January, we will be delivering our Family Risk and Safety Assessment (FRaSA) training using the VLE in one London borough, and are currently developing some child exploitation programmes for three other boroughs and the Metropolitan Police." said Dr Barlow. "My ambition for this training, once we are past the restrictions placed on us by the pandemic, is that we will be able to blend teaching in the virtual learning environment with live face-to-face training back in the classroom where we can focus on practical skills training. It's a very exciting opportunity."
Court of Appeal Amends Judgement In Brecani-v-R Following Complaints About Inaccurate Statements. What has become known as the Brecani Judgement sent shock waves through the Legal Community, but an expert witness in the case confronted the Court of Appeal over factual inaccuracies leading to an amendment to the Judgement.
On May 25th 2021 the Court of Appeal concluded on the case of Kevin Brecani -v- Regina that the original trial judge was right to have concluded a NRM positive conclusive grounds decision by the Single Competent Authority that Kevin Brecani was a victim of Modern Slavery.
The judgement critisised the defense team for not providing their Expert Witness with crucial facts of the case and therefore had not considered the range of facts needed for reaching an informed opinion, nor was the Court persuaded that he had sufficient knowledge of Modern Slavery in the context of this case. The expert introduced by Brecani's defense team was Craig Barlow.
Barlow had not been provided with the opportunity to respond to the judgement before its publication which was unfortunate as there were factually incorrect statements made about him.
"I was shocked by the complete inversion of the facts of my qualifications and experience," said Dr Barlow. "These were then compounded by a number of inaccurate statements about my report that were misleading. I therefore wrote to the Registrar of the Court of Appeal. The two key points of complaint were:
The Judgement stated that Dr. Barlow had not completed his PhD Research, despite him clearly stating in his report that the research was complete.
The Judgement referred to his knowledge being based upon research that he had 'undertaken into the trafficking of children for the purposes of Criminal Exploitation as part of a PhD Course'."
Dr Barlow explained that a PhD is not a course but a substantial body of research offering new knowledge to the field; in this case, the trafficking of children for Criminal Exploitation. "In addition to this, I had provided a full CV and a list of similar cases in which I had provided evidence before the Brecani trial."
The Registrar considered Dr Barlow's complaint. It seemed that his CV and similar case work had not been put before the Court. In a letter to Dr Barlow the Registrar explained, "The Court proceeds upon the information put before it. Before a judgement is handed down it is provided to the parties expressly for the purpose of enabling any factual errors to be picked up. The appellant's legal team did not suggest that the Judgement contained factual errors."
The Judgement has now been amended to make clear, "He has completed his PhD research into the trafficking of children for the purposes of Criminal Exploitation at the Wilberforce Institute at the University of Hull." The Court referred to the shortcomings in the evidence provided by the defense team and did not criticise Dr Barlow.
Dr Barlow said, "I am very grateful to the Court for making this important amendment. Whether or not a report by an expert is ruled inadmissible is neither here nor there - I had been diligent in fulfilling my duties to the Court, I made it clear the provenance of the evidence of which I relied and the limitations of the evidence. I am appalled that my CV and experience had not been put before the Court together with my report (which included a summary of my qualifications and experience). If the judgement had been shared with me before it had been handed down, these errors would have been resolved and the reputational damage avoided"
Wilberforce Institute Announces Programme of FREE Public Lectures:
The Wilberforce Institute is a part of the University of Hull dedicated to researching Historical and Modern Slavery. Every year the Institute provides a fascinating and eclectic series of free evening lectures from academics and practice experts in the field from all over the country.
Radio Sputnik: County Line Gangs "If you're recruiting people who are in school that's an easy network" - Discussion with Dr Alicia Kidd, Wilberforce Institute.
The Children's Society has revealed that children as young as seven are being recruited by 'county lines' gangs to move drugs around the UK. In a new report, the charity said that a council worker it had spoken to said they were working with a seven-year-old victim, whilst a member of police staff confirmed they were working with an eight-year-old. With more on this story, Sputnik spoke to Dr Alicia Kidd from the Wilberforce Institute at the University Hull, in this interview.
Dr. Alicia Kidd (picture right) is a Post-Doctoral Researcher and modern slavery expert at the Wilberforce Institute, University of Hull.
Child Criminal Exploitation: Craig Barlow on the Conference Circuit.
Craig Barlow has been presenting his 'Circles of Analysis' model of Child Criminal Exploitation at a number of events over the past few weeks. These have included a post-graduate Symposium at St Mary's University in Twickenham (hosted by the Centre for the Study of Modern Slavery), the East Riding Safeguarding Children's Partnership Conference on Contextual Safeguarding, and the Lincolnshire Senior Practitioners Network Practice Development Conference in Oakham, with more events coming soon.
"I am tremendously grateful to the Social Workers, Police Officers, Lawyers and Academics who have contributed to the development of the Circles of Analysis Theory. This research is my PhD Thesis and has been funded by the Wilberforce Institute at the University of Hull," said Barlow. Whilst the final thesis will be submitted in the next few weeks, the model itself is being presented to academics and professionals at a range of events. A recording of the presentation at the East Riding conference is on the right and represents the compression of 3 years worth of research into just over 8 minutes!
Cannabis Court: Jury says trafficked man was victim, not criminal.
A Vietnamese man has become the first person in Northern Ireland to be cleared of criminal charges after putting forward a defence of human trafficking.
The ruling effectively overturned a Home Office finding which dismissed his claim of being a victim. Read more at the BBC HERE.
COMING SOON: New Webinars on Human Trafficking, Modern Slavery, Risk Assessment, and Safeguarding.
Craig Barlow has been delivering blended learning courses which combine classroom teaching and e-learning content through this website. This summer, Craig Barlow Consultancy And Training will be Launching new open-courses aimed at independent Practitioners and others who are always battling to fit in their CPD commitments with their daily schedules.
"The value of web-based teaching and learning sessions is their flexibility for learners." said Craig. "We can offer much of our terrific course content in small, topic focused webinars that can be built upon at the participants pace. We will be offering live sessions at different times and access to recorded sessions afterwards. We believe that this will provide a cost effective, valuable resource for colleagues to pursue their professional development interests, stay up to date, and link with other people who share an interest in a topic."
New FGM Assessment Tool for Social Workers now provided by the National FGM Centre.
The National FGM Centre has created a tool for Social Workers to help guide the assessment of cases where FGM is a concern.
This tool is not intended to replace professional judgement and only provides recommendations. The tool has two elements: Best Practice Guidance (which can be downloaded as a hard copy or viewed online from the National FGM Centre's website) and an Online FGM Assessment Tool which generates a risk level and relevant alerts regarding Mandatory Reporting and more.
Development of a Model of Criminal Exploitation of Children.
The 'Circles of Analysis' model is set to be a major development of the SIPPS approach to safeguarding and tackling human trafficking, exploitation and modern or contemporary slavery.
The research by Craig Barlow has been funded by the Wilberforce Institute for the Study of slavery and Emancipation and (WISE) and is expected to be complete by next Summer. The research has received a great deal of support and interest from Police Officers, Social Workers, Lawyers and other experts.
The next phase of the research is a series of focus groups which will test and evaluate the new model. These multi-agency groups are running across England and Wales and have been supported by the Modern Slavery Police Transformation team.
Craig told 'Police Professional' magazine that he is anticipating that by explaining and describing the relational contexts to the criminal exploitation of children in England and Wales, it will be possible to extend and improve the range of responses to the problem and share this more widely across other jurisdictions.
Striking an encouraging note, he said, "Despite what the national press, general media and some politicians might have us believe, we have some of the world’s best child safeguarding systems and expertise right here in the UK. If we understand trafficking and exploitation of children first as a pattern of child abuse, rather than trying to ascribe it to a category or type of crime, we can improve and develop and share joint agency responses. To achieve this, constant input and feedback from a range of professionals (but Police Officers, Social Workers and Lawyers in particular) has been invaluable. Over the coming months, I will be running focus groups to gain systematic and structured feedback on the model, effectively 'stress-testing' it, and ensuring that I am meeting that goal of producing something that is of real use and value to the professions.”
Read Tackling Child Criminal Exploitation, an article about this research for EMPAC - East Midlands Police Academic Collaboration. If you are a Police Officer, Experienced Social Worker or Lawyer and would like to participate in the research by joining a focus group please contact us.
The annual report from the National Crime Agency on the NRM data for 2017 indicates that the numbers of those referred have now topped 5000.
Download the NCA Report HERE
A record number of over 5,000 potential victims of modern slavery and trafficking were referred to UK authorities last year, according to the NCA Report. British nationals made up the highest number of cases for the first time, followed by people from Albania and Vietnam.
A notable statistic is the rise in the number of children thought to be victims, which rose by 66% from 2016. Perhaps it is of some reassurance that the agency suggests that increase in referrals was "driven by greater awareness" of the problem.
One reason for the increase in the numbers of children that are thought to be victims of trafficking and modern slavery is the growth of the 'County Lines' method of drugs supply, which uses children to courier Class A drugs from the city bases of the drug gangs to rural and coastal towns.
Investigators said this was largely the reason for the rise in the number of UK nationals involved - up to 819 last year from 326 in 2016.
Last year, 5,145 potential victims of trafficking and slavery were flagged up to the National Referral Mechanism, which identifies and supports victims; the highest number recorded by the UK authorities since the figures were first compiled in 2009, and a 35% rise from 2016.
The report found that forced labour accounted for 2,352 cases (almost half of all referrals), and that in a third of cases (1,744), it was suspected that people had been exploited for sexual purposes.
More than 2,000 children (2,118) were referred for help, compared with 1,278 the previous year.
Will Kerr, NCA director, told the BBC that greater reporting of modern slavery was behind the overall rise in referrals but that the figures "almost certainly represent an underestimate of the true scale" in the UK. He added that authorities were dealing with an "evolving threat" as criminals go into online spaces - particularly 'adult services websites', to enable their offending.
Modular Risk Assessment Training Program is well received by Social Workers.
The training programme Systemic Approaches to Risk Assessment and Child Safeguarding has been declared a success by social workers and managers in Medway. The course consists of 5 modules covering physical abuse, emotional and psychological abuse, sexual abuse, and neglect, as well as special issues relating to adolescents at risk of harm. The course structure is a blend of classroom-based learning and e-learning which allows participants access to additional resources, tools, and opportunities to recap learning points from the taught sessions.
Managers have noted an immediate impact citing improved confidence, improved analysis, and development of the professional discussions both within supervision and more general discussions between colleagues. The programme incorporated a 'Train the Trainer' module so that some of the modules can be run in-house in future but the access to trained practitioners locally also helps practitioners with the transition from classroom-based learning to daily practice.
The course has been so successful that it has been recommissioned.
SIPPS Domestic Trafficking and Criminal Exploitation of Children Training Course praised by participants in Knowsley and Sefton:
This new course was commissioned by Knowsley Community Safety Service through the Understanding Modern Gov (the training division of GovNet), the leading UK company running Public Sector events and exhibitions. With contributions from leading barrister and Modern Slavery expert Caroline Haughey, this course provided an environment in which professionals could develop their knowledge of the nature and dynamics of domestic trafficking and criminal exploitation, and build confidence in identifying and describing the problem, developing systemic safety plans to intervene and disrupt or prosecute offenders, divert potential children and young people away from exploitative relationships, and support those that have been exploited towards safety and recovery.
It was a highly interactive day as delegates posed interesting and astute questions throughout the day. The programme was built upon Craig Barlow's current research in the field of criminal exploitation of children, and drew on a range of practice examples and detailed case studies.
One senior member of the Community Safety Service said "This course has given us the academic weight to support what we are trying to achieve locally". Another practitioner said that Domestic Trafficking and Criminal Exploitation of Children was "a really enjoyable course. The theory added much needed contexts to my own thoughts and observations which I can evidence in decision making and practice". Further praise came from a locality team manager who said that the "training and tools given to support those being exploited were clear, concise and relevant".
"Of course I'm delighted that this course was so well received," said Craig Barlow, "But it is more important that training like this has practical, useful value to practitioners. The professionals on courses such as this are working with the issues every day, and what they value is the opportunity to develop their knowledge and practice experience through sound research-based theoretical models supported by practical demonstrations of theory in action. The commitment of everyone to the day was fantastic and it was really exciting to see how practitioners from law enforcement, Youth Justice and Social Care backgrounds were using the SIPPS model together to make some impressive analyses, and in so doing, come up with equally impressive and flexible solutions to problems."
The "Domestic Trafficking and Criminal Exploitation of Children Course is available as an In House course through Craig Barlow Consultancy and Training or ModernGov.
New Modular Risk Assessment Training Launches in Medway.
This week saw the launch of the Systemic Approaches to Risk Assessment and Child Safeguarding training for social workers in Medway, Kent. This innovative course has 5 modules beginning with the principles of risk assessment theory and practice. Module 2 provides practitioners with the Family Risk and Safety Assessment, a structured professional judgement framework for the assessment of risk for physical abuse, emotional abuse and neglect.
The remaining modules examine the issues relating to adolescents at risk of harm, children with sexually harmful behaviour and sexual abuse risk assessment.
What really excites us about this programme is that each module has classroom-based face-to-face teaching which is then supported by extensive web content contained within this website, downloads, the FRaSA e-manual, e-learning activities and discussion forums.
"This specialist training for social workers has taken months to design and develop," said course leader Craig Barlow. "But we are really pleased with the product, and initial feedback from course participants has been extremely positive. Classroom-based training is incredibly important, but we wanted to extend that experience back into day-to-day practice. This course is the solution; providing busy practitioners with fast access to up-to-date knowledge and research from the professional and academic literature, Q&A forums, and discussion groups in which those face-to-face exchanges of ideas and questions can be pursued and developed. Furthermore, practitioners can access that additional content when and where it suits them."
The Systemic Approaches to Risk Assessment and Child Safeguarding is a 5 month course with 6 face-to-face training days. For more information on how to arrange this program for your organisation contact us.
MARCO FANTON - VIDEOGRAPHER AND FILM MAKER JOINS OUR ABE SERVICE
Introducing our ABE Technical Operator: Marco Fanton
The Family Courts are increasingly ordering ABE compliant Video-Recorded Interviews for children to be enabled to give oral evidence to family proceedings, and calling upon Craig Barlow Consultancy & Training to undertake this specialist work. This has become an important extension of our ABE portfolio, which includes Training for Police Officers and Social Workers, advice and assistance with Interview Strategy, and Re:W Assessments.
Marco Fanton has now joined the CBCT team of associates as our Expert ABE Technician. Marco is an experienced Director of Photography and Film Maker with an incredibly diverse list of commercial credits to his name.
ABE Operator
Crucial to the ABE video-interview process is the smooth running of equipment, accurate recording, and a relaxed and comfortable environment for the child or vulnerable adult witness. "Marco's knowledge and experience is invaluable", said Craig Barlow. "Having him on the team substantially improves the flexibility we are able to offer in that we are not dependent upon the availability of police interview suites and equipment; we are able to be truly child-and-witness-led, meaning that with Marco's sate of the art recording equipment, we can set up an unobtrusive interview environment quickly and almost anywhere. This will be invaluable to some witnesses with special needs, physical disabilities and health issues".
Plymouth: 3 Women and 2 Men Jailed for 20 years and 6 months Following Prosecution for Trafficking Offences.
In the first case of its kind in Devon and Cornwall, followed a large and complex operation by Devon and Cornwall Police and its partner agencies. The operation resulted in the emancipation of 7 men, who had been trafficked for the purposes of labour exploitation.
Read more here: https://www.devon-cornwall.police.uk/News/newsarticle.aspx?id=2bb78bbe-2071-4223-9786-4e0eace57522
Independent Review of the Modern Slavery Act finds it is working but identifies wide ranging training needs.
Barrister Caroline Haughey undertook the Independent Review of the Modern Slavery Act.
Theresa May, whilst still Home Secretary, commissioned a review of the Modern Slavery Act, published in July. She commissioned barrister Caroline Haughey to undertake the Independent Review. Ms Haughey is one of the most experienced prosecutors in the field of Human Trafficking and Modern Slavery, and Craig Barlow has worked with her utilising the SIPPS Model to assist in the successful prosecution of more than 20 perpetrators of Modern Slavery Offences.
The Haughey Report identified that the operational response to Modern Slavery is improving, but also that training for police officers, investigators and prosecutors is "patchy". She has recommended a comprehensive plan for professional development at all levels, emphasising the need for a structured organisational approach to the identification, investigation, prosecution and prevention of slavery.
London Borough of Southwark recognises Craig Barlow Consultancy & Training as doing great work for Diversity in its Services.
In July 2014, the London Borough of Southwark agreed a new council plan that set out how it will deliver the Fairer Future vision. One of the commitments made in the plan is to build on the existing equality work by introducing a new Diversity Standard.
The Diversity Standard provides a baseline set of standards that organisations, including voluntary and community sector organisations, and businesses of all sizes can sign up to. Through the Standard, the council is recognising good practice among local organisations that are already doing great work in developing diversity.
The Standard has been shaped through discussions with representatives of some of the key forums and umbrella organisations in the borough, including the Business Forum and the Business Improvement Districts, Community Southwark, Southwark Multi-Faith Forum, and the Forum for Equalities and Human Rights in Southwark. It addresses all nine strands of the Equality Act: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation, as well as socio-economic status – the last being high on the council’s agenda.
Craig Barlow said "Quite a lot of effort goes into ensuring that our training reflects and respects the diversity of our participants and the communities in which they live and work. I really appreciate having this acknowledged by Southwark in such a public way and am proud to be able to display the Southwark Diversity Standard".
The Diversity Standard was approved by Southwark Cabinet in February 2016.
Unchosen makes valuable deposits in the CBCT Knowledge Bank.
The Modern Slavery Charity 'Unchosen' produces high quality films illustrating the nature and impact of Modern Day Slavery. They use film to create innovative DVD resources, which are used at events and trainings around the country to raise awareness of Modern Slavery. Some of Unchosen's films are made in-house, and some come from the Unchosen Short Film Competition.
Craig Barlow Consultancy & Training uses these films for SIPPS training courses, and now, Unchosen has generously supported our training even further with video links in our Knowledge Bank and other pages.
Find out more about the work of the Unchosen Team and their products and their Short Film competition by visiting www.unchosen.org.uk.
Domestic Servitude and Child Safeguarding - Children are Forgotten Victims. Craig Barlow, August 31 2016.
Father and son Ioan Berlan, 47, and Reni Parczewski, 25, worked a pregnant woman as their house servant after offering her accommodation at a house in Tottenham, North London. This month, Southwark Crown Court heard how the Polish woman was threatened with "grave consequences" if she failed to keep the home spotless. The victim's statement described how she was treated as "a toy" by a 5 year-old child in the home.
A neglected aspect of such cases is the impact upon children who are exposed to domestic servitude in addition to direct victims.
Domestic servitude has some specific characteristics that set it apart from other forms of forced labour. The perpetrators are often singletons or a couple, and the exploitation occurs within a family context. Facilitators may include intermediaries such as employment agencies, friends, or family of the end-user and/or the victim in the source country or destination country. Much of the logistics may well be co-ordinated by the end-user.
By nature, it is often a form of exploitation that is occurring within a family home. As a consequence, a part of the forced labour may involve the victim undertaking duties to children such as basic care, cooking, school run, etc.
Relevance to Safeguarding Children:
Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve seeing or hearing the ill-treatment of another, causing children frequently to feel frightened or in danger, or the exploitation or corruption of children.
There is increasing evidence of the adverse long-term consequences for children’s development where they have been subject to sustained emotional abuse. It has an important impact on the development of the child’s mental health, behaviour and self-esteem. Emotional abuse can be especially damaging in infancy. Underlying emotional abuse may be as important, if not more so, as other more visible forms of abuse with regard to its impact upon the child.
As adults, children who have witnessed violence and abuse are more likely to become involved in a violent and abusive relationship themselves. Children tend to copy the behaviour of their parents. Boys learn from their fathers to be violent to women. Girls learn from their mothers that violence is to be expected, and something you just have to put up with. This was a worrying aspect of the abuse in R-v-A where such statements were made by the husband and colluded with, or supported by other family members.
However, children don't always repeat the same pattern when they grow up. Many children don't like what they see, and try very hard not to make the same mistakes as their parents. Even so, children from violent and abusive families may grow up feeling anxious and depressed, and find it difficult to get on with other people.
A particularly troubling aspect to the impact of exposure to domestic servitude, is that the abuse is perpetrated and condoned by the children’s parents and possibly extended family. Children learn social norms, values, and behaviours from their parents. When the victim of domestic servitude is also required to tend to the needs of the children, attitudes to the victim are modeled by the adults.
Children are often the indirect victims of domestic servitude. Investigators need to recognise the presence of children and the effects of exposure to this form of abuse, in exactly the same way that we would with regard to domestic violence. At the point of identifying suspected Domestic Servitude, Children’s Social Care should be engaged in joint planning and investigation with the Criminal Investigators. Children within families may therefore be witnesses but should also be considered as indirect victims of the abuse i.e. suffering or likely to suffer significant harm.
Case Examples:
Siliadin v France 43 EHRR - A Case of Domestic Servitude:
A young woman who arrived in France at the age of sixteen had worked for several years carrying out household tasks and looking after their three, and subsequently four, children for seven days a week, from 7 am to 10 pm, without receiving any remuneration.
In February 2016, in Rochdale:
Psychiatrist Minu Chopra and her marine engineer husband, Sanjeev Chopra, (both aged 47) were charged with intentionally arranging or facilitating entry into the UK of a person with a view to their exploitation, and knowingly holding another person in slavery or servitude between January 1 2011 and July 31 2015. The alleged victim was a 28 year-old female. The couple had an 8 year old child.
Emanuel and Antan Edet kept Ofonime Sunday Inuk in Domestic Servitude:
Emanuel Edet was a doctor and his wife a senior nurse. Ofonime was made to sleep on a piece of foam and kept his meagre possessions in a cupboard under the stairs. Ofonime Inuk’s work included included cooking, cleaning and gardening and looking after the couple’s two children.
Case of R-v-SK (2011):
The victim, MM, gave evidence. She said she had worked as a cleaner at the hospital run by SK’s husband in an African country. After he had died, she was made redundant. SK then proposed that MM should come to the United Kingdom and work for her. MM said that when she arrived at the SK’s home she was not given her own room. She was made to sleep on a mattress on the kitchen floor. She had to keep her belongings in a shed outside. Often she was cold at night. SK required her to work all day and into the night. She cooked, cleaned, worked in the garden and attended to SK’s two children, which required her to work at night because both of them suffered from disabilities. She would only be allowed out to do the SK’s shopping or to take SK’s son for a walk. If SK wanted something she would ring a bell to summon the complainant. MM was expected to be available to SK 24 hours a day.
