Homes for Ukraine: safeguarding and modern slavery guidance

The Welsh Government is working to ensure that safeguarding is a central consideration in the systems, policy and advice being developed to support the arrival of people from Ukraine. We know this is also a priority for local authorities and relevant safeguarding partners.

Overall, local authorities are required to carry out their existing statutory safeguarding functions in relation to this individual sponsoring scheme, as they would for any other population in Wales. These responsibilities apply whether persons from Ukraine are accommodated with individual host sponsors, response hosts who support new arrivals via the Welsh Government’s super-sponsor route, and move-on host sponsor accommodation.

Advice on identifying and responding to safeguarding concerns about children or adults at risk (as defined in the Social Services and Well-being (Wales) Act 2014) is explained in the Wales Safeguarding Procedures and in the All Wales Practice Guides on Social care Wales.

Additional advice and guidance

A range of UK Government security checks including Police National Computer (PNC) and Warnings Index are carried out on people from Ukraine applying for a Visa. These checks must be passed in order for a visa to be issued. To be approved as a sponsor, The Home Office will undertake security and criminal checks on the sponsor and all adults aged 18+ who will live in the same household as the guests. This includes checks on government databases and other third parties such as the Police National Computer. Central government will make these checks on potential guests and sponsors when considering the visa application.

Local authorities will complete checks on the accommodation and living arrangements, along with safeguarding checks (including Disclosure and Barring Service (DBS) checks) to determine suitability of sponsors and hosts.  Local authorities may be in possession of information held on their systems, for example, safeguarding concerns, to suggest that individuals in the host address are not suitable to act as hosts. Checking of such internal systems is a decision for the individual local authority. In this way decisions that some individuals cannot act as hosts can be made by the local authority in advance of the Disclosure and Barring Service (DBS) checking process.

If a match is made which involves a person from Ukraine who is a child (i.e., under 18), an Enhanced DBS check will be undertaken on all members of the host household who are aged 16+.

If the local authority decides, that an adult guest that is not related needs more support due to age, disability or illness (that an individual aged 16 years and over within the household, intends to provide) then the local authority may ask for an Enhanced DBS check (including a check of the adults’ barred list) for those specific members of the household that will be providing the additional support.

In all other cases, including where there is a family relationship between the sponsor and the people from Ukraine, a Basic DBS check should be undertaken on all members of the host household who are aged 16+.

DBS checks and associated costs can be paid for from the tariff UK Government is providing to local authorities via the Welsh Government for each person from the Ukraine hosted in the UK.

Information for hosts and people from the Ukraine

In undertaking safeguarding checks, local authorities are asked to request that hosts complete the online safeguarding training module.

The Welsh Government has published a guide for sponsors that includes information for hosts on the need to report any safeguarding concerns and how to do so.

The Welsh Government’s Sanctuary website provides people arriving in Wales with information about life in Wales including how to report any safeguarding concerns.

Our National Advisory Service provide a free helpline between 09:00hrs and 17:00hrs, Monday to Friday on 0808 175 1508 or on +44 (0)204 542 , or via email: support@sanctuary.gov.wales.

Social media

We know there have been cases where individuals have used social media to match with a person or people from Ukraine. While social media and the internet have many benefits, there are also many risks in respect of safeguarding and the potential for exploitation.  

To ensure effective safeguarding for all individuals and families, the use of the RESET matching system is strongly encouraged.

Advice included in the guidance for sponsors states:

Social media: some do’s and dont's

Everyone uses the internet and social media to stay in touch and even more so when families are separated. This advice is to help you as a sponsor to protect the privacy and dignity of the person or people from Ukraine you are hosting. The good intentions of people can sometimes be taken advantage of by those less scrupulous. A sensible approach would be to ask yourself if you would be happy to have images and information shared about you or your family/children on a public network, with or without consent. Remember that children are unable to give ‘informed consent’.

As a sponsor, there are a range of simple things you can do to help secure privacy:

Do

Make sure that everyone in your home who is using social networks is aware of their security settings and how to change them.

Be aware that usernames, profile pictures and social media biographies are always public, even on private accounts.

Be very careful about friend requests from people you don’t know. Ensure that the person or people you are hosting have downloaded the ‘panic button’ onto Facebook.

Don’t

Publish photographs of the people you are hosting on public networks.

Publish any information about where the people you are hosting are living.

Publish any information about where the people you are hosting will be at a particular time.

Assume people are who they say they are.

If you are sponsoring people from Ukraine including a child or children, these resources for both adults and children are helpful: Children and young people - UK Safer Internet Centre and Parents and Carers - UK Safer Internet Centre.

Safeguarding home visits to host households

Following the arrival of people from Ukraine in to host households and to confirm that there are no safeguarding or wellbeing concerns about people from Ukraine or people already residing in the host household, it is suggested that a home visit is scheduled for the first week of placement and then the third week of placement. If no concerns are established following these home visits, then no further visits need be made. Local authorities will need to decide whether additional visits are necessary on a case by case basis. It is recommended that local authorities provide information about their services to host households.

Unless specific safeguarding and/or care and support needs are identified then home visits will not need to be undertaken by qualified staff/social workers. However, staff undertaking home visits should have undertaken relevant safeguarding training. As a minimum, this online safeguarding training should be completed.

Concerns identified through local authority safeguarding checks in advance of people from Ukraine arriving at host sponsor address

Where local authority checks identify that a sponsor and/or address is unsuitable on safeguarding grounds, the local authority should make a decision on the appropriate course of action, subject to the level of risk. Local authorities may wish to consider establishing a panel of relevant officers to consider cases.

Where a person(s) from Ukraine is at risk of immediate harm from a host sponsor and the local authority needs the assistance of Border Force to intercept people on arrival, the local authority should log this issue with the UK Government helpdesk (known as Jira).

Local authorities will need to register via the same link. In raising your Jira ticket, add ‘safeguarding’ to the subject header as these cases are prioritised.

Alternatively, local authorities can contact the UK Government Telephone Helpdesk on 0303 444 4445. This operates between 9am-6pm, Monday to Friday (except Bank Holidays).

The local authority will then need to arrange alternative accommodation for the person/people from Ukraine. Where people present or are identified as requiring emergency accommodation, it remains the responsibility of the local authority to identify suitable accommodation in their area. 

The local authority should also:

• as soon as possible, notify the person who has applied to become a host sponsor that they will not be able to act as a sponsor, in person or by telephone, followed by a letter or email. There may be cases where the local authority decides that the support of the police is needed in informing the person who has applied to become a host sponsor that they will not be able to act as a sponsor. This is a decision for local authorities to take on a case by case basis. If the local authority assesses that police involvement is necessary due to the risk to local authority officers, please contact the Police Liaison Unit on plu@gov.wales
• if the local authority believes there is a possibility that the person who has applied to become a host sponsor may have breached any conditions of a license or community sentence by applying to be a host sponsor the local authority should notify the Probation Service via: WalesPSIAR@justice.gov.uk
• raise a Jira ticket to request that the host sponsor is removed from the UK Government’s host sponsor list
• notify the Welsh Government of the actions taken by email support@sanctuary.gov.wales

Concerns identified or reported after people from Ukraine have started living with a host sponsor

Where a safeguarding concern is identified or reported after the hosting arrangement has commenced, the local authority should respond in the usual way, making decisions on a case-by-case basis in line with existing statutory duties.

Where the local authority believes the nature of the safeguarding concerns means that the person or people from Ukraine should no longer live at the host sponsor address, they should provide advice about the unsuitability of the current arrangements and associated risks and make recommendations about moving to alternative accommodation.  

In the event that a local authority makes a decision to remove people from Ukraine from a host sponsor address to alternative accommodation, they should notify Welsh Government of the actions taken by email: support@sanctuary.gov.wales.

Alternative and move on accommodation

The Welsh Government has published a Framework for Accommodation which sets out arrangements for housing people from Ukraine. You are advised to read this together with this guidance.

People from Ukraine going missing

The Welsh Government has provided advice in the guide for sponsors on responding in the event that a person(s) from Ukraine does not arrive at their address as expected. This includes making reasonable efforts to contact and locate the person(s) from Ukraine and in event that these attempts are unsuccessful, to make a missing person(s) report to the police.

In cases where we have been informed by UK Government that a person(s) has arrived in the UK on the Homes for Ukraine Super Sponsor Scheme but have been uncontactable by the National Advisory Service (NAS), staff there  will report the person as missing to the police on 101.

In cases where a person(s) from Ukraine have been contacted by NAS staff and have failed to arrive at initial accommodation, the local authority providing wraparound support into the temporary accommodation is required to report the person(s) as missing to the police on 101.

In cases where a person(s) from Ukraine is being hosted on the Homes for Ukraine Individual Sponsor Scheme and they fail to arrive at their agreed host sponsor, the host sponsor is required to report the person as missing to the police on 101.

Violence against Women, Domestic Abuse and Sexual Violence

Violence against women, domestic abuse and sexual violence (VAWDASV) covers a range of abusive acts and violence disproportionately committed against women, which can include, domestic abuse (physical, sexual, psychological, emotional or financial abuse and coercive control), sexual violence and rape, ‘honour-based’ abuse including female genital mutilation, forced marriage and ‘honour’ killings, as well as public sexual harassment.

Whilst the term VAWDASV acknowledges the vast majority of victims are female, the scope of domestic abuse, sexual violence and harassment can extend to all victims regardless of gender.

In Wales, the Violence Against Women, Domestic Abuse and Sexual Violence (Wales) Act 2015 aims to improve the prevention of VAWDASV and the protection and support provided to victims and survivors. 

Ukrainians coming to the UK may have experienced VAWDASV in their home country, as part of their journey to the UK or when they arrive in the UK.

Sponsors and hosts will need to be aware that Ukrainians coming to the UK may have experienced VAWDASV in their home country, as part of their journey to the UK or when they arrive in the UK.

Guidance for sponsors and hosts provides information on recognising VAWDASV and the relevant support services by completing the open access Welsh Government eLearning module. This is available bilingually and should take approximately 45 minutes. Guidance also provides details for  support services for people experiencing VADASV or for people who are concerned about others.

It is important that local authority staff engaging with Ukrainians have an awareness of what VAWDASV is, what signs to look out for and how to support anyone who has experienced VAWDASV or who is at risk of doing so.

Under the VAWDASV Act 2015, all local authority staff should undertake VAWDASV training.

Local authority staff working in a public facing role, coming into contact with potential victims of VAWDASV (clients in which either an assessment is made and/or care is delivered) should have also undertaken Ask and Act training. Ask and Act training provides the local authority workforce with the skills to safely ask and respond to disclosures of violence and abuse.

There are specialist VAWDASV support services in every region of Wales that can offer information, advice and support to victims of VAWDASV. Support can include; emotional, practical, access to emergency accommodation, educational and preventative measures, risk assessing and safety planning.

It is highly recommended that a referral to a specialist service is considered at the earliest opportunity following a disclosure of VAWDASV.

The Live Fear Free helpline

Our Live Fear Free helpline is a free, 24/7 service for all victims and survivors of violence against women, domestic abuse and sexual violence and those close to them, including family, friends and colleagues. Live Fear Free can be contacted in the following ways:

Call: 0808 80 10 800 (Croesawir galwadau yn Gymraeg / Calls are welcomed in Welsh)

Text: 0786 007 7333

Email: info@livefearfreehelpline.wales

Live chat.

Dyn Wales helpline, is an organisation supporting male victims of domestic abuse. 0808 801 0321 or email support@dynwales.org (support for male victims).

Welsh Women’s Aid is an organisation supporting Welsh women affected by domestic abuse.

BAWSO is a specialist organisation dedicated to supporting ethnic minority communities.

Meic is a free, confidential, anonymous, and bilingual helpline service for children and young people up to the age of 25 in Wales providing information, useful advice and support. Meic is open 8am - midnight, 7 days a week, by telephone, SMS text and instant messaging. 

Telephone: 0808 80 23456

Text: 54001

Live chat.

Modern slavery is an umbrella term that covers human trafficking, slavery, and forced labour. Modern slavery can affect people of all ages, gender and races and includes a range of different forms of exploitation. There are 4 main types of modern slavery:

1. labour exploitation
2. criminal exploitation
3. sexual exploitation
4. domestic servitude

As Ukrainian guests adapt to life in the UK, there is the possibility that they make be at risk of exploitation and modern slavery, by those seeking to profit from their exploitation.

Whilst modern slavery is a reserved matter, the Welsh Government works with partners in Wales, the Home Office, and other governmental and non-governmental agencies to tackle this crime and support victims and survivors.

Local Authority staff engaging with Ukrainians should have awareness of modern slavery.

Accessible and multilingual information and resources on modern slavery are also available at online sources including:

• The Welsh Government’s Sanctuary site
• The Welsh Government’s Live Fear Free site
• The Wales Safer Communities Network site
• Modern slavery awareness and victim identification guidance.

Local Authorities in England and Wales are required to follow the Statutory Guidance for England and Wales under section 49 of the Modern Slavery Act 2015. Local Authorities in Wales should also follow the Wales Modern Slavery Safeguarding Pathway.

There are many different signs of modern slavery that depend on the type of exploitation. Unseen UK, who run the Modern Slavery and Exploitation Helpline have produced information on signs of modern slavery to look out for.

Read Information about reporting modern slavery. In Wales, a Multi-Agency Risk Assessment Conference (MARAC) approach is adopted to refer adult victims into support and appropriate MARAC guidance should be followed. Complete the online form to make a National Referral Mechanism (NRM) referral.

Informed consent is required for an adult to be referred into the NRM. Where an adult does not consent to be referred, a Duty to Notify referral should be completed using the same online form.

Following referral to the NRM, a decision should be made within five days by the Home Office competent authority on whether there are reasonable grounds to suspect the person referred is a victim of modern slavery. This is called a Reasonable Grounds (RG) decision. Following a positive RG decision, the potential victim will enter a recovery period until a Conclusive Grounds (CG) decision is made.

Adults and their dependents should receive support through the recovery period. This includes financial support, medical support, accommodation, translation and interpretation services, and access to legal representation. Bawso are the Modern Slavery Victim Care and Coordination (MSVCC) service provider in Wales.

Children who are suspected victims of modern slavery must always be referred to the NRM and do not have to provide consent. In addition, children should also be referred to the Independent Child Trafficking Guardianship (ICTG) service. The ICTG service, operated by Barnardo’s, operates nationally in Wales. This service provides various practical, psychological, and emotional specialist services to children. Children can be referred using this online form. This is in addition to NRM and safeguarding referrals which must also be made.

The Gangmasters and Labour Abuse Authority (GLAA) have produced ‘Know Your Rights’ posters about exploitation in English and Ukrainian. Local authorities should ensure these posters are displayed in all Welcome Centres and initial temporary accommodation within their areas.

People seeking sanctuary from Ukraine have the right to work as soon as they have been given a visa to stay in the UK from Ukraine. However, offers of accommodation are not permitted to be linked to employment offers. While some sponsors may offer employment opportunities following Ukrainians arriving in sponsor accommodation, the employment rights of Ukrainians must be fully respected. They must not be required to take up or continue in employment in order to maintain their accommodation.