SCD9 performance and practice in the first six months

Report: 9
Date: 9 December 2010
By: Assistant Commissioner Specialist Crime on behalf of the Commissioner

Summary

On 1 April 2010 the Human Exploitation and Organised Crime Command, SCD9, was formed. The aim of the report is to inform the Metropolitan Police Authority of progress made by SCD 9 in the last six months. The report will highlight how, in a short period of time, SCD 9 has established itself as an efficient and effective command, already being seen as a centre of excellence in many areas such as tackling the trafficking of human beings, dealing with those that share indecent images of children and tackling organised immigration crime.

A. Recommendation

That

1. Members note the progress made by SCD9 to date.

B. Supporting information

Overview of the responsibilities of SCD9

1. SCD 9 comprises a number of distinct units located across London. The command has pan London responsibility for both reactive and proactive investigations targeting criminal networks in the following areas:

• Trafficking for Sexual Exploitation, Forced Labour and Domestic Servitude where there is a clear link to a transnational or Organised Criminal Network (OCN)
• On and off-street prostitution
• Organised immigration crime
• Obscene Publications, extreme pornography and the sharing of indecent images of children via the Internet
• Tackling violence and drugs supply within the night-time economy
• Tackling violence within promoted music events
• Casino fraud and money laundering.

2. The command consists of both uniform and detective officers as well as seconded staff from the UK Borders Agency (UKBA), and City of London Police. A structural chart of the command is shown at Appendix 1. SCD9 comprises the following units:

Abusive and Extreme Images Unit (AEIU)

3. This unit is responsible for investigating obscenity and extreme pornography as well as targeting those who share indecent images of children via the Internet. The unit’s priorities are to;

• Tackle the production, distribution and sharing of obscene material with importance given to the protection of the most vulnerable, particularly children
• To identify those sharing abusive images of children and obscene material via the Internet.

4. The unit holds the policy lead for the MPS on all obscenity and extreme pornography as well as leading on the use of Peer Precision software [1] to identify those that share abusive images of children. The unit is also engaged at national level developing policy and sharing best practice amongst other forces within the UK.

Clubs Unit

5. This unit is made up of two distinct teams, The Criminality, Drugs and Gaming Team and the Proactive Licensing Team. The Criminality, Drugs and Gaming Team targets OCNs that supply class ‘A’ drugs operating within London’s night time economy. The Gaming Unit is the only dedicated team in the UK tackling complex crime linked to casinos. It is nationally recognised as a centre of excellence providing intelligence and expertise within the MPS and to other police forces. The unit works closely with the Association of Chief Police Officers (ACPO) and the Gambling Commission, advising on gaming legislation.

6. The Proactive Licensing Team supports boroughs in tackling violence in problematic and high risk licensed premises, working with partners such as the Security Industry Authority (SIA), London Ambulance Service (LAS), and borough licensing teams. The unit offers a range of tactical solutions including carrying out covert and overt licensing visits, implementing action plans and assisting with applications for closure orders. The unit also offers a fast time solution to critical incidents occurring in licensed premises in the form of ‘Scarlet 100’, a vehicle crewed by experts in licensing legislation who are able to provide immediate support to borough Duty Officers. This particular tactic has been a key contributor in tackling gun crime in the nighttime economy [2].

Intelligence Unit

7. The unit is split into two teams, the Intelligence Unit and the Promoters Focus Desk. The intelligence unit provides the main analytical support for the OCU. Field Intelligence Officers develop intelligence from across the organisation and other law enforcement agencies in order to identify trends and develop both operational activity and problem profiles. The unit also provides the strategic and tactical assessments to drive operational activity. The Promoters Desk risk assess promoted music events in London working closely with borough officers and those involved in the music industry to prevent serious violence and harm occurring around these types of promotions [3].

Financial Investigation Unit

8. The Financial Investigation Unit supports all SCD 9 proactive investigations with financial intelligence or investigation. They secure and remove assets from those convicted of offences relating to SCD 9 objectives.

Trafficking and Prostitution Unit

9. The Trafficking and Prostitution Unit (TPU) tackle all elements of on and off street prostitution. The unit also undertakes both reactive and proactive investigations into trafficking for sexual exploitation, forced labour and domestic servitude. It is comprised of a Crime Team, Brothels Team, two Proactive Teams and an Olympic Borough Team. The TPU is seen as a centre of excellence both within the UK and overseas. It operates within London and, at times, both nationally and internationally to tackle those that traffick in human beings.

10. A large proportion of the work conducted by the unit involves the investigation of trafficking for sexual exploitation which reflects the global experience; international studies have shown that world wide at least 80 per cent of trafficking cases involve the trafficking of women for sexual exploitation. The unit have a number of investigations concerned with trafficking for domestic servitude and are shortly to commence an in-depth scoping exercise to gauge the extent of trafficking linked to forced labour; an area where limited intelligence exists [4]. Work has already begun to identify intelligence gaps in this area. As part of this scoping exercise, the command will be working with partners such as Greater London Authority, London Councils and Anti-slavery International to gain a more in depth knowledge around trafficking for labour. This research will assist in developing both operational and strategic approaches in combating this particular issue.

Organised Immigration Crime Teams (Operations Maxim and Swale)

11. Since April 2010 SCD 9 has taken the MPS lead for tackling organised immigration crime which includes identity document abuse, facilitation of persons into the country, bogus college investigations and those benefiting financially from these types of crime. Operational activity is conducted by two distinct teams. Operation Maxim works directly to SCD 9 and is a fully equipped MPS funded surveillance syndicate concentrating on the most serious offenders who operate within this sphere. Operation Swale is a joint MPS and UKBA team fully funded by the UKBA that is led by their staff and focuses on UKBA priorities such as identity offences, people smuggling and removing individuals from the UK who represent the greatest threat to public safety.

Overview of the changes and developments in policy and practice

12. With the creation of SCD 9 a number of pre-existing units moved into the command in their entirety. Pre-existing policies and practices within these units [5] have in the majority of cases remained unchanged. The picture around trafficking however is completely different and has required new developments in policy and practice. These include the introduction of an MPS Trafficking Standard Operating Procedure (SOP). This SOP outlines key areas such as investigative principles, victim care, and the key steps for all officers involved in the investigation of human trafficking. It also clearly sets out where individual and unit responsibilities lie to ensure clarity of approach. In addition, a number of existing SOPs such as that associated with nuisance brothels, carding [6] and kerb crawling offences have also been updated. This has enabled a greater quality of service to be given to victims of trafficking and promulgated best practice to borough officers.

13. To professionalise the service provided to colleagues across the organisation, and support victims in times of crisis, the command introduced 24/7 ‘on call’ support. This has ensured that officers are able to access specialist support at any time of the day where incidents of human trafficking are encountered. In addition officers from SCD 9 conduct a review of all MPS systems on a daily basis in order to identify any allegations or incidents recorded across to ensure consistency of approach to all investigations.

14. Since its inception, the command has developed a comprehensive referral [6i] system for Non-Government Organisations (NGOs) and partners, to enable any agency to refer victims of trafficking to the unit. Each of these referrals is assigned a dedicated officer who will complete a comprehensive assessment and investigation into each case. In addition, effective relationship building with NGOs has enabled greater communication between the command and partners [6ii]. As a direct consequence significant improvements have been made in the amount of intelligence, information and investigative opportunities available to the command. One recent example that demonstrates this is that recently, the Command has charged a suspect with one of the first prosecutions brought in the UK for trafficking for domestic servitude. This was a case referred directly by one of the trafficking NGOs. It necessitated rescuing the victim from their place of servitude and conducting enquiries in Tanzania. The ability to access this information, provide immediate intervention and conduct extensive enquiries in a relatively short space of time would not have been possible before as the lines of communication and operational resilience were not previously as effective as they are now. Since April the command has dealt directly with 225 other women, of which 75 have identified themselves as trafficked. All of these women have been debriefed and offered support and routes out of the environments within which they have been discovered. This enhanced engagement and information gathering has allowed the Command to have a better understanding of how traffickers operate, directly resulting in increased prosecutions of traffickers as well as refining the service provided to victims.

15. As part of the ongoing development of partnership working and stakeholder engagement, the OCU Commander has recently taken on the chairing role of the 2012 London Human Trafficking Network which brings together over 40 NGOs involved in tackling the trafficking of human beings. The network also includes key partners such as the MPA, GLA, Home Office and London Councils. The aim of this group is to develop longer-term solutions to tackling trafficking within London.

Data of cases SCD9 have investigated

16. Data provided from the MPS Crime Recording System (CRIS) highlights the rise in trafficking investigations this year. Between 1 April 2009 and 13 September 2009 a total of 12 classifications of trafficking were recorded on MPS systems. In the same period this year, since the creation of SCD 9, a total of 43 offences have been recorded; a 358% per-cent increase on the previous year. 34 of these crimes remain live investigations. In addition there are 8 proactive operations in existence with officers from the unit conducting investigations in Romania, Lithuania, Bulgaria, Hungary, Tanzania, Nigeria and Poland. There have been 8 convictions for trafficking for sexual exploitation since April 2010 with 5 cases involving 11 offenders currently awaiting trial. A further 4 trafficking cases are currently with the Crown Prosecution Service (CPS) for decisions on charging.

17. The TPU also continue to focus on street offences and problem brothels to assist local SNTs reduce anti-social behavior. This has allowed officers to gain a greater insight into the origins of trafficked victims and offer them a safe exit. Since April the unit has visited 92 brothels, arrested 61 men for kerb-crawling and been the first in the UK to use new legislation which criminalises men paying for sex.

18. The experience of SCD 9 officers is that women involved in the sex industry and those who have been trafficked predominantly originate from Eastern Europe [7] and South East Asia [8]. A breakdown of the nationalities of women that officers have engaged with is contained at Appendix 2. The majority of offenders tend to be from the same regions as those that are trafficked. The 11 convictions obtained since April 2010 are from two operations. Operation ICEFALL involved victims from South East Asia and Eastern Europe. The offenders in this case were from China and the UK. In the second case Operation BLUEBOK the victims were predominantly first generation UK women who originated from Iran. The offenders were Iranian but currently resident in the UK.

19. The AEIU have in the last 5 months executed 36 warrants in relation to those sharing indecent images of children. In the previous 12 months prior to the creation of SCD 9 the unit executed 46 warrants. The effective use of partnership working and joint investigative opportunities has significantly enhanced performance since the command was created and recently the unit has uncovered what is believed to be the biggest seizure ever of indecent images of children.

20. As well as instigating 5 proactive operations against suppliers of extreme pornography, since April the AEIU has increased activity in policing unlicensed sex shops across the MPD with a view to dismantling the OCNs linked to them. By working with local authorities and groups linked to the film industry they have charged 15 individuals with offences this year as opposed to 7 during the previous 12 months.

21. The Clubs Unit continues to tackle organized crime linked to London’s night-time economy and has already mounted 5 proactive operations since April exceeding their annual target. On joining SCD, the command demonstrated its ability to operate at the highest level by dismantling a major OCN utilising services provided by Commander Covert policing which led to the recovery of 3.5 kg of cocaine and convictions ranging from 4 to 7 years imprisonment.

22. The Clubs Unit continues to support TP boroughs by undertaking covert and overt licensing visits which include providing ‘Scarlet 100’, a fast time response vehicle providing licensing officers to critical incidents. Since April the unit has conducted 209 SIA [9] visits compared to 210 for the whole of 2009-2010, 28 covert visits and charged 3 individuals with offences.

23. The Gaming Unit which is unique within the UK and has a world wide reputation, continues to play a major role in developing and sharing intelligence with the casino industry both in the UK and abroad. They target individuals and OCNs using forged documents. This small unit has disrupted 2 OCNs and charged 7 individuals since April with offences ranging from large scale deception to forgery and identity offences which is an increase from last year’s results.

24. Operation Swale comprises of MPS and UKBA staff that are tasked and directed by the UKBA to achieve their targets. Since April the unit has arrested over 700 individuals of which over 170 were high risk offenders and detained for removal from the UK. Swale officers have also forfeited over £2.75 million from criminal gangs.

25. The Command continues to concentrate on those causing most harm to London and have already disrupted 10 criminal networks which is a 25% increase on last year’s figures.

Sanction detections

26. Since April this year SCD9 have investigated and recorded 27 different crime types ranging from human trafficking to prostitution and obscenity. The sanctioned detection rate for the command overall stands at 69%, well above the MPS target.

Partnership working

27. SCD 9 officers work both strategically and tactically with a wide range of agencies, NGOs and government bodies both within the UK and overseas. Elements of the command are currently working with police and NGOs in Thailand, Lithuania, Romania, Belarus, Poland, Bulgaria, Hungary, Tanzania and Nigeria. The Command is currently finalising the legislative processes, which will see the creation of two joint investigation teams with law enforcement agencies in Poland and Bulgaria. These agreements will enhance intelligence and speed up operational activity enabling the command to target those networks that operate both within the UK and in these countries [10].

28. The OCU Commander chairs a number of strategic meetings, which aim to develop intelligence and create joined up solutions to tackling the trafficking of human beings. Examples include a UK wide Operations and Intelligence meeting, which brings together practitioners from across UK law enforcement to develop best practice and share intelligence, and the London 2012 Human Trafficking Network which aims to enhance the provision of services and tactical investigation of cases of human trafficking within London [11]. The command is also represented on strategic work streams that work towards delivering the Government owned UK Trafficking Action Plan.

29. SCD 9 works closely with a number of stakeholders in order to provide a more joined up approach to trafficking and victim care. A recent development has been the embedding of officers with the Poppy Project [12]. All victims referred through the project are now debriefed by specialist officers from the command [13]. This approach has led to direct benefits; in a recent example, due to concerns raised by staff from the Poppy Project officers were able to engage directly with UKBA and challenge a decision not to support a victim of trafficking through the National Referral Mechanism (NRM); as a consequence the decision was reversed and the victim allowed to remain in the UK. The traffickers in this case were subsequently charged.

30. The OCU Commander has regular meetings with a number of strategic partners including the Chief Executive of Eaves Housing, the umbrella organisation under which Poppy sits, and ECPAT. This is to ensure that provision of services and police response is continually reviewed and where necessary improved. This has led directly to improved services, and greater connectivity between police and third sector organisations. SCD 9 attends national meetings and has been instrumental in the creation of a national intelligence-sharing programme to alert vulnerable people of risk.

31. SCD 9 supports a number of NGO and voluntary sector programmes in relation to trafficking. A recent initiative with ‘Stop the Traffik [14]’ involved officers from the command assisting communities to collate intelligence relating to trafficking. Other initiatives include the development of shared services with key partners such as the Salvation Army. This has resulted in the NGO providing SCD9 with support services and accommodation for victims of trafficking. To further improve victim care a process is being formalised to allow them to conduct additional debriefs following police intervention [15]. The Command also works with stakeholders such as Cambridge University, resulting in the development of support equipment such as MP3 players which deliver advice to trafficked women in at least eight languages to assist in translation during investigations.

32. The Clubs Unit works closely with a number of partners including the licensing trade and the SIA. This partnership work has enabled joint operational activity to be undertaken. Examples include the checking of door supervisors to ensure they are correctly accredited to support the SIA in subsequent prosecutions. In addition links with the casino industry remain strong providing valuable information and intelligence sharing opportunities. Partnership working in both of these areas has also led to the development of preventative work to combat fraud and violence in the night-time economy.

33. The AEIU work in partnership with a number of stakeholders including the British Board of Film Classification (BBFC), and Federation Against Copyright Theft (FACT). The BBFC provides the unit with evidential support and guidance, providing certification in relation to seized films and DVDs to assist in prosecutions for offences against the Video Recordings Act [16]. In addition regular meetings are held between officers from the unit and staff from FACT to examine material submitted to them by adult film-makers which fall in the grey area between acceptable and obscene material. These meetings determine FACT’s policies regarding the content of R18 films [17] and are essential to avoid a situation where police could prosecute a film which may be passed as being legal. Officers from the unit also sit as advisors on the BBFC Consultative Committee regarding quality assurance in relation to the classification of films. In partnership with FACT the unit has conducted joint operations which have resulted in the closure of several DVD production factories and storage addresses and led to the subsequent prosecution of offenders. In one operation over a million counterfeit DVDs including large numbers of obscene and extreme films were seized and an organised crime network destroyed. The information sharing agreement in place between the unit and FACT has enhanced operational activity and created greater efficiencies leading directly to more seizures and prosecutions.

34. With the pornographic nature of many of the operations conducted by the AEIU a recent partnership link up has been made with an organisation called DELTA. DELTA is a private company formed on a similar basis to FACT which focuses on the adult film industry and aims to prosecute those that are involved in the illegal adult film trade. The unit recently set up an information sharing agreement with them which has already been successful operationally, enabling DELTA to conduct their own prosecutions. This has led to greater efficiency within the command by freeing up resources to be redeployed on additional investigations.

35. Another priority of the AEIU is the targeting of those individuals that share indecent images of children via the internet. The unit works with a number of partners in this area. The Internet Watch Foundation (IWF) [18], supply the unit with details of offenders regarding obscenity, extremity and indecent images of children. This intelligence has led directly to prosecutions. In addition the IWF will issue web site hosts with take down notices [19] where officers come across sites that contain this type of indecent material. If these notices are not complied with then they are brought to the attention of officers within the unit for follow up action. The unit also has an ongoing partnership with the Child Exploitation Online Protection centre (CEOP). SCD 9 is the recognised UK lead on Peer Precision operations and assists CEOP with UK and International investigations. In a similar vein the unit also works closely with the United States Internet Crimes Against Children Task Force (ICAC). SCD 9 license and train UK, EU and International Law Enforcement officers in the use of various Hi-Tech Peer Precision Tools that locate and identify suspects offering to distribute indecent images of children via the Internet. Work is also currently underway between the AEIU and UKBA to develop a working partnership to combat those offenders who are importing and supplying obscenity and indecent images of children within the UK.

Standard Operating Procedures

36. To ensure SCD 9 continue to provide BOCUs with the appropriate support, guidance and expertise across a range of policing activities, a Service Level Agreement (SLA) has been produced outlining all parties’ responsibilities. A robust Tasking process in existence within SCD 9 enables officers from across the MPS to request assistance for any of the areas of responsibility for the command. This has ensured there has been no reduction in capacity, activity or support offered by the command to other business areas within the MPS.

37. SCD9 have commenced a training programme for local borough officers focused on the planning and progressing of kerb crawling and brothel operations. SCD 9 staff act as tactical advisors to local Safer Neighbourhood Teams (SNTs) enabling specialist advice to be given at crucial stages and at the same time empower local officers to undertake a significantly greater number of operations. Local officers will still retain ownership of local issues identified by their communities, with additional SCD 9 assistance where required. To increase resilience and flexibility, SCD9 have recruited members of the Metropolitan Special Constabulary (MSC) to work within the command, initiating a training package for MSC officers has enabled the them to take on additional areas of responsibility such as tackling the problem of carding as well as undertaking licensing activity and assisting the Extreme and Abusive Images unit with viewing obscene material.

38. Within the AEIU there is already in existence a policy whereby the unit assists boroughs who investigate offences regarding abusive and extreme images. This is in the form of assistance around viewing material and scheduling exhibits for subsequent prosecutions. This includes grading of images and advice around the appropriate legislation in this complicated area.

39. Investigations around licensing breaches and drug supply remain the responsibility of local boroughs, however the Clubs team is able to support borough officers in covert deployments and where additional operational assistance is required.

Preparing for the Olympics

40. In preparation for the 2012 Olympics SCD 9 has created a dedicated team funded by the Migration Impact Fund [20] who respond to all areas of trafficking and prostitution on the five Olympic Boroughs. The team advise and work closely with borough SNTs, Local Authorities, and a range of NGOs. Examples of the activities to date include the education and work place training of many SNTs and the collation of intelligence for local authorities and boroughs which has allowed brothel closure orders to be obtained. A number of street enforcement and covert operations have taken place and continue to take place to minimise the risk of a rise in trafficking or prostitution offences in the Olympic footprint area.

41. SCD Command Team are engaged at the more strategic level in preparing for the Command for 2012 and this includes representing the MPS at MPA trafficking project boards and SOCA programmes. In addition the chairing of the Human Trafficking 2012 London Olympic Network by the OCU Commander is aimed at developing cross organisational initiatives to prevent an escalation in trafficking at the 2012 Olympic Games.

42. To improve the intelligence gathered and shared with other agencies SCD 9 have centralised the Intelligence Unit which has given the command the capacity to continually scan law enforcement and open source databases to obtain a true intelligence picture and then quickly develop solutions to tackle trafficking both in the UK and abroad.

Examples of good practice and challenges

43. There have been a number of developments that have successfully driven and enhanced operational responses, from internal and external marketing, enhanced referral processes and operational delivery, some of which have already been detailed within the body of this report.

44. Investigations conducted by officers from the AEIU under Operation Caiman [21] have, since the formation of SCD9, significantly increased leading to a significant rise in prosecutions. In a number of cases this operational activity has enabled the identification and prosecution of contact abusers [22]. The most recent example being that of a male who was prosecuted for the sexual touching of his 9 year old sister and 3 year old second cousin. Without the efforts of officers from the AEIU and the pioneering use of the peer precision software these types of investigations would not have been possible. This work remains essential in the safeguarding of children from potential abusers.

45. To inform all MPS staff of the command’s formation and its areas of responsibility a comprehensive communications plan was instigated informing officers of the positive steps required in relation to the investigation of trafficking and the existence of the new command. This included a poster campaign placing material in every police station, a new SCD9 website and material circulated both inside and outside the MPS by the DPA. This has proved extremely successful with increased contact between officers from the command and borough staff as well as a reduction in complaints around the investigation of trafficking from victims and NGOs. In addition the command is now developing, in conjunction with NGOs, an external awareness campaign to increase opportunities for victims to come forward and report. The recent creation of a referral system whereby NGOs can submit reports through a dedicated E-Mail account on prepared documentation has directly resulted in an increase in the number of victims identified. To improve this service further SCD9 now plan to create a free phone direct line for trafficked victims which hopes to enhance services available to victims. In a recent document from the Rights of Women [23] organisation, which looked at responses to trafficking across the UK, SCD 9 was highlighted as best practice which should be adopted by other UK law enforcement organisations.

46. A significant success for SCD9 has been the increase in the number of trafficking investigations undertaken, charges laid and convictions achieved. The core of experience in tackling trafficking within the MPS was retained in the development of the command, particularly around trafficking for sexual exploitation. Since April officers have quickly gained experience in other aspects of trafficking, which has resulted in one of the first charges in the UK for domestic servitude. Since the creation of SCD 9 in April the Command has dealt with 43 cases of trafficking.

47. Training and raising awareness amongst officers and staff in relation to the identification of trafficked victims remains a key priority. The command has recently secured agreement from MPS Training Board to provide training for all front line responders. As a consequence, SCD9 have joined with the National Policing Improvement Agency (NPIA) to develop a computer based training package for MPS staff which will go live in late 2010. This training programme will be compulsory for all officers and staff in key front line public facing units. It is estimated it will affect over three quarters of MPS staff to ensure early identification of trafficking is a key priority and will reflect lessons learned from previous cases. The training is being developed with NGOs and stakeholders to encompass all areas of trafficking. In addition, to ensure staff have some understanding prior to this date useful literature and documentation has been placed on the SCD9 website.

48. Nationally SCD 9 was recently commissioned by ACPO and the Home Office to conduct a national review of off street prostitution in order to gain some insight into the proliferation of trafficked victims within the UK. The choice of SCD 9 leading on this work reflected the fact that the command not only had the greatest understanding of trafficking within the UK but also the ability to undertake significant work to prevent further offences taking place. SCD 9 were able to assist a number of forces within the UK in the development of their trafficking response within their own policing areas and share key intelligence in those areas in order to inform operational activity.

49. As the command develops the most significant challenge will be meeting the ever growing demand placed on the limited resources. SCD9 have found that the complexity of some investigations along with the growth in international travel and associated cost is putting the command under financial pressure. In addition the increase in trafficking investigations, which continue to grow month on month, will continue to put pressure on resources. Key areas such as a robust tasking process are ensuring that all operational activity is prioritised; funding success such as that of the Migration Impacts Fund have assisted in enabling greater flexibility within the Command but financial and resourcing pressures will continue to provide challenges in the future. SCD 9 continues to seek external funding opportunities to assist in meeting this challenge. Agreement has just been reached with Poland and Bulgaria to set up two distinct joint investigation teams between the MPS and these countries. Both of these developments come with some funding from the EU which will assist with some of the challenges outlined.

50. Operation Swale is one of the two teams responsible for tackling organised immigration crime and is fully funded by the UK Borders Agency. With the expected budget cuts that all organisations will experience as part of the comprehensive spending review there may be a likelihood that funding could be withdrawn which would impact on the team’s operational capability around organised immigration crime.

C. Other organisational and community implications

Equality and Diversity Impact

1. As part of the creation of SCD9 a new SOP for investigating human trafficking was written and published and a full Equality Impact Assessment (EIA) has been completed for the SOP. An EIA measures the adverse and positive impact of policing proposals on communities through a structured and transparent process. Specific areas identified in the EIA for further consideration and consultation were around race, age and gender but currently all activities are being monitored and reviewed.

Consideration of MET Forward

2. The work of SCD9 is crucial in tackling organised crime and working with partners to reduce criminality and increase confidence in policing. The command provides value for money under Met Specialist, Met Partners and with the work by the trafficking and prostitution unit supports Met Olympics

Financial Implications

3. The costs associated with the activities set out are all covered by existing budgets.

Legal Implications

4. There is ongoing legal debate as to the precise nature of the investigative obligation in respect of breaches of Article 3 of the ECHR (prohibition of torture) and Article 4 (prohibition of servitude). There is a school of thought that maintains that the investigative duty is absolute. Many of the investigations SCD 9 undertake fall within these articles. The Commissioner’s position is that there is an absolute duty to investigate wherever there is an ongoing risk of harm. Further that police are entitled to have a proper regard to resources and generally to have a proportionate approach in how matters are investigated where complaints are historic. A civil trial is to take place in March 2011 which will provide some certainty on this issue. There are also two cases currently before the European courts which will assist. Clearly SCD9 is best placed both to advise on, and where appropriate, carry out the investigation, and to ensure the necessary awareness exists throughout the organisation of these fast developing areas of law.

Environmental Implications

5. There are no environmental implications associated with this report.

Risk Implications

6. Since April 2010 SCD 9 has built on the previous good work of CO14, MPS HTT and Maxim team to develop an efficient and effective command. SCD 9 already has a strong brand name with other law enforcement agencies, NGOs and victims and is seen as a centre of excellence. While the command has dealt with a significant increase in trafficking allegations on behalf of the MPS, it has through effective planning continued to deliver in all other areas and is on track to achieve targets set for it.

7. Currently the command is running close to capacity in all areas and any reductions in staff would have a significant impact on the effectiveness of our response to meet demand. This would result in a review of the command’s activity to ensure core business needs are met.

8. To reduce demand on MPS staff, strong partnerships have and continue to develop with other agencies which are utilised where possible to provide victim care (Poppy), enforcement activity (Local authorities and Delta), and prosecutions (FACT, Gambling Commission and SIA). This strong partnership work also allows the command to manage expectations of what we as an organisation can and cannot offer to victims of crime and allows all agencies to allocate resources efficiently.

9. With the commands expanding remit, increased demand and moving into SCD, there is potential that requests for assistance from TP BOCUs cannot be met, particularly around ‘Street Offences’. To mitigate this, an SLA was agreed with TP and CO and a robust performance and tasking process has been developed to constantly monitor the OCU’s activity towards annual targets and to allocate resources.

10. At this time there are no known health and safety implications identified as a result of this report.

D. Background papers

None

D. Contact details

Report author: DCS Richard Martin, OCU Commander, SCD 9, MPS

For information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

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